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EU Considers Expansion of Russia-Related Sanctions

Washington, D.C. (December 8, 2023) - On November 15, 2023, the European Union (EU) High Representative Josep Borrell, together with the European Commission, submitted to the Council of the European Union (the Council) a proposal for the 12th package of EU Russia-related sanctions. According to an official statement by the EU, the proposed package would substantially expand current EU sanctions by listing new entities, altering the petroleum price cap, and imposing additional controls on various exports. The proposal must receive unanimous approval by the Member States prior to taking effect, with review by the Council beginning November 17th and a final decision in the coming weeks.

The proposed sanctions package, which is not available for review by the public at the time of this Alert, would sanction more than 120 new individuals and entities from Russian “military, defence and IT sectors, as well as other ... economic operators.” Additionally, the proposed sanctions would “tighten” the current Oil Cap (see our earlier alert on Oil Cap Guidance) and adopt new import and export bans on a variety of raw and manufactured materials and products.

Separately, on November 9, 2023, the European Parliament adopted a non-binding resolution that similarly called on EU Member States to tighten export controls, sanction additional entities, and work together with the G7 to “substantially lower the price cap on Russian oil and petroleum products.” These EU actions are non-binding; affected or concerned parties should continue to monitor and comply with currently in-place sanctions regulations.

Lewis Brisbois attorneys are actively guiding businesses as they navigate constantly evolving sanctions laws and regulations. For more information, please contact the authors of this alert. For more alerts in this area, please visit the Ukraine Conflict Response Practice page.

Author:

George Leahy, Associate

Editors:

Jane C. Luxton, Managing Partner - Washington, D.C.

Andrew Pidgirsky, Partner and Chair of Ukraine Conflict Response Practice

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