When the EU strengthened its economic sanctions against Russia on 12 September, EU Member States agreed to review the implementation of the Ukraine peace plan by the end of September. At the time, European Council President Herman Van Rompuy suggested that, if the situation on the ground warranted it, sanctions could be amended, suspended or even fully repealed. While no official press release has been issued, we understand this review took place on Tuesday 30…

In short, wider than originally anticipated. We previously analysed the targeted oil and gas restrictions regarding “equipment or technologies” listed in Annex II of Regulation 833/2014. These restrictions prohibit the sale, supply, transfer or export of Annex II technologies relating to “deep water oil exploration and production, Arctic oil exploration and production, or shale oil projects in Russia” to or for use in Russia. Currently the Regulation lists (only) goods which are referenced through…

On September 18, 2014, the German export control authority (Bundesamt für Wirtschaft und Ausfuhrkontrolle – „BAFA“) published an FAQ Document on trading with Russia. The most important clarifications by BAFA in the FAQ are the following: · Transit controls: In Germany, the following transit controls apply with respect to shipments destined to Russia: The transit of items suited for unconventional oil projects in Russia and the transit of dual use items destined for a military use…

The new measures include further restrictions on: (i) dual-use goods and technology to specified entities, (ii) the provision of services in relation to projects regarding deep water oil exploration and production, arctic oil exploration and production, or shale oil projects in Russia, (iii) services related to goods and technology listed in the Common Military List, and (iv) access to capital markets. They also introduce a new prohibition on certain types of loans and credit to…