On 9 May 2023, the President of the European Commission, Ursula von der Leyen, announced further details on the proposed eleventh package of EU sanctions against Russia.

According to the press statement issued by the European Commission and related press reports, the proposed package mainly focuses on combatting circumvention of EU sanctions. More specifically, it would include the following additional measures:

  • Ban of ‘shadow’ entities from Russia and third countries that are intentionally circumventing EU sanctions. These restrictions will likely involve additional designated party listings of individuals and entities. Press reports indicate that, for the first time, various Chinese companies would also be among the parties that are being designated for aiding Russia. Additional designations of entities in other third countries, including the UAE, Uzbekistan, Syria and Iran, are also reported to be included.
  • Expansion of restricted item lists for controls on transit shipments through Russia to cover additional items, including advanced technology products and aircraft parts.
  • Introduction of restrictions on the sale, supply, transfer or export of certain items to specific third countries that are at risk of being used for circumvention. It is understood that this would be done through introduction of a “new tool to combat circumvention”, allowing the European Commission to propose restrictions on exports of certain items that are found to be going from the EU to specific third countries and eventually end up in Russia, which proposals need to be approved by the EU Member States.
  • Further restrictions on the import, transport and supply of Russian oil.
  • Prohibition to access EU ports and locks for vessels suspected or found to be in breach of the EU restrictions related to seaborne crude oil and petroleum products and vessels tampering their navigation systems when transporting such sanctioned Russian products.

The European Commission sent its proposal to the EU Member States last week. This proposal will be subject to further discussion, as unanimity among all 27 EU Member States is required before any additional measures can eventually be adopted and enter into force.


Derk advises clients on a wide variety of EU, regulatory and competition law matters, including merger control, cartels and vertical agreements. In addition, he advises and assists clients with respect to compliance and enforcement issues relating to EU and Dutch export controls, trade laws and sanctions. Derk has further acted for clients in various compliance investigations, both internally and involving government authorities.


Sietske is a Junior Associate within the Amsterdam competition and trade practice group. Sietske particularly focuses on EU/Dutch Competition Law, Dutch trade matters and compliance with EU sanction regulations. Competition matters that Sietske advises upon often include merger control, alleged cartel investigations, vertical agreements and FDI screenings. Trade matters may include export control, export license applications, and application of trade or sanction laws. Competition and trade matters may be advisory or as part of an Investigation of (public/private) procedure.