The 20th sanctions package is currently being proposed by the European Commission. To enter into force, the measures must be formally approved by the Council of the European Union and published in the Official Journal. The final scope, including the technical lists and possible product codes affected, will be known once the corresponding regulation has been adopted.

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New sanctions on exports of goods and services

The package incorporates new export bans to Russia affecting both industrial goods and specialized services, including:

• Rubber products.
• Tractors and certain industrial equipment.
• Cybersecurity services.

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Restrictions on the export of goods and technologies used in the Russian military effort, including materials used in the manufacture of explosives and other sensitive products, are also tightened.

These measures are in addition to the already existing restrictions on dual-use goods and advanced technologies, broadening the scope of control over export flows from the European Union to Russia.

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Measures to prevent indirect exports and circumvention

In order to reinforce the effectiveness of the sanctioning regime, the Commission will activate for the first time the anti-circumvention instrument. This tool will make it possible to prohibit the export of certain products to third countries when there is a high risk that they will subsequently be re-exported to Russia.

Within this framework, the export ban is contemplated:

• Numerical control machines (CNC).
• Radios and communication equipment.

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These restrictions will apply specifically to jurisdictions identified as having a high risk of re-export, introducing an additional control on indirect exports.

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Additional import restrictions

The package also includes new import bans from Russia, affecting:

• Metals.
• Chemicals.
• Critical minerals not included so far in the sanctioning regimes.

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In addition, a quota system for ammonia imports is proposed, with the objective of limiting the volumes currently imported.

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Other complementary measures

The new package is completed with:

• The extension of sanctions in the energy sphere, including a ban on maritime services for the transportation of Russian crude oil, conditional on a G7 decision.
• New measures against the so-called “shadow fleet”, with the inclusion of 43 additional vessels on the sanctions list.
• Additional restrictions on the Russian banking system and alternative payment channels, including measures related to cryptocurrencies.
• Strengthened legal safeguards to protect EU companies against infringement of intellectual property rights or expropriation resulting from abusive court decisions in Russia.