On 6 October 2022, the EU Council announced that it has adopted new economic and individual sanctions against Russia, referred to also as the eight package sanctions.

Ban on more professional services, including “legal advisory services”

The package prohibits the provision of architectural and engineering services, IT consultancy services and legal advisory services by EU persons and firms to Russia.

Little precise detail is understood at this time as to extent of the prohibition, but these will have significant implications throughout the EU – especially in respect of the right to legal representation – and will be added to the growing list of other banned professional services, introduced in May 2022, which includes: accounting, management consulting, and trust services.

Ban on crypto

The package includes a full ban of the provision of crypto-asset wallet, account or custody services to Russian persons and residents, regardless of the total value of those crypto-assets. Under the prior regime only transfers in excess of €10,000 were caught.

Price cap on Russian oil

The agreed package introduces into EU legislation a legal basis for imposing a price cap related to the maritime transport of Russian oil for third countries and further restrictions on the maritime transport of crude oil and petroleum products to third countries.

Additionally, it will be prohibited to provide maritime transport and technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries of crude oil (as of December 2022) or petroleum products (as of February 2023) which originate in or are exported from Russia. The price cap derogation would allow the provision of the transport and these services if the oil or petroleum products are purchased at or below a pre-established price cap.

The restrictions implement the work EU member states have committed to undertaking at the recent G7 summit in September 2022.

Other trade bans

As concerns trade, the EU is extending the import ban on steel products that either originate in Russia or are exported from Russia. Further import restrictions are also imposed on wood pulp and paper, cigarettes, plastics and cosmetics as well as elements used in the jewellery industry such as stones and precious metals, that altogether generate significant revenues for Russia. The sale, supply transfer or export of additional goods used in the aviation sector will also be restricted.

The package agreed also comprises:

• The sanctioning of individuals and entities that have played a role in the organisation of illegal “referenda”, representatives of the defence sector, and well-known persons spreading disinformation about the war. The Council also decided to broaden the listing criteria on which specific designations can be based, in order to include the possibility to target those who facilitate the circumvention of EU sanctions.
• The extension of the list of restricted items which may contribute to Russia's military and technological enhancement or the development of its defence and security sector.
• A prohibition to sell, supply, transfer or export civilian firearms and ammunition, military vehicles and equipment, paramilitary equipment, and spare parts.
• A ban on EU nationals to hold any posts on the governing bodies of certain Russian state-owned or controlled legal persons, entities or bodies.
• The insertion in the list of state-owned entities that are subject to the transaction ban of the Russian Maritime Shipping Register, a 100% State-owned entity which performs activities related to the classification and inspection, including in the field of security, of Russian and non-Russian ships and crafts.

European Council’s press release can be found here.