13.10.2022 — European Union Adopted Eighth Package of Sanctions against Russia

The new package of EU sanctions restricts seaborne transportation of Russian oil by EU parties to third countries other than where the sale is subject to a pre-set price cap. Moreover, the eighth package of sanctions introduces the prohibition of importing certain types of Russian steel products, plastics and chemicals into the EU. EU entities and individuals are also prohibited from rendering some types of services to the Russian companies and the Russian Government, including IT consultancy and legal advisory services.

On 06 October 2022 the European Union adopted the eighth package of sanctions against Russia. This package prohibits European operators from undertaking and supporting the transport of Russian oil to third countries except when the price conforms to a pre-set price cap. The restriction is effective with regard to oil starting from December 2022 and with regard to petroleum products starting from February 2023. At the same time, the new package of sanctions provides only the legal framework, but not the price cap itself. In particular, the price cap will be implemented through the exemption from the prohibition to provide technical assistance, brokering services or financial assistance, including insurance, related to the maritime transport to third countries of the Russian crude oil or petroleum products, which was introduced by the sixth package of sanctions, if the oil or petroleum products are purchased at or below a price cap agreed by the Price Cap Coalition.

Furthermore, the eighth package provides for restrictions on the import from Russia of certain types of Russian steel products, plastics and chemicals and other goods. The new prohibition also affects exports of electronic components suitable for creating weapons and additional goods used in the aviation sector to Russia.

The package of sanctions also includes the prohibition to render financial services (including auditing and accounting services), architectural and engineering services, legal advisory services and IT consultancy services to entities established in Russia and to the Russian Government. IT consultancy services cover consultancy services related to the installation of computer hardware, development and implementation of software. Prohibited legal advisory services cover the provision of legal advice to customers in non-contentious matters. The prohibition in particular prohibits legal advice on commercial transactions, including advice on the application or interpretation of law; participation on behalf of clients in commercial transactions, negotiations and other dealings with third parties; and preparation, execution and verification of legal documents. At the same time, prohibited legal advisory services do not cover representation of Russian parties in proceedings before administrative agencies, courts or other duly constituted official tribunals, or in arbitral or mediation proceedings, as well as offering advice, preparing or verifying documents in connection with such proceedings.

EU nationals are also prohibited from holding any positions on the governing bodies of select Russian State-owned or State-controlled legal persons, entities or bodies (including PJSC NK Rosneft, PJSC Transneft and PJSC Gazprom Neft).

Apart from that, the eighth package prohibits the provision of crypto-asset wallet services to Russian individuals and entities, regardless of the total value of such crypto-assets and extends personal sanctions to a number of Russian individuals and entities.