The EU has imposed two rounds of sanctions on Russia in response to its actions in Ukraine. The sanctions include an arms embargo, restrictions on dual-use and energy goods, capital transaction bans, and asset freezes targeting over 100 individuals and entities. The sanctions prohibit a wide range of military, dual-use, and energy goods from being exported or sold to Russia, and restrict certain financial transactions. They apply both within and outside of the EU to EU individuals, companies, and their branches abroad.

1. Russia: EU Sanctions
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2. EU Sanctions
 The EU has imposed two rounds of sanctions on Russia since the
end of July 2014:
 on 31 July 2014 via Council Decision 2014/512/CFSP and
Council Regulation (EU) No 833/2014.
 on 12 September 2014, via Council Decision 2014/659/CFSP
and Council Regulation (EU) No 960/2014.
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3. EU Sanctions: 5 Elements
1) Arms embargo
2) Dual use goods and related services
3) Energy-related equipment, technology and services
4) Capital transactions
5) Asset freezes
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4. 1) Arms Embargo
Prohibited:
 direct or indirect sale, supply, transfer or export of all items on the UK
Military List arms to Russia
 technical assistance related to goods and technology listed in UK Military
List, or related to the provision, manufacture, maintenance and use of goods
included in that list, to or for use in Russia;
 financing or financial assistance, including insurance and re-insurance
related to the goods and technology listed in the UK Military List, for any
sale, supply, transfer or export of such items, or for any provision of related
technical assistance to or for use in Russia;
 import, purchase or transport of arms and related materiel of all types
from Russia
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5. 1) Arms embargo
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 extant licences: HMG has reviewed these to ensure they are consistent
with the sanctions and has contacted licence holders directly if they are
affected
 embargoed destinations: Russia has been added to the list in the Export
Control Order 2008
 Contracts signed before 1 August 2014: are exempted from the
sanctions. Licence applicants should provide a copy of the relevant
contract with their application. The existence of a relevant contract does
not guarantee that a licence will be granted as applications will still be
assessed against the export licensing Criteria

6. 2) Dual Use Goods
Prohibits:
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 to sell, supply, transfer or export, directly or indirectly, dual-use goods and technology to or for use in Russia, if
those items are or may be intended, in their entirety or in part, for military use or for a military end-user,
 Where the end-user is the Russian military, any dual-use goods and technology procured by it shall be deemed
to be for military use
 Licences will be denied if there are reasonable grounds to believe that the end-user might be a military end-user
or that the goods might have a military end-use
 technical assistance or brokering services related to dual-use goods and technology, or related to the provision,
manufacture, maintenance and use of such goods or technology, to or for use in Russia, if the items are or may be
intended, in their entirety or in part, for military use or for a military end-user;
 financing or financial assistance related to the dual-use goods and technology, for any sale, supply, transfer or
export of such items, or for any provision of related technical assistance to or for use in Russia, if the items are or
may be intended, in their entirety or in part, for military use or for a military end-user.
 All of the above applies to 9 named mixed defence companies for contracts or agreements after 12 Sept 2014
 Does not apply to items intended for civil end-users for civil end-use. Such applications will continue to be
processed in the normal way
 Does not apply to dual-use goods and technology for the aeronautics and space industry for non-military use
and for a non-military end user, and for the maintenance and safety of existing civil nuclear capabilities within the EU

7. 2) Dual-use Goods
 extant licences: HMG has reviewed these to ensure they are
consistent with the sanctions and has contacted licence holders
directly if they are affected
 Contracts signed before 1 August 2014: are exempted from
the sanctions. Applicants should provide a copy of the relevant
contract with their application. The existence of a relevant
contract does not guarantee that a licence will be granted as
applications will still be assessed against the export licensing
Criteria
 financial assistance related to dual use goods arising from a
contract or agreement concluded before 1 August 2014: no
licence is required but retain sufficient records to demonstrate the
condition is met
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8. 2) Dual-use Goods:
End-Use Controls
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 Because Russia is subject to an arms embargo, the “Military End-
Use” control applies to export of non-listed dual-use items.
 If you are aware, or have been informed by HMG, that the items
are or may be intended for a military end-use in Russia, then you
should apply for a licence.

9. 3) Energy-related Items:
Prohibitions
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 Prohibited to provide the following services necessary for deep water oil exploration and production,
arctic exploration and production or shale oil projects in Russia:
 Drilling
 Well testing
 Logging and completion services
 Supply of specialised floating vessels
 to participate, knowingly and intentionally, in activities the object or effect of which is to circumvent
these measures.
 Exemptions:
 where the services are necessary for the urgent prevention or mitigation of an event likely to have a
serious and significant impact on human health and safety of the environment
 for the execution of an obligation arising from a contract or a framework agreement concluded before
12 September 2014 or ancillary contracts necessary for the execution of such contracts.
 If one of the exemptions applies, you do not need to apply for a licence or seek clearance from the
Government but you should retain sufficient documentary evidence (such as a copy of a contract
concluded before 12 September 2014) to demonstrate that you acted in compliance with the
sanctions.

10. 3) Energy-Related Items:
Licence Required
 Licence Required For:
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 sale, supply, transfer or export of listed technologies to Russia or for any other country
where the technologies are for use in Russia. A licence will not be granted if there are
reasonable grounds to determine that the technologies are for use in connection with a
project pertaining to deep water oil exploration and production, Arctic oil exploration and
production, or shale oil projects in Russia.
 provision of technical assistance, brokering services, financing and financial
assistance related to the sale, supply, transfer or export of these technologies to Russia or
for use in Russia. Includes the supply of staff to carry out those activities. Again, a licence
will not be granted as above
 A licence may be granted where the transaction is for one of the specified oil projects and that
transaction concerns an obligation arising from a contract or an agreement concluded before 1
August 2014. (But you must still apply for a licence in these circumstances.)
 Definitions:
 HMG interprets ‘Arctic’ to mean the area north of the Arctic Circle
 Work is ongoing on an EU definition of ‘deep water’. US define it as ‘greater than 500 feet’.

11. 3) Energy-related Items
 A licence will only be required when the goods leave the EU.
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 In all cases the licence application must be made in the Member State
where the exporter is established - The exporter is the person holding
the contract with the customer outside the EU,
 A licence to supply Annex II goods is valid throughout the EU.
 The requirement for prior authorisation applies to items listed under the
CN codes listed in Annex II to Council Regulation (EU) No 833/2014. If
the item to be supplied has a CN code that is not listed in Annex II then
an authorisation is not required even if that item contains a listed item
as a component.

12. Definitions
 “Technical assistance” is defined as “any technical support
related to repairs, development, manufacture, assembly, testing,
maintenance, or any other technical service, and may take forms
such as instruction, advice, training, transmission of working
knowledge or skills or consulting services; including verbal forms
of assistance”.
 “financial assistance”: no specific definition. HMG interpret it in
its broadest sense, i.e. involvement in any financial transaction
which promotes, enables or facilitates the prohibited or restricted
trade transaction to which it relates. include the processing of
payments for prohibited/restricted trade transactions
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13. 4) Capital Transactions
 Prohibits purchase, sale or provision of investment services or any
dealing with bonds, equity, or similar financial instruments with a
maturity exceeding 90 days, issued after 1 August 2014 to 12
September 2014, or with a maturity exceeding 30 days, issued after 12
September 2014 by:
a) major credit institutions or finance development institutions
established in Russia with over 50 % public ownership or control as
of 1 August 2014, as listed in Annex I
b) any legal person, entity or body established outside the Union
owned for more than 50 % by an entity listed in Annex I; or
c) any legal person, entity or body acting on behalf, or at the direction,
of an entity within the category referred to in point (b) of this
paragraph or listed in Annex I,
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14. 4) Capital Transactions
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Prohibits purchase, sale or provision of investment services or any dealing with
bonds, equity, or similar financial instruments with a maturity exceeding 30 days,
issued after 12 September 2014 by:
a) entities established in Russia predominantly engaged and with major
activities in the conception, production, sales or export of military equipment
or services, as listed in Annex II, except entities active in the space and
nuclear energy sectors;
b) entities established in Russia which are publicly controlled or with over 50 %
public ownership which have estimated total assets of over 1 trillion Russian
Roubles and whose estimated revenues originate for at least 50 % from the
sale or transportation of crude oil or petroleum products as of 12 September
2014, as listed in Annex III;
c) any legal person, entity or body established outside the Union owned for
more than 50 % by an entity referred to in points (a) and (b); or
d) any legal person, entity or body acting on behalf, or at the direction, of an
entity within the category referred to in point (c) or listed in Annex II or III,

15. 4) Capital Transactions
 prohibited to directly or indirectly make or be part of any
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arrangement to make new loans or credit with a maturity exceeding
30 days to any legal person, entity or body referred to above after
12 September 2014
 except for loans or credit that have a specific and documented
objective to provide financing for non-prohibited imports or exports
of goods and non-financial services between the Union and Russia
or for loans that have a specific and documented objective to
provide emergency funding to meet solvency and liquidity criteria for
legal persons established in the Union, whose proprietary rights are
owned for more than 50 % by an entity referred to in Annex I.’.

16. 5) Asset Freezes
 119 persons (24 of them added 12 September 2014) and 23 entities
subject to an asset freeze and a visa ban.
 Freezes and bans may also be imposed on those conducting
transactions with Ukrainian separatists
 Check the details on HM Treasury website
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17. EU Sanctions: Scope
EU sanctions apply:
 within EU territory, including its airspace
 to EU nationals, whether or not they are in the EU
 to companies and organisations incorporated under the law of a member
state, whether or not they are in the EU. Includes branches of EU
companies in third countries
 to any business done in whole or in part within the EU
 on board aircraft or vessels under the jurisdiction of a member state
 No extraterritorial application, unlike …
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18. Other Export Licensing Concerns
 Do not assume that the export of goods and services which are not banned
by the EU sanctions will automatically be approved. They will not receive an
export licence if they raise other concerns under the export licensing
Criteria.
 Exports to Russia potentially raise a number of risks:
 Risk of diversion to a WMD or related missile programme
 Risk of use to violate human rights or international humanitarian law
 Risk of exacerbating internal or regional tensions
 Risk of undermining the security of the UK or our allies
 Risk of diversion to undesirable end-users such as Syria or Iran
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Richard Tauwhare
Green Light Exports Consulting
Email: richard@greenlightexports.co.uk
Web: www.greenlightexports.co.uk
Phone: +44(0)770 311 0880