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 technologies or equipment, and related services, are not included in the latest draft of the amending regulation.
3) The amending regulation may include a list of entities which provide military equipment or services and will have restricted access to capital markets, including Oboronprom, United Aircraft Corporation and Uralvagonzavod.
We understand that the amending regulation is now in final form, but that its adoption depends on the consent of all 28 Member States, which are currently in disagreement over the proper timing of the adoption.
