In brief

After intense debates in the Council of the European Union, the EU has agreed on an 11th package of sanctions against Russia and its supporters in their aggression against Ukraine.

The relevant Council Regulation (EU) 2023/1214 and Council Regulation (EU) 2023/1215 (respectively amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014) have been published in the Official Journal of the EU, LI 159/1 on 23 June 2023. Following publication, the amending regulations entered into force on 24 June 2023. The 11th EU-Russia Sanctions Package includes, among other key elements, new targeted sanctions against individuals and entities, an expansion of the restrictions on the sale, export and now also transit of certain goods and technology, as well as additional measures to prevent circumvention. It introduces a new anti-circumvention tool that allows the EU to restrict the sale and export of sanctioned goods to certain third countries. Moreover, the new package targets “shadow” entities from Russia and third countries that intentionally circumvent EU sanctions.

Detailed Content of the 11th EU Sanctions Package

1. Anti-circumvention tools

The new sanctions restrict “the sale, supply, transfer or export of goods and technology” to countries that are at “risk of being used for circumvention.”

The EU has assessed that so far, exports of prohibited EU goods to Russia via third countries have undermined the effectiveness of the measures. Sensitive products and technologies are still being sold to Russia through states such as Armenia, Kazakhstan, China, Turkey and others. To end circumvention, the EU is now able to restrict the sale and export of sanctioned goods and technology to countries that are “at continued and particularly high risk of being used for circumvention for the benefit of Russia.” This will be a last resort measure when other individual measures and outreach by the EU to concerned third countries have been insufficient to prevent circumvention.

The 11th package also targets “persons and entities circumventing the Union’s restrictive measures by activities which have the aim or result of frustrating the prohibitions in those measures. This concerns, for example, companies established in third countries, which obtain goods subject to restrictions from companies established in the Union and which are then supplied to Russia, directly or through intermediaries.” While circumvention and indirect sales and exports of sanctioned goods and technology through third countries to Russia are already prohibited, the new anti-circumvention tools aim to ensure that EU sanctions are better enforced and implemented. The provisions first list sensitive products in terms of circumvention, then the countries where they are being shipped.

Third countries will be targeted by export restrictions if all 27 member states unanimously agree.

It should be noted that “such action should be proportionate and solely aimed at depriving Russia of the resources which allow it to pursue its war of aggression against Ukraine.” Before imposing such a measure on the respective country, EU countries will receive “a thorough technical analysis” from the Commission, including trade data and information about efforts “to address the matter with the third country in question, and a clear indication that such efforts were not successful.” Moreover, before making any such proposal of sanctioning third countries, “alternative measures” should be considered, such as individual listings.

2. Additional EU Designated Parties

The EU has added another 71 individuals and 33 entities to the list of EU designated parties (Annex I to Regulation (EU) 269/2014) which have contributed in various ways to the war, especially for involvement in deportation of Ukrainian children to Russia. Listed persons and entities are subject to an asset freeze, and funds and economic resources must not be made available to them directly or indirectly.

3. Additional goods and technology specific restrictions

The EU has expanded its lists of goods and technology subject to specific restrictions in several categories including on goods and technology that could contribute to the technological enhancement of Russia’s defense and security sector.

The EU is banning the transit of certain sensitive goods like advanced technology or aviation-related materials, exported from the EU to third countries, via Russia.

The 11th sanctions package also tightens already existing restrictions on the import, transport and supply of Russian oil. The temporary derogation allowing Germany and Poland to receive Russian crude oil through the northern section of the Druzhba oil pipeline is ending.

Additionally, another 87 additional entities supporting Russia’s military-industrial complex are included in Annex IV of Regulation (EU) 833/2014. For the first time three Chinese companies are encompassed due to a “key enabling role” in supplying “electronic components for use by Russia’s military.” Also included on the list are two companies from the United Arab Emirates, two from Uzbekistan, one from Syria and one from Iran. Annex IV encompasses targeted end-users, to which the deliveries of items may not be authorized by the competent authorities notwithstanding a general possibility to authorize respective deliveries under the EU Russia Sanctions regime. Four Iranian entities are added as well as other third-country entities (Uzbekistan, Syria, UAE, Armenia and Hong Kong, China). The underlying rationale of these additional listings is to rule out a supply of controlled goods via third parties.

Other measures include:

  • A Prohibition on the sale, license or transfer of intellectual property rights and trade secrets used in connection with restricted goods.
  • The suspension of the broadcasting license of RT Balkans, Oriental Review, Tsargrad, New Eastern Outlook and Katehon in the EU.
  • A ban to transport goods into the EU with trailers and semi-trailers registered in Russia.
  • A prohibition on imports of steel products from third countries if they contain components originating from Russia.

4. Restrictions for vessels accessing EU ports

Vessels “suspected or found in breach” of the EU import ban on Russian seaborne crude and petroleum products or the G7 price cap via “ship-to-ship transfers” will be prohibited from accessing EU ports and locks. The same ban applies to vessels that “illegally interfere, switch off or otherwise disable their navigation system” when transporting these sanctioned Russian products.

5. Extension of derogations

The exemption provided in relation to the Sakhalin-2 Project, located in Russia, will be extended until March 31, 2024, to ensure Japan’s energy security needs. Current rules would have led to expiry on June 5, 2023.

The new package provides derogations to allow goods and technologies, technical and financial assistance, as well as engineering services for the operation and maintenance needed to keep the Caspian Consortium Pipeline working.

The infrastructure allows the “purchase, import or transfer” of Kazakh crude oil, which is only loaded in Russia, or departs or transits from its territory.

6. Impact and Outlook

The EU sanctions regime has been significantly expanded. In particular, the new anti-circumvention measures will affect the internal compliance program and risk analysis of EU companies. Transactions with third countries will require increased scrutiny and diligence of the risks of onward-sale and end-use in Russia.

Given the intense negotiations preceding the recent regulations, it is only a matter of time when discussions about the next sanctions package will start.


Anahita heads Baker McKenzie's International Trade Practice in Germany and is a member of our EMEA Steering Committee for Compliance & Investigations. Anahita is Global Lead Sustainability Partner for our Industrials, Manufacturing and Transportation Industry Group and a member of the ABA International Human Rights Steering Committee. Anahita focuses her practice on global investigations and white-collar crime proceedings before German authorities and courts. She has significant experience advising on internal compliance programs, accompanying internal and external investigations and self-disclosures, inter alia in cases of breaches of sanctions, export control, human rights, data protection and foreign investment review, closely collaborating with the competent authorities.


Alexander advises clients on the international, European and public law governing international trade. His practice encompasses advising on sanctions and embargoes, trade defense instruments, export control regulations, foreign investment review and international investment law as well as human rights and sustainability due diligence and compliance, including on the German Supply Chain Due Diligence Act and the EU Directives on ESG compliance. Alexander furthermore advices on trade policy, free trade agreements, disputes arising out of these and customs matters.


Kimberley focuses on international, European and public law governing international trade compliance and sustainability. She advises clients on internal compliance systems, sanctions and embargo regimes, export control law and foreign investment reviews. She accompanies internal and external investigations and self-disclosures of export control and sanctions breaches. In addition, she assists clients in complying with the rapidly evolving EU and German legal landscape on sustainability, in particular the new directives and regulations under the EU Green Deal and the German Supply Chain Due Diligence Act. This includes setting up and improving corporate governance structures and internal compliance programs with regard to environmental, social and governance (ESG) matters.