EU Adopts 11th Package of Sanctions Against Russia

  • 03 July 2023 03 July 2023
  • Commercial Disputes

On June 23 2023, the EU announced its 11th package of sanctions against Russia. Chief among the new measures is a new anti-circumvention provision, aimed at third countries through which Russia has sourced sanctioned goods. Additional measures target a further 71 individuals and 33 entities in the military, technology and media sectors.

The New Measures

Anti-Circumvention Tools

‘Third country’ gateways through China, Turkey, Armenia and Kazakhstan have undermined the effectiveness of EU export bans. The 11th package gives the EU power to restrict the sale and export of sanctioned goods to countries that present ‘a continued and particularly high risk of being used for circumvention for the benefit of Russia.’ 
The EU has clarified that third countries will only be sanctioned as a last resort, following a ‘thorough technical analysis’ and the unanimous agreement of all 27 member states. 

Additions to the Sanctioned Individuals and Entities List

104 new specific listings in the following sectors:

  • Military and Defence: Several senior Russian military officials and companies manufacturing weapons, vehicles and components. Separatist military officials responsible for shooting down flight Malaysia Airlines Flight MH17 in 2014 were also listed. 
    • An additional 87 entities supplying dual-use goods and technologies to Russia face tighter export restrictions. For the first time, entities registered in other jurisdictions, including Armenia, Hong Kong, Syria, the United Arab Emirates and Uzbekistan, are covered. 
  • Media: Media executives, propagandists and a television company. The Council also extended the suspension of broadcasting licences to five additional media outlets
  • Judiciary: Members of the judiciary who took politically motivated decisions against Ukrainian citizens who opposed the annexation of Crimea.
  • Finance: Two banks which operate in the annexed Ukrainian territories.
  • Forced Deportation: Individuals responsible for the forced transfers and deportation of Ukrainian children and the destruction of Ukraine’s cultural heritage. 

Additions to the Sanctioned Goods, Services and Technology List

The EU has expanded its restrictions for goods that contribute to the Russian military and industrial complex. These include:

  • Advanced Technology: Extension of the transit prohibition for certain sensitive goods (e.g., advanced technology, aviation-related materials) exported from the EU to third countries via Russia.
  • Information Technology: All IT companies that hold a licence administered by the Russian Federal Security Service or the Ministry of Industry and Trade were listed. The EU announced that the holding of such a licence would also be a criterion of designation in the future.
  • Iron and Steel: Importers of iron and steel that has been processed or produced in a third country must prove that any iron or steel products incorporated into the final product do not come from Russia. 
  • Intellectual Property: Prohibition on the sale, license, transfer or reference to intellectual property rights and trade secrets used in connection with restricted goods.
  • Military Items: Restriction on the exports of further 15 technological items found on the battlefield in Ukraine or equipment needed to produce such items. 
  • Cars and Yachts: A full ban on all new and second-hand cars above a certain engine size, and all yachts. 


The 11th package makes the following changes to oil importation rules:

  • The temporary derogation allowing Germany and Poland to import Russian crude oil through the northern section of the Druzhba oil pipeline has been ended. 
  • Narrow derogations have been introduced to existing export bans relating to the Caspian Pipeline Consortium, which transports Kazakh oil to the EU through Russia. 
  • The exception to the oil price cap for Sakhalin oil for Japan has been extended until 31 March 2024. 


The 11th package also introduces transport restrictions by road and sea with the following measures:

  • A full ban on trucks with Russian trailers and semi-trailers from transporting goods to the EU
  • A ban on access EU ports for vessels that engage in ship-to-ship transfers suspected to be in breach of the Russian oil import ban or G7 price cap
  • A ban on access to EU ports for vessels if they do not notify the competent authority at least 48 hours in advance about a ship-to-ship transfer occurring within the Exclusive Economic Zone of a Member State or within 12 nautical miles from the baseline of that Member State's coast
  • A ban on access to EU ports for vessels which manipulate or turn off their navigation tracking system when transporting Russian oil subject to the oil import ban or G7 price cap

Further Resources


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