In May 2014, Regulation EU/476/2014
23 (and the corresponding amendment of
Decision 2014/145/CFSP) broadened the personal scope of Article 3 of Regulation
EU/269/2014 for the first time. More specifically, sanctions could now be imposed
against parties that “obstruct the work of international organisations in Ukraine, and
natural or legal persons, entities or bodies associated with them, or legal persons,
entities or bodies in Crimea or Sevastopol whose ownership has been transferred
contrary to Ukrainian law, or legal persons, entities or bodies which have benefited
from such a transfer”.
In July 2014, via Regulations EU/783/2014
24 and EU/811/2014
25 (and, once
more, the corresponding amendment of Decision 2014/145/CFSP), the EU sanctions
regime in respect of the situation in Ukraine was intensified and substantiated
further. Since then, the “personal scope” of Article 3 of Regulation EU/269/2014
includes “legal persons, entities or bodies supporting, materially or financially,
actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine”; and “natural or legal persons entities or bodies who actively
provide material or financial support to, or are benefiting from, Russian decisionmakers responsible for the annexation of Crimea and Sevastopol or the destabilising
of the Eastern-Ukraine”.
Via a methodology also applicable for other “regionalised” EU sanctions
regimes
26 the act enables the EU Council to impose—at short notice—further
restrictions on a wide range of stakeholders representing the Russian industry, the
Russian finance sector, and other Russian business sectors—even if those stakeholders are themselves not directly responsible for any crimes or actions in respect of
the Crimean situation since March 2014. For example, in 2016, 23 individuals and
21 entities were added to Annex I of Regulation EU/269/2014 via Regulations
EU/810/2014
27 and EU/826/2014.
28
By 2019, the continuously updated and extended economic sanctions of the EU—
implemented via Regulation EU/269/2014 and its amending acts after about six
23 Council Regulation (EU) No 476/2014 of 12 May 2014 amending Regulation (EU) No 269/2014
concerning restrictive measures in respect of actions undermining or threatening the territorial
integrity, sovereignty and independence of Ukraine, OJ 2014 L137/1.
24 Council Regulation (EU) No 783/2014 of 18 July 2014 amending Regulation (EU) No 269/2014
concerning restrictive measures in respect of actions undermining or threatening the territorial
integrity, sovereignty and independence of Ukraine, OJ 2014 L214/2.
25 Council Regulation (EU) No 811/2014 of 25 July 2014 amending Regulation (EU) No 269/2014
concerning restrictive measures in respect of actions undermining or threatening the territorial
integrity, sovereignty and independence of Ukraine, OJ 2014 L221/11.
26 See the EU’s global “Sanctions Map” which includes more than 30 sanctioned foreign States in
2018: https://sanctionsmap.eu.
27 Council Implementing Regulation (EU) No 810/2014 of 25 July 2014 implementing Regulation
(EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening
the territorial integrity, sovereignty and independence of Ukraine, OJ 2014 L221/1.
28 Council Implementing Regulation (EU) No 826/2014 of 30 July 2014 implementing Regulation
(EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening
the territorial integrity, sovereignty and independence of Ukraine, OJ 2014 L226/16.
296
H. Jessen
23 (and the corresponding amendment of
Decision 2014/145/CFSP) broadened the personal scope of Article 3 of Regulation
EU/269/2014 for the first time. More specifically, sanctions could now be imposed
against parties that “obstruct the work of international organisations in Ukraine, and
natural or legal persons, entities or bodies associated with them, or legal persons,
entities or bodies in Crimea or Sevastopol whose ownership has been transferred
contrary to Ukrainian law, or legal persons, entities or bodies which have benefited
from such a transfer”.
In July 2014, via Regulations EU/783/2014
24 and EU/811/2014
25 (and, once
more, the corresponding amendment of Decision 2014/145/CFSP), the EU sanctions
regime in respect of the situation in Ukraine was intensified and substantiated
further. Since then, the “personal scope” of Article 3 of Regulation EU/269/2014
includes “legal persons, entities or bodies supporting, materially or financially,
actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine”; and “natural or legal persons entities or bodies who actively
provide material or financial support to, or are benefiting from, Russian decisionmakers responsible for the annexation of Crimea and Sevastopol or the destabilising
of the Eastern-Ukraine”.
Via a methodology also applicable for other “regionalised” EU sanctions
regimes
26 the act enables the EU Council to impose—at short notice—further
restrictions on a wide range of stakeholders representing the Russian industry, the
Russian finance sector, and other Russian business sectors—even if those stakeholders are themselves not directly responsible for any crimes or actions in respect of
the Crimean situation since March 2014. For example, in 2016, 23 individuals and
21 entities were added to Annex I of Regulation EU/269/2014 via Regulations
EU/810/2014
27 and EU/826/2014.
28
By 2019, the continuously updated and extended economic sanctions of the EU—
implemented via Regulation EU/269/2014 and its amending acts after about six
23 Council Regulation (EU) No 476/2014 of 12 May 2014 amending Regulation (EU) No 269/2014
concerning restrictive measures in respect of actions undermining or threatening the territorial
integrity, sovereignty and independence of Ukraine, OJ 2014 L137/1.
24 Council Regulation (EU) No 783/2014 of 18 July 2014 amending Regulation (EU) No 269/2014
concerning restrictive measures in respect of actions undermining or threatening the territorial
integrity, sovereignty and independence of Ukraine, OJ 2014 L214/2.
25 Council Regulation (EU) No 811/2014 of 25 July 2014 amending Regulation (EU) No 269/2014
concerning restrictive measures in respect of actions undermining or threatening the territorial
integrity, sovereignty and independence of Ukraine, OJ 2014 L221/11.
26 See the EU’s global “Sanctions Map” which includes more than 30 sanctioned foreign States in
2018: https://sanctionsmap.eu.
27 Council Implementing Regulation (EU) No 810/2014 of 25 July 2014 implementing Regulation
(EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening
the territorial integrity, sovereignty and independence of Ukraine, OJ 2014 L221/1.
28 Council Implementing Regulation (EU) No 826/2014 of 30 July 2014 implementing Regulation
(EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening
the territorial integrity, sovereignty and independence of Ukraine, OJ 2014 L226/16.
296
H. Jessen