Alert | 24.02.2022

Ukraine crisis: Updated Trade Sanctions from the European Union

In response to the crisis in Ukraine, the European Union adopted a new set of sanctions against Russia.

Marketing & Communication

In response to the crisis in Ukraine, since 2014 the EU has progressively imposed restrictive measures against Russia. In particular, in 2014 the Council of the European Union introduced the following Regulations, whose terms of application have been subsequently extended several times:

  • Council Regulation (EU) No. 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine. Specifically, the Regulation lists Russian, Ukrainian and Crimean natural and legal persons involved in the events in Ukraine and imposes prohibitions on the provision of funds and economic resources. On 21 February 2022, the list has been expanded by the Council Implementing Regulation 2022/236.
  • Council 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. The Regulation forbids the supply of certain goods and technologies (relating to the fields of transport/telecommunications/energy/exploration/prospecting and production of oil/gas and mineral resources) to natural or legal persons in Crimea and Sevastopol or for use in such territories. It is also prohibited to provide, directly or indirectly, financing or financial assistance, as well as to provide insurance and reinsurance services related to the importation of goods from Crimea or Sevastopol; it is further forbidden to grant or participate in arrangements aimed at providing loans  or otherwise provide financing to entities in Crimea or Sevastopol.
  • Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine. The Regulation prohibits the export of dual-use goods to military end-users in Russia; restricts the export and provision of financing in relation to certain goods and equipment in the oil sector; imposes financial restrictions on transactions with certain Russian entities; and also imposes restrictions on the access to the capital market by certain Russian banks and companies related to the military and energy sectors.


Most recently, in response to the Russian Federation’s formal recognition of two regions in Eastern Ukraine – Donetsk and Luhansk – as self-proclaimed Republics, the EU Council adopted a new set of sanctions against Russia. In particular, the Council extended the scope of the above-mentioned Regulations and adopted a fourth regulation:

  • Council Regulation (EU) 2022/263 of 23 February 2022 concerning restrictive measures in response to the recognition of the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine and the ordering of Russian armed forces into those areas


The abovementioned sanctions include, in particular:

  1. Targeted sanctions: extension to the 351 members of the Duma who voted for the invasion of Ukraine, as well as to 27 natural and legal persons active in the Russian political, military, financial and media sectors. The sanctions include an asset freeze and a travel ban on EU territory.
  2. Financial sanctions: ban on all financing directed to the Russian Federation, its government, and the Russian Central Bank. In addition, restrictions on Russia’s access to the EU capital market.
  3. Territorial sanctions: with respect to the non-governmental controlled areas of the Donetsk and Luhansk oblasts, the sanctions include: (i) ban on the import of goods into the EU; (ii) ban on the export of certain goods and technologies from the EU; (iii) restrictions on trade and investment in certain sectors; and (iv) ban on the provision of tourism services.


Finally, a few hours ago, the President of the EU Commission announced that a new set of sanctions will be approved tonight. The new sanctions will affect strategic sectors of the Russian Economy, shutting down all access to fundamental technologies and markets. Furthermore, all Russian assets in the EU will be frozen and access of all Russian banks to European financial markets will be restricted.

A new update will follow as soon as the new sanctions are approved.

Team Golden Power 

Marketing & Communication

Golden Power (FDI)

LCA opera da anni in tutti gli aspetti concernenti il Commercio Internazionale e la Sicurezza Nazionale attraverso un team multidisciplinare di avvocati appartenenti ai diversi Dipartimenti dello Studio: Corporate M&A, Amministrativo & Regolatorio, IP/IT, Doganale e Business Crime.