On 16 February 2022, President of the European Commission Ursula von der Leyen addressed the European Parliament Plenary on EU-Russia relations, European security and Russia's military threat against Ukraine.

In the speech the European President gave the clearest signal yet as to the possible shape of what forthcoming EU/West sanctions on Russia might look like assuming Russia invades. Key to the speech is possibly the following statement:

The European Commission and the [European External Action Service] have been working closely with all Member States to prepare a robust and comprehensive package of potential sanctions. And we have worked in close coordination with our friends in the US, the UK and Canada. Let me say that in these weeks we have built a unity of purpose that is truly remarkable, both within the EU and with our partners. In case of a Russian aggression, Europe's reaction will be swift and robust. We are not just talking about freezing assets and banning travel for Russian individuals. Russia's strategic interest is to diversify its one-sided economy and to close its current gaps. But for this, they need technologies in which we have a global leadership. High-tech components for which Russia is almost entirely dependent on us. Our sanctions can bite very hard, and the Kremlin knows this well. https://ec.europa.eu/commission/presscorner/detail/en/speech_22_1101

We highlight the key parts in bold. In broad terms, sanctions:

• Are likely to be rolled out uniformly across the Western block
• Further entity and individual asset freeze designations are a given
• The EU is looking at sanctioning “high tech components” for the first time on a broad scale

Sanctioning high tech components would be an escalation of the approach taken in 2014 with the introduction of “sectoral sanctions” and would mark a novel development for the EU. The US has adopted such regimes historically, most recently against Huawei under its so-called “Foreign Direct Product Rule” (FDPR). The idea behind the FDPR is to restrict a targets’ ability to source critical items produced from Western-origin technology.

Such measures are likely to be relevant in the UK Overseas Territories to the extent that the UK follows the EU in introducing them.