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The EU adopts 15th sanctions package against Russia and Belarus

18 December 2024
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The EU adopts 15th sanctions package against Russia and Belarus
Chapter
  • Chapter

  • Chapter 1

    Overview of the 15h sanctions package
  • Chapter 2

    What to expect next?
  • Chapter 3

    Annex – List of the new sanctions regulations published on 16 December 2024

On 16 December 2024, the EU adopted several new sanctions measures, including its 15th package of sanctions against Russia which expands the sectoral and financial restrictions applicable to Russian persons.

The EU also adopted new sanctions targeting Belarus, Haiti, Sudan and North Korea.

Chapter 1

1

Overview of the 15h sanctions package

expanded collapse

EU Russia sanctions

The main elements of the new package include: 

  • extension of the wind down of the authorisation ground for the import and export of restricted items and provision of restricted professional services and software for divestment until 31 December 2025; 
  • addition of 52 vessels involved in circumventing sanctions by transporting warfare material and oil to the list of vessels subject to a ban on port access and services;
  • introduction of the prohibition to recognise or enforce certain rulings issued by Russian courts under Article 248 of the Russian procedural code, which grants exclusive jurisdiction to Russia’s courts;
  • a new authorisation ground for the release of cash balances held by EU central securities depositaries to meet legal obligations to clients;
  • a new non-liability clause for the payment of interest or any other compensation by central securities depositories to the Central Bank of Russia made in good faith;
  • addition of 32 military-related entities including not only Russian but also Chinese, Indian, Iranian, Hong Kong, Serbian and U.A.E. companies to the list of entities which cannot benefit from exemptions and authorisations related to exported restrictions (Annex IV); 
  • designation of 54 individuals and 30 entities, including civilian airline UTAIR, manufacturer of aircraft parts Aerosila, and private air transportation company Leading Charter Technologies, which are now subject to asset freezing measures. In total, as of today, 1,829 persons and 496 entities are subject to asset freezing measures under the EU Russia sanctions.  

For the first time, Chinese and Hong Kong persons and entities have been subject to asset freezing measures under the EU Russia sanctions. One EU individual has also been added to the list of asset freeze measures. These new asset freeze measures include JSC Gruppa Kremniy El, a manufacturer of microelectronics and microchips and Asia Pacific Links, a Hong Kong-based company supplying microelectronic components to Russian companies. 

Russian hybrid threats 

Additionally, under the new legal framework to respond to Russia’s destabilising activities against the EU organisations and third countries, which was introduced earlier this year, 16 individuals and 3 entities have been sanctioned, including a covert unit of the Russian military intelligence GRU Unit 29155, disinformation network Groupe Panafricain pour le Commerce et l’Investissement (GPCI) and African news agency African Initiative.

EU Belarus sanctions

The EU also expanded sanctions against Belarus, imposing asset freezing measures on 26 individuals and 2 entities, including a Belarussian transport and storage company, Vlate Logistik LLC.

Other sanctions

The EU added new designations to its Haiti, Sudanese, and North Korea sanctions regimes.

Chapter 2

2

What to expect next?

expanded collapse

This sanctions package is expected to be the last sanctions package of the Hungarian Presidency of the Council of the European Union. From January 2025, Poland will take the presidency of the Council. It is expected that Poland will work on the adoption in Q1 2025 of a 16th sanctions package that may contain new measures that could impact EU operators significantly. The adoption of new EU sanctions requires a unanimous decision by all Member States of the European Union.

Chapter 3

3

Annex – List of the new sanctions regulations published on 16 December 2024

expanded collapse

Russia

Council Regulation (EU) 2024/3189 of 16 December 2024 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Regulation (EU) 2024/3192 of 16 December 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Implementing Regulation (EU) 2024/3183 of 16 December 2024 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Implementing Regulation (EU) 2024/3188 of 16 December 2024 implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilizing activities

Belarus

Council Implementing Regulation (EU) 2024/3177 of 16 December 2024 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

Haiti

Council Implementing Regulation (EU) 2024/3138 of 16 December 2024 implementing Regulation (EU) 2022/2309 concerning restrictive measures in view of the situation in Haiti

Democratic People’s Republic of Korea

Council Implementing Regulation (EU) 2024/3152 of 16 December 2024 implementing Regulation (EU) 2017/1509 concerning restrictive measures against the Democratic People’s Republic of Korea

Sudan

Council Implementing Regulation (EU) 2024/3156 of 16 December 2024 implementing Regulation (EU) 2023/2147 concerning restrictive measures in view of activities undermining the stability and political transition of Sudan


Authored by Lourdes Catrain, Aline Doussin, Y. Alp Ozturk, Pierre Estrabaud, Kacper Maksymczuk, Helka Kittila.

Companies should continue to review their business activities and trade compliance procedures regularly to confirm they are in compliance with applicable new restrictions. Hogan Lovells lawyers can assist you with assessing the potential impact of these and other trade restrictions on the global operations of your company.

 Please contact any of the listed Hogan Lovells lawyers for further information or assistance.

Contacts

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Lourdes Catrain

Partner

location Brussels, Madrid

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Aline Doussin

Partner

location London, Paris

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Kate Poppitt

Senior Associate

location London

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Pierre Estrabaud

Associate

location London

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Y. Alp Ozturk

Associate

location Brussels

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Daniel Shapland

Associate

location London

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Jamie Rogers

Partner

location London

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