months—target more than 170 Russian individuals and more than 44 Russiancontrolled entities selected for “undermining the territorial integrity or stability of
Ukraine.”
29 The relevant EU sanctions comprise the freezing of their financial funds
and economic resources, and a general prohibition to make funds and economic
resources available to those parties. The wide scope of the EU sanctions regime
makes virtually any business activity with those sanctioned parties illegal. In particular, the violation of the provisions is actionable through fines and, e.g., the listing of
the violating entity itself.
2.2.1.2 Broader Economic Sanctions Imposed on Russia by the EU
Regulation EU/692/2014
30 imposed a first general import ban on goods originating
in Crimea and Sevastopol, and prohibiting the provision of related financing and
insurance services. These measures were further extended by Regulation EU/825/
2014.
31 The legislative package concerns first, the creation, acquisition or development of infrastructure in the sectors of transport, telecommunications, and energy,
and second, the exploitation of oil, gas or mineral resources. Additionally, an export
ban on key equipment and technology for the oil and gas industry (such as pipes and
drilling equipment) has been established.
32
Remarkably, since the adoption of Regulation EU/883/2014 (July 2014),
33 the
EU sanctions regime targets Russia directly. As all other EU sanctions Regulations
discussed here, this legal act has been subsequently amended and further intensified,
i.e. via Regulations EU/960/2014
34 and EU/1290/2014.
35 The applicable sanctions
29 In 2016, for example, amendments had been affected by Implementing Regulation EU/2016/353
amending Regulation EU/269/2014 (and Decision 2016/359 amending Decision 2014/145/CFSP).
Since then, updates and amendments to the Regulations are affected (roughly) twice per calendar
year, see https://www.consilium.europa.eu/en/policies/sanctions/ukraine-crisis/.
30 Regulation (EU) No 692/2014 of 23 June 2014 concerning restrictions on the import into the
Union of goods originating in Crimea or Sevastopol, in response to the illegal annexation of Crimea
and Sevastopol, OJ 2014 L183/9.
31 Council Regulation (EU) No 825/2014 of 30 July 2014 amending Regulation (EU) No 692/2014
concerning restrictions on the import into the Union of goods originating in Crimea or Sevastopol,
in response to the illegal annexation of Crimea and Sevastopol, OJ 2014 L226/2.
32 For a detailed discussion of the measures (in German, however) see, e.g., Schwendiger and Trennt
(2015), p. 93; Brauneck (2015), p. 498.
33 Council Regulation (EU) No 883/2014 of 31 July 2014 concerning restrictive measures in view of
Russia’s actions destabilising the situation in Ukraine, OJ 2014 L229/1.
34 Council Regulation (EU) No 960/2014 of 8 September 2014 amending Regulation (EU) No
833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in
Ukraine, OJ 2014 L271/3.
35 Council Regulation (EU) No 1290/2014 of 4 December 2014 amending Regulation (EU) No
833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in
Ukraine, and amending Regulation (EU) No 960/2014 amending Regulation (EU) No 833/2014, OJ
2014 L349/20.
Sanctions Compliance Risks in International Shipping: Closure of Five. . .
297
Ukraine.”
29 The relevant EU sanctions comprise the freezing of their financial funds
and economic resources, and a general prohibition to make funds and economic
resources available to those parties. The wide scope of the EU sanctions regime
makes virtually any business activity with those sanctioned parties illegal. In particular, the violation of the provisions is actionable through fines and, e.g., the listing of
the violating entity itself.
2.2.1.2 Broader Economic Sanctions Imposed on Russia by the EU
Regulation EU/692/2014
30 imposed a first general import ban on goods originating
in Crimea and Sevastopol, and prohibiting the provision of related financing and
insurance services. These measures were further extended by Regulation EU/825/
2014.
31 The legislative package concerns first, the creation, acquisition or development of infrastructure in the sectors of transport, telecommunications, and energy,
and second, the exploitation of oil, gas or mineral resources. Additionally, an export
ban on key equipment and technology for the oil and gas industry (such as pipes and
drilling equipment) has been established.
32
Remarkably, since the adoption of Regulation EU/883/2014 (July 2014),
33 the
EU sanctions regime targets Russia directly. As all other EU sanctions Regulations
discussed here, this legal act has been subsequently amended and further intensified,
i.e. via Regulations EU/960/2014
34 and EU/1290/2014.
35 The applicable sanctions
29 In 2016, for example, amendments had been affected by Implementing Regulation EU/2016/353
amending Regulation EU/269/2014 (and Decision 2016/359 amending Decision 2014/145/CFSP).
Since then, updates and amendments to the Regulations are affected (roughly) twice per calendar
year, see https://www.consilium.europa.eu/en/policies/sanctions/ukraine-crisis/.
30 Regulation (EU) No 692/2014 of 23 June 2014 concerning restrictions on the import into the
Union of goods originating in Crimea or Sevastopol, in response to the illegal annexation of Crimea
and Sevastopol, OJ 2014 L183/9.
31 Council Regulation (EU) No 825/2014 of 30 July 2014 amending Regulation (EU) No 692/2014
concerning restrictions on the import into the Union of goods originating in Crimea or Sevastopol,
in response to the illegal annexation of Crimea and Sevastopol, OJ 2014 L226/2.
32 For a detailed discussion of the measures (in German, however) see, e.g., Schwendiger and Trennt
(2015), p. 93; Brauneck (2015), p. 498.
33 Council Regulation (EU) No 883/2014 of 31 July 2014 concerning restrictive measures in view of
Russia’s actions destabilising the situation in Ukraine, OJ 2014 L229/1.
34 Council Regulation (EU) No 960/2014 of 8 September 2014 amending Regulation (EU) No
833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in
Ukraine, OJ 2014 L271/3.
35 Council Regulation (EU) No 1290/2014 of 4 December 2014 amending Regulation (EU) No
833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in
Ukraine, and amending Regulation (EU) No 960/2014 amending Regulation (EU) No 833/2014, OJ
2014 L349/20.
Sanctions Compliance Risks in International Shipping: Closure of Five. . .
297