A recent press release issued by the European Union confirms that the new EU sanctions will be published on Friday (12 September 2014). These will capture: A restriction on the provision of loans to five major Russian state-owned banks. A restriction on trade (and related services) in certain financial instruments with a maturity exceeding 30 days issued by certain banks, “Russian defence companies and three major energy companies”. A ban on the provision of…

The Netherlands Ministry of Foreign Affairs released the ‘Russia Manual’ which contains additional guidance on the application of the EU sanctions against Russia. The manual, which is currently only available in Dutch, summarizes the contents of the various EU Regulations setting out the EU sanctions against Russia, Crimea and Sevastopol. Below is a short overview of additional points of guidance set out in the manual: Export of dual use items (i.e., items included in Annex…

We have previously analysed some of the measures that the EU has been considering to adopt. In the meantime, it has come to our attention that: 1) The additional prohibition applicable to exports of dual-use items may be limited not only to those items listed in our previous blog post, but also to such supplies made to certain listed entities, including JSC Sirius, OJSC Stankoinstrument and JSC Kalashnikov. 2) The provisions regarding supplies of hydrocracking and desulphurisation…

On 9 August 2014, the German export control authority (Bundesamt für Wirtschaft und Ausfuhrkontrolle – “BAFA”) published a new template for an end-user certificate. The language of the template specifically addresses the exports of items to Russia. The template does not only contain the usual language, i.e. that the consignee will not use the items supplied for the development of biological or chemical weapons. Using this template, a consignee will, in addition, confirm that the items…