The European Union has adopted new sanctions against Russia and its supporters in China, North Korea and Iran. The so-called 15th sanctions package primarily includes restrictive measures in relation to the ‘Russian shadow fleet’. These are non-Russian ships that are used for the delivery of crude oil and petroleum products. The restrictive measures must also be observed by German companies.
The latest EU sanctions also include numerous individuals and organisations associated with the Russian military-industrial complex in the sanctions lists. In addition, the EU is imposing comprehensive sanctions against several Chinese actors for the first time with this package (travel ban, freezing of assets, ban on the provision of economic resources).
Further EU measures
In addition, the EU has now issued guidelines for Art. 12gb of Regulation (EU). According to this provision, all EU companies that export so-called Common High Priority items (CHP) (Annex XL of Regulation (EU) 833/2014) to any third country are obliged to carry out due diligence. CHP items are goods that have been found on the battlefields of Ukraine or that are suitable for the development, production or use of military systems. A large number of companies in the EU are affected by this provision.
Articles 12g and 12ga of Regulation (EU) 833/2014 are still relevant, as they oblige companies to include certain contractual clauses in deliveries to third countries in order to avoid circumventing deliveries. These provisions apply to all companies in the EU. They also apply to companies that have never operated in Russia or have since ceased to do so.
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