the luxembourg government is introducing comprehensive reforms to modernise the governance and operations of the commission de surveillance du secteur financier (cssf) and the commissariat aux assurances (caa). these changes align with the transposition of the european directive crd6 and aim to enhance the independence and effectiveness of financial oversight bodies. the luxembourg government is introducing comprehensive reforms to modernise the governance and operations of the commission de surveillance du secteur financier and the commissariat aux assurances. these changes align with the transposition of the european directive crd6 and aim to enhance the independence and effectiveness of financial oversight bodies. luxembourg's financial sector reforms: key changes the luxembourg government is introducing comprehensive reforms to modernise the governance and operations of the commission de surveillance du secteur financier (cssf) and the commissariat aux assurances (caa). these changes align with the transposition of the european directive crd6 and aim to enhance the independence and effectiveness of financial oversight bodies.

the luxembourg government is introducing comprehensive reforms to modernise the governance and operations of the commission de surveillance du secteur financier (cssf) and the commissariat aux assurances (caa). these changes align with the transposition of the european directive crd6 and aim to enhance the independence and effectiveness of financial oversight bodies. a key aspect of the reform is the strengthening of governance practices. measures include stricter conflict-of-interest management, such as restrictions on post-tenure employment for directors, and limits on the duration of mandates,14 years for cssf directors and 15 years for caa directors. these steps are designed to ensure greater transparency and accountability. the leadership structures of both institutions are also being expanded. the cssf will see an increase in its director count from four to six, alongside the general director, to address emerging challenges in the financial sector, such as crypto-assets and electronic payments. similarly, the caa will now have between two and four directors, in addition to its general director, to strengthen its operational capacity. another significant change involves the handling of financial sanctions. under the new framework, funds collected from sanctions imposed by the cssf will be redirected to the state treasury, ensuring a clear separation between regulatory activities and financial penalties. the reforms also emphasise the importance of financial education. a legislative proposal seeks to formalise the cssf’s role in promoting financial literacy, with efforts underway to integrate this mission into the broader legal framework. lawmakers are pushing for swift implementation to benefit the public. lastly, discussions are ongoing regarding the role of the european securities and markets authority (esma) in financial supervision. while some eu member states advocate for a stronger esma role, luxembourg supports maintaining financial oversight at the national level through authorities like the cssf. for more information the news release can be found here

on 12 march 2026, the european securities and markets authority (esma) released findings and proposed actions to enhance the retail investor journey, based on its 2025 call for evidence. the initiative aims to address barriers faced by retail investors in accessing eu capital markets, focussing on both regulatory and non-regulatory challenges. key areas of focus on 12 march 2026, the european securities and markets authority released findings and proposed actions to enhance the retail investor journey, based on its 2025 call for evidence. the initiative aims to address barriers faced by retail investors in accessing eu capital markets, focussing on both regulatory and non-regulatory challenges. simplifying the retail investor journey: esma's latest actions on 12 march 2026, the european securities and markets authority (esma) released findings and proposed actions to enhance the retail investor journey, based on its 2025 call for evidence. the initiative aims to address barriers faced by retail investors in accessing eu capital markets, focussing on both regulatory and non-regulatory challenges. key areas of focus

on 12 march 2026, the european securities and markets authority (esma) released findings and proposed actions to enhance the retail investor journey, based on its 2025 call for evidence. the initiative aims to address barriers faced by retail investors in accessing eu capital markets, focussing on both regulatory and non-regulatory challenges. key areas of focus: simplifying disclosures: current disclosures are criticised for being lengthy, complex, and not user-friendly, particularly for digital-first investors. esma plans to streamline these requirements, introducing clearer, layered, and mobile-friendly formats. reducing complexity in assessments: suitability and appropriateness assessments, while valuable for investor protection, are seen as burdensome. esma aims to simplify these processes, especially for straightforward products and digital channels, while addressing the complexity of integrating sustainability preferences. addressing non-regulatory barriers: issues such as lack of trust, high fees, limited product comparability, low financial literacy, and complex cross-border taxation were highlighted. esma emphasises the need for broader reforms, including financial education and tax alignment across member states. esma will use these insights to guide updates to mifid ii guidelines and provide technical advice for the retail investment strategy (ris). consumer testing will play a critical role in validating improvements, ensuring they meet the needs of diverse investor profiles, including mobile-first users. esma’s news release can be found here

on 27 april 2026, the jersey financial services commission (fsc) introduced "focus examinations" as part of its 2026-2030 strategy to adopt a more risk-based and proportionate supervisory approach. these examinations are designed to assess compliance with regulatory requirements in specific, clearly defined areas, offering a streamlined alternative to full-scale examinations. key features: minimal documentation: only essential document extracts are required, reducing administrative burden. short onsite duration: typically, lasting half a day, minimising disruption to business operations. interactive format: firms can demonstrate controls and processes directly, avoiding extensive written submissions. tailored feedback: specific feedback is provided to highlight strengths and areas for improvement. industry insights: anonymised observations will be shared to promote good practices and address common challenges. proportionality: ensures reduced disruption while maintaining regulatory assurance. cross-sector assessment: enables evaluation across various industry sectors. implementation: focus examinations will begin in june 2026, with the initial topic being targeted financial sanctions. selected entities will be notified via email with further details on the process and required information. the industry update can be found here

on 27 march 2026, the european commission initiated infringement procedures against several eu member states for failing to fully transpose key eu directives into their national laws by the required deadlines. these actions aim to ensure compliance with eu legislation and safeguard harmonisation across the eu. key directives and actions: european single access point (esap) omnibus directive: aimed at centralising corporate public information for investors. deadlines for transposition: july 2025 (phase 1) and january 2026 (phases 2 & 3). non-compliance by 19 member states, including cyprus and luxembourg. sixth capital requirements directive (crd6): focusses on the carrying out of banking activity by third country banks in the eu, reverse solicitation, requirements for third country branches in the eu, and integrating environmental, social, and governance (esg) risks. deadline: january 2026.22 member states, including cyprus and luxembourg. e-evidence directive: establishes mechanisms for judicial authorities to access electronic evidence across borders. deadline: february 2026. non-compliance by 22 member states, including cyprus and luxembourg. next steps: the eu commission issued formal notices, granting member states two months to address the deficiencies. failure to comply may result in the issuance of reasoned opinions, escalating the enforcement process. the press release can be found here

on 22 april 2026, the cssf announced updated procedures for cross-border management notifications and de-notifications for luxembourg-domiciled investment fund managers (ifms) operating under a european passport. these changes, effective from 22 april 2026, aim to enhance efficiency and transparency in the notification process using digital platforms. key details: the updated procedures apply to: ucits management companies: those authorised under chapter 15 of the law of 17 december 2010 (the 2010 law) to manage ucits in other eu member states. this includes activities conducted via branch establishment or under the freedom to provide services (fps), as well as the management of ucits established in other member states (articles 114 and 115 of the 2010 law). authorised aifms: those operating under article 5 of the law of 12 july 2013 (the 2013 law) to manage eu aifs (authorised or not) in other member states, either directly (fps) or through branch establishment. this also includes providing services outlined in article 5(4) of the 2013 law (article 32 of the 2013 law). new submission methods: edesk portal: all notifications and de-notifications must now be submitted via the cssf’s edesk portal. this platform centralises the submission and monitoring of cross-border management activities. cssf application programming interface (api) transmission: alternatively, submissions can be made using the cssf api solution, which leverages s3 technology for secure file transfers. monitoring: ongoing monitoring of notifications will be conducted exclusively through the edesk portal. obligations for ifms: ifms are reminded of their obligation to notify the cssf of all cross-border activities and services they intend to provide, regardless of whether these are conducted under the freedom to provide services or through branch establishment. support and assistance: for any questions or technical support, ifms can contact the cssf helpdesk at edesk@cssf.lu. why this matters: these updates reflect the cssf’s commitment to modernising regulatory processes and ensuring compliance with eu directives. by leveraging digital tools like the edesk portal, the cssf aims to simplify administrative procedures, reduce processing times, and enhance the overall efficiency of cross-border fund management operations. cssf’s communique can be accessed here and comprehensive guidance is provided in the user guide: ifm guidelines on cross-border management notification and de-notification procedures. the edesk portal is here.

on 16 february, the british virgin islands financial services commission (bvi fsc) published industry circular 5 of 2026, highlighting the critical importance of ongoing customer due diligence (cdd) and transaction monitoring for financial institutions (fis) and designated non-financial businesses and professionals (dnfbps). while initial cdd establishes a foundational understanding of customer profiles and risks, the bvi fsc underscores that ongoing cdd is essential to address changes in customer circumstances or activities. key elements of ongoing cdd include: transaction monitoring: systems must be in place to detect unusual or suspicious activities, flag them for examination, and take appropriate action. customer screening: regular screening is required to identify changes in customer status, such as becoming a politically exposed person (pep) or being subject to sanctions. updating cdd information: customer data must be reviewed and updated regularly, particularly for higher-risk customers or upon specific trigger events. the bvi fsc encourages fis and dnfbps to strengthen compliance by maintaining updated policies, training staff, and utilising available guidance, including faqs and monitoring frameworks. if any fis or dnfbps require a review of their internal policies and procedures to ensure that they meet the regulatory requirements, please do get in touch with us. we can also provide general regulatory advice to ensure that any fis or dnfbps mitigate any deficient cdd areas in their business to offset any breaches being detected. for more information, fsc circular 5 of 2026 can be found here

the income tax (amendment) law 2026 (the income tax amending law) was officially published in the gazette of the republic of cyprus on 6 march 2026. the income tax amending law introduces amendments to the existing income tax law 2002, as amended (the income tax law), with the following key provisions: 1. introduction of new tax exemption (section 8 amendment) a new subsection (21b) has been added to section 8 of the income tax law, providing a 25 per cent tax exemption on income from employment or business profits in cyprus, capped at €25,000 per tax year. this exemption applies under the following conditions: the individual must be a resident of cyprus, starting employment or business activity in cyprus between 1 january 2025 and 31 december 2030. during the first 12 months of employment or business activity, the individual must have earned over €30,000 in income. the individual must not have been a resident of cyprus for the seven tax years preceding the start of employment or business activity. the individual must have been a resident of cyprus at least once prior to the seven-year period mentioned above. the individual must meet at least one of the following criteria: hold a recognised university degree and have worked full-time outside cyprus for a non-cypriot employer for at least 36 months within the last 84 months. have worked full-time outside cyprus for a non-cypriot employer for 84 consecutive months prior to starting employment or business in cyprus. additional notes: the exemption is granted for the year employment or business activity begins and the subsequent six tax years, provided annual income exceeds €30,000. this exemption cannot be combined with the exemption under subsection (21a). the exemption is granted once per lifetime for eligible individuals. this exemption is part of the "minds in cyprus" initiative, a strategic framework designed to attract skilled professionals and entrepreneurs to cyprus, leveraging their global expertise to contribute to the country’s economic growth. 2. other tax exemptions for relocating/returning individuals in addition to the new 25 per cent tax exemption under section 8(21b) of the income tax law, two other tax exemptions are currently in force to encourage individuals to relocate or return to cyprus: a. 20 per cent exemption (section 8(21a)) under section 8(21a), individuals may claim a 20 per cent exemption from income tax, up to a maximum of €8,550 per tax year, on emoluments from their first employment in cyprus, provided that: they have not performed any employment in cyprus for the last 15 years; and they were employed outside cyprus by a non-cypriot employer for the 3 years immediately before starting their first employment in cyprus. this exemption is granted for 7 years, starting from the year following the commencement of employment. it is applicable for employment starting on or before 31 december 2027. b. 50 per cent exemption (section 8(23a)) under section 8(23a), individuals may claim a 50 per cent exemption from income tax on emoluments from any employment exercised in cyprus, provided that: they have not been a tax resident of cyprus or exercised any employment in cyprus for at least 15 consecutive years immediately before starting their first employment in cyprus; and their employment emoluments for the first or second year of employment in cyprus exceeded €55,000. this exemption is granted for 17 years. however, if this exemption is granted, the tax exemptions provided in sections 21, 21a, 21b and 23 do not apply. 3. non-domicile (non-dom) regime and section 8(21b) the non-dom regime operates independently of section 8(21b). under the non-dom regime, individuals are exempt from paying special defence contribution (sdc) on income derived from dividends and interest. in contrast, section 8(21b) provides an income tax exemption on remuneration from employment exercised in cyprus or profits from a business carried out in cyprus. these two exemptions are not mutually exclusive and may be claimed simultaneously, allowing eligible individuals to benefit from both regimes concurrently. 4. effective date the amendments are retroactively effective from 1 january 2025. the income tax amending law can be found here

on 10 april 2026, the cssf issued a communication to the investment fund industry regarding the activation of the "liquidity management tool (lmt)" module. this follows the implementation of additional liquidity management requirements introduced by the law of 3 march 2026, which transposes directive (eu) 2024/927. key points include: lmt activation module launch: effective from 16 april 2026, luxembourg-domiciled ucits, their management companies, and luxembourg-authorised aifms managing open-ended aifs were required to begin notifying the cssf of the activation or deactivation of: suspensions of subscriptions, repurchases, and redemptions. liquidity management tools (lmts) as specified in the relevant laws, when not in the ordinary course of business. side pockets, with prior notification to the cssf within a reasonable timeframe. scope: the requirements also apply to open-ended funds under part ii of the 2010 law, specialised investment funds, and investment companies in risk capital, provided they do not qualify as aifs or are not managed by luxembourg-authorised aifms. notification process: notifications must be submitted via the cssf's edesk platform. information provided is shared with relevant authorities, including esma and, where applicable, the esrb. for further details, the cssf’s communiqué can be found here. our previous blog post on this matter, referring to the cssf's communiqué of 18 march 2026, is available here. cssf circular 26/910 on esma liquidity management tools guidelines on 15 april 2026, the cssf published circular cssf 26/910, informing that it applies the esma guidelines on lmts of ucits and open-ended aifs (esma34-671404336-1364), published on 12 march 2026, and is integrating the guidelines into its administrative practice and regulatory approach with a view to promoting supervisory convergence at european level. scope the circular applies to luxembourg management companies under chapter 15 and article 125-2 of chapter 16 of the 2010 law, luxembourg branches of ifms under chapter 17, ucits investment companies which have not designated a management company, aifms authorised under chapter 2 of the 2013 law, and internally managed aifs. summary of the guidelines the guidelines are divided into four main sections addressing: general principles quantitative-based lmts (suspension of subscriptions, repurchases and redemptions; redemption gates; extension of notice periods; and redemptions in kind) anti-dilution tools (adts) (redemption fees, swing pricing, dual pricing, and anti-dilution levy) side pockets. the general principles emphasise that the primary responsibility for liquidity risk management, as well as for the selection, calibration, activation and deactivation of lmts, remains with the investment fund manager (ifm). ifms should give due consideration that the selected lmts will allow effective management of the fund’s liquidity risk under both normal and stressed market conditions and that the selection is as comprehensive as possible to address different circumstances. in the selection of lmts, the guidelines provide that ifms should consider the merit of selecting at least one quantitative-based lmt and at least one adt, while also considering selecting one lmt to use under normal market conditions and one lmt to be used under stressed market conditions. ifms may choose to select more than the mandatory two lmts. ifms should be able to demonstrate at the request of the cssf that the calibration and activation of the selected lmts are in the best interest of all investors and are appropriate and effective considering the market conditions and relevant characteristics of the fund. entry into force the circular with the guidelines applied as from 16 april 2026. by way of derogation, for funds existing before the date of application, the guidelines apply twelve months from that date (i.e. 16 april 2027). for more details, the cssf’s circular 26/910 can be accessed here

the british virgin islands financial services commission (bvi fsc) successfully concluded its 2026 "meet the regulator" (mtr) forum series, fostering robust dialogue and engagement across key global markets. the series began in the bvi on 17 february 2026, with over 200 stakeholders from various financial sectors, including trust services, insurance, and virtual assets. subsequent forums were held in panama, london, and hong kong, attracting significant participation. notably, the panama forum featured the announcement of a new latam representative office, set to open by the end of 2026. the london session gathered over 50 stakeholders from the uk and europe, while the hong kong forum concluded the series with over 100 attendees. the mtr forum series highlighted key regulatory updates and initiatives. a major focus was on the implementation of the beneficial ownership (bo) regime, which aims to enhance transparency and align with international aml/cft standards. the bvi fsc reported significant progress, with over 86 per cent of companies and 63 per cent of limited partnerships filing bo information as of february 2026. additionally, the fsc emphasised its commitment to risk-based supervision, enhanced compliance inspections, and the integration of new technologies like the virtual integrated registry regulatory general information network (virrgin), reflecting its role in maintaining a transparent regulatory framework. bvi fsc’s press release 5 of 2026 can be found here and the presentation slides detailing areas of discussion here

on 13 march 2026, the cyprus securities and exchange commission (cysec) issued circular 759, to inform relevant entities about the adoption of the european securities and markets authority’s guidelines on outsourcing to cloud service providers (the esma guidelines). this replaces circular 457 from july 2021. key points include: scope revision: the esma guidelines now exclude financial entities covered under the digital operational resilience act (dora) regulation. they focus on depositaries of alternative investment funds (aifs) and undertakings for collective investment in transferable securities (ucits) not subject to dora. purpose: the esma guidelines aim to ensure consistent supervisory practices and uniform application of requirements for cloud outsourcing. they address risks and challenges in areas like outsourcing decisions, provider selection, activity monitoring, and exit strategies. this update ensures the esma guidelines remain relevant and applicable to entities outside dora's scope without altering their content or requirements. cysec’s circular 759 can be accessed here

on 6 march 2026, luxembourg's commission de surveillance du secteur financier (cssf) issued updates regarding the anti-money laundering and countering the financing of terrorism (aml/cft) data collection exercises for 2026. these updates aim to streamline processes and align with european standards. key highlights on 6 march 2026, luxembourg's commission de surveillance du secteur financier issued updates regarding the anti-money laundering and countering the financing of terrorism data collection exercises for 2026. these updates aim to streamline processes and align with european standards. cssf circular letters on aml/cft data collection on 6 march 2026, luxembourg's commission de surveillance du secteur financier (cssf) issued updates regarding the anti-money laundering and countering the financing of terrorism (aml/cft) data collection exercises for 2026. these updates aim to streamline processes and align with european standards. key highlights

on 6 march 2026, luxembourg's commission de surveillance du secteur financier (cssf) issued updates regarding the anti-money laundering and countering the financing of terrorism (aml/cft) data collection exercises for 2026. these updates aim to streamline processes and align with european standards. on 16 march 2026, the cssf issued a further circular letter confirming that the final relevant documents for the aml/cft standardised data collection have now been made available by amla and can be accessed via edesk. the circular letter is addressed to credit institutions, investment firms, investment fund managers (including registered aifms, luxembourg branches of investment fund managers, siag, fiaag and investment funds which did not designate an investment fund manager), payment institutions and electronic money institutions, virtual asset service providers, crypto asset service providers, and central securities depositories incorporated under luxembourg law. it also applies to all luxembourg branches of the above-listed entities having their registered office in an eu country or a third country. key highlights aml/cft data collection update the launch of the 2026 aml/cft standardised data collection campaign was initially delayed due to ongoing revisions by the european authority for anti-money laundering (amla). however, the cssf has since confirmed that the final documents have been made available by amla. for additional information and frequently asked questions, the cssf has directed entities to a recorded webinar held by amla and the corresponding slides. adoption of amla templates the cssf will use amla-developed templates for data collection, replacing its usual annual questionnaire for most supervised entities. this approach ensures consistency and reduces the reporting burden. revised submission deadlines for entities included in the amla data calibration sample, the deadline was updated to 22 april 2026. for entities not included in the amla data calibration sample, the deadline is 22 may 2026. specialised professionals will continue using cssf’s standard questionnaire. submission requirements the questionnaire must be submitted via the cssf edesk platform by the compliance officer in charge of compliance with the professional obligations (the rc) or the person responsible for compliance with the professional obligations (the rr). the completion of the questionnaire may be assigned within the edesk platform to another employee of the entity or a third party; however, the ultimate responsibility for the adequate completion of the questionnaire shall remain with the rc or the rr. this implies that the relevant person and the potential delegate hold an edesk account, which requires a luxtrust authentication. entity-specific requirements selected entities are participating in amla's calibration exercise, focussing on ml/tf risk assessments. non-selected entities must report ml/tf risks using amla templates. these measures reflect the cssf's alignment with eu aml/cft methodologies while ensuring effective risk management and compliance. for more information, the cssf's publication and the circular letter can be found for more information the cssf’s publication can be found here and here

further to our blog post on eu russia sanctions, please find below an updated table of sanctions. table.instrument-table { table-layout: auto; border-collapse: collapse; width: 100%; max-width: 100%; margin-left: auto; margin-right: auto; margin-bottom: 10px; border: 1px solid #000000; overflow-x: auto; } table.instrument-table th, table.instrument-table td { border: 1px solid #000000; padding: 5px; vertical-align: top; } table.instrument-table thead tr { color: #ffffff; background-color: #3a5dae; } table.instrument-table tbody tr:nth-child(even) { background-color: #f1f1f1; /* light grey */ } table.instrument-table h5 { font-size: 1.15em; margin: 0; } table.instrument-table p { font-size: 14px; color: #000000; margin: 0; line-height: 1.6; } table.instrument-table a { color: inherit; text-decoration: underline; } table.instrument-table li { font-size: 14px; color: #000000; padding-top: 2px; line-height: 1.6; } name of instrument date published amends or implements? comes into force summary of key provisions council regulation (eu) 2022/259 23 february 2022 regulation (eu) no 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (regulation 269) on publication date but with reference to 24 august 2022 new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. council implementing regulation (eu) 2022/260 23 february 2022 regulation 269 on publication date addition of 22 russian government figures/individuals and four entities added to the asset freeze list under regulation 269, related to the recognition by russia of donetsk and luhansk breakaway republics. council implementing regulation (eu) 2022/261 23 february 2022 regulation 269 on publication date addition of 336 members of the russian state duma to the asset freeze list under regulation 269, related to the vote on recognition of the breakaway republics. council decision (cfsp) 2022/265 23 february 2022 decision 2014/145/cfsp concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (decision 145) on publication date new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. addition of 22 russian government figures/individuals and four entities added to the asset freeze list under decision 145, related to the recognition by russia of donetsk and luhansk breakaway republics. council decision (cfsp) 2022/267 23 february 2022 decision 145 on publication date addition of 336 members of the russian state duma to the asset freeze list under decision 145, related to the vote on recognition of the breakaway republics. council regulation (eu) 2022/262 23 february 2022 regulation (eu) no 833/2014 concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (regulation 833) on publication date but with reference to 9 march 2022 new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council decision (cfsp) 2022/264 23 february 2022 decision 2014/512/cfsp concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (decision 512) on publication date new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council regulation (eu) 2022/263 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 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. luhansk/donetsk embargo. council decision (cfsp) 2022/266 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 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. council implementing regulation (eu) 2022/300 (regulation 300) 24 february 2022 regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus (regulation 765) on day following publication date implementing article 8a of regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus. some changes to reasoning of designation. not directly relevant to russia-ukraine conflict but contemporaneous with it. council decision (cfsp) 2022/307 24 february 2022 decision 2012/642/cfsp concerning restrictive measures in view of the situation in belarus (decision 642) on day following publication date materially equivalent to measures referred to in regulation 300. not directly relevant to russia-ukraine conflict but contemporaneous with it. decision (eu) 2022/313 of the european parliament and of the council of 24 february 2022 providing macro-financial assistance to ukraine 24 february 2022 n/a. new measure on day following publication date provision of macro-financial assistance to support ukraine’s commitment to values shared with the eu, including democracy, the rule of law, good governance, respect for human rights, sustainable development and poverty reduction, as well as its commitment to the principles of open, rule-based and fair trade. not directly relevant to russia-ukraine conflict but contemporaneous with it. council regulation (eu) 2022/328 (regulation 328) 25 february 2022 regulation 833 on day following publication date, however many measure come into force from 12 april 2022 imposition of numerous restrictive measures in various sectors of the russian economy, specifically defence, energy, aviation and finance. restrictions and prohibitions on: exports of dual-use goods and technology and on the provision of related services, as well as restrictions on exports of certain goods and technology which might contribute to russia’s technological enhancement of its defence and security sector (articles 2, 2a, 2b, 2c) the provision of public financing or financial assistance for trade with, or investment in, russia, subject to certain exceptions (article 2e) the sale, supply, transfer or export to russia of specific goods and technologies for use in oil refining, together with restrictions on the provision of related services (article 3b) export ban covering goods and technology suited for use in aviation and the space industry and prohibits the provision of insurance and reinsurance and maintenance services in relation to those goods and technology (article 3c) expanding the existing financial restrictions, in particular those on access by certain russian entities to the capital markets – including elimination of maturity periods for debt issued after 12 april 2022 (article 5) addition of new annex xii (now includes alfa bank and otkritie bank) the listing and provision of services in relation to shares of russian state-owned entities on union trading venues (article 5(5)) the acceptance of deposits exceeding certain values from russian nationals or residents (article 5b), the holding of accounts of russian clients by eu based central securities depositories (article 5e) as well as the sale of euro-denominated securities to russian clients (article 5e) bank account reporting requirements where eu bank accounts hold in excess of €100,000 (article 5g) council decision (cfsp) 2022/327 25 february 2022 decision 512 on day following publication date, however many measure come into force from 12 april 2022 equivalent to those listed under regulation 328. council regulation (eu) 2022/330 25 february 2022 regulation 269 on publication date recasting and expanding designation criteria for asset freeze under regulation 269. council decision (cfsp) 2022/329 25 february 2022 decision 145 on publication date recasting and expanding designation criteria to include persons and entities supporting and benefitting from the government of the russian federation as well as persons and entities providing a substantial source of revenue to it, and natural or legal persons associated with listed persons or entities. council implementing regulation (eu) 2022/332 (regulation 332) 25 february 2022 regulation 269 on publication date addition of: members of the russian national security council who supported russia's immediate recognition of the two self-proclaimed republics donetsk and luhansk persons who facilitated the russian military aggression from belarus, as well as those members of the state duma not yet included in that list who ratified the government decisions of the 'treaty of friendship, cooperation and mutual assistance between the russian federation and the donetsk people's republic and between the russian federation and the luhansk people's republic comprises 98 new individuals including president vladimir putin and minister of foreign affairs sergei lavrov. council decision (cfsp) 2022/331 25 february 2022 decision 145 on publication date measures equivalent to those in regulation 332. council decision (eu) 2022/333 on the partial suspension of the application of the agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia 25 february 2022 2007 agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia (2007 visa agreement) on publication date suspends application of 2007 visa agreement, including as relevant to business people and representatives of business organisations. council regulation (eu) 2022/334 28 february 2022 regulation 833 on publication date prohibition for any aircraft operated by russian air carriers, including as a marketing carrier in codesharing or blocked-space arrangements, or for any russian registered aircraft, or for any non-russian-registered aircraft which is owned or chartered, or otherwise controlled by any russian natural or legal person, entity or body, to land in, take off from or overfly the territory of the eu (article 3d). prohibition on transactions related to the management of reserves as well as of assets of the central bank of russia, including transactions with any legal person, entity or body acting on behalf of, or at the direction of, the central bank of russia, are prohibited (article 5a(4)). council decision (cfsp) 2022/335 28 february 2022 decision 512 on publication date prohibition of any transactions with the central bank of russia. russia central bank asset freeze (article 1a). denial of permission to land in, take off from, or overfly, their territories to any aircraft operated by russian air carriers, including as a marketing carrier, to any russian-registered aircraft, and to non-russian-registered aircraft which are owned or chartered, or otherwise controlled by a russian legal or natural person (article 4e). council decision (cfsp) 2022/338 on an assistance measure under the european peace facility for the supply to the ukrainian armed forces of military equipment, and platforms, designed to deliver lethal force 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 establishment of an assistance measure benefitting ukraine financed under the european peace facility (epf). the objective of the assistance measure is to contribute to strengthening the capabilities and resilience of the ukrainian armed forces to defend the territorial integrity and sovereignty of ukraine and protect the civilian population against the ongoing military aggression. provides for a centralised budget framework and reporting coordination between ministries of defence of the eu member states. council decision (cfsp) 2022/339 on an assistance measure under the european peace facility to support the ukrainian armed forces 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 provision of assistance measures calling for contributions up to €50,000,000. the funds called by the administrator for assistance measures to be used to pay expenditure within the limits approved by the committee established by decision (cfsp) 2021/509 in the 2022 amending budget corresponding to the assistance measure. council implementing regulation (eu) 2022/336 28 february 2022 regulation 269 on publication date addition of: numerous ultra-high net worth russian businessmen (oligarchs) including igor sechin, chief executive of rosneft oil co. alexey mordashov, the majority owner of steel giant severstal pao alisher usmanov mikhail fridman and petr aven, founders of alfa bank the measures also target key kremlin officials including dimitry peskov, vladimir putin’s press secretary; several journalists the eu accuses of anti-ukrainian propaganda; and military officers council decision (cfsp) 2022/337 28 february 2022 regulation 269 on publication date measures equivalent to those in regulation 336. council regulation (eu) 2022/345 1 march 2022 regulation 833 on publication date imposing further restrictive measures with regard to the provision of specialised financial messaging services to certain russian credit institutions and their russian subsidiaries, which are relevant for the russian financial system and which are already the subject of restrictive measures imposed by the union or by partner countries and, subject to certain exceptions, with regard to engagement with the russian direct investment fund. it also prohibits, subject to certain exceptions, the supply of euro banknotes to russia. these measures fall within the scope of the treaty and, therefore, in particular with a view to ensuring their uniform application in all member states, regulatory action at the level of the union is necessary. council decision (cfsp) 2022/346 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 345. council regulation (eu) 2022/350 1 march 2022 regulation 833 on publication date prohibition on the broadcasting and the facilitation of broadcasting by the following media outlets, including through transmission/distribution by any means such as cable, satellite, ip-tv, internet service providers, internet video-sharing platforms or apps: sputnik rt – russia today english rt – russia today uk rt – russia today germany rt – russia today france rt – russia today spanish these measures also suspend any broadcasting licence, authorisation or arrangement with the above entities. council decision (cfsp) 2022/351 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 350. council regulation (eu) 2022/353 2 march 2022 regulation 269 on publication date addition of 22 belarusian individuals to the asset freeze list under regulation 269. council decision (cfsp) 2022/354 2 march 2022 decision 145 on publication date equivalent to those listed under regulation 353 above. council regulation (eu) 2022/355 2 march 2022 regulation 765 on publication date renames the regulation 765 to refer expressly to the fact that these measures relate also to the involvement of belarus in the russian aggression against ukraine. introduces extensive new prohibitions with respect to dealing with belarus, some of these equivalent to the prohibitions introduced on russia under regulation 328 (eg in relation to dual-use goods and technology, goods and technology which might contribute to belarus’s military and technological enhancement), as well as a number of prohibitions with respect to wood, cement, iron, steel and rubber products and specific machinery as listed in the regulation. council decision (cfsp) 2022/356 2 march 2022 decision 642 on publication date equivalent to those listed under regulation 356 above. council implementing regulation (eu) 2022/375 4 march 2022 (but dated 3 march) regulation (eu) no 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date update following a review by the council, on the rights of defence and effective judicial protection on individuals charged with the misappropriation of ukrainian state funds, including former ukrainian president yanukovych (now thought to be in hiding in russia). council decision (cfsp) 2022/376 4 march 2022 (but dated 3 march) decision 2014/119/cfsp concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date equivalent to those listed under implementing regulation 375 above. council implementing regulation (eu) 2022/396 9 march 2022 regulation 269 on publication date adds a further 160 persons to the asset freeze list under regulation 269, including persons owning or holding senior management positions or otherwise connected to prominent russian businesses considered to support the russian government, as well as a number of persons of the federation council who ratified the government decisions to recognise the declaration of independence of the donetsk and luhansk regions. council decision (cfsp) 2022/397 9 march 2022 decision 145 on publication date equivalent to those listed under implementing regulation 397 above. council regulation (eu) 2022/394 9 march 2022 regulation 833 on publication date extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets”. this regulation also introduces a new prohibitions in relation to maritime navigation goods and technology to any natural or legal person, entity or body in russia, for use in russia, or for the placing on board of a russian-flagged vessel. council decision (cfsp) 2022/395 9 march 2022 decision 512 on publication date equivalent to those listed under regulation 394 above. council regulation (eu) 2022/398 9 march 2022 regulation 765 on publication date expands the existing financial restrictions under the belarus sanctions to include prohibitions similar to those already included under regulation 833 on russia. in particular, it prohibits the listing and provision of services in relation to shares of belarusian state-owned entities on eu trading venues. in addition, it introduces new measures which significantly limit the financial inflows from belarus to the union by prohibiting the acceptance of deposits exceeding certain values from belarusian nationals or residents, the holding of accounts of belarusian clients by the eu central securities depositories as well as the selling of euro-denominated securities to belarusian clients. it also prohibits transactions with the central bank of belarus related to the management of reserves or assets, the provision of public financing for trade with and investment in belarus, with limited exceptions, and the provision of euro denominated banknotes to belarus or for use in belarus it also imposes further restrictive measures with regard to the provision of specialised financial messaging services to certain belarusian credit institutions and their belarusian subsidiaries, which are relevant for the belarusian financial system and which are already the subject of restrictive measures imposed by the union it also extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets” this also adds obligations on the network manager for air traffic management network functions of the single european sky regarding overflight prohibitions and amend the provisions on non-circumvention council decision (cfsp) 2022/399 9 march 2022 decision 642 on publication date equivalent to those listed under regulation 398 above. council regulation (eu) 2022/408 11 march 2022 regulation 269 on publication date amends the information concerning 37 individuals and six entities already included under regulation 269. council decision (cfsp) 2022/411 11 march 2022 decision 145 on publication date equivalent to those listed under regulation 408 above. council regulation (eu) 2022/427 15 march 2022 regulation 269 on publication date adds a further 15 individuals and 9 entities to the asset freeze list under regulation 269, including among others prominent figures such as roman abramovich. council regulation (eu) 2022/428 15 march 2022 regulation 833 on publication date introduces further sectoral restrictive measures, as follows: prohibits all transactions with certain state-owned companies prohibit the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities, to any russian person or entity tightens export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, and expands the list of persons connected to russia’s defence and industrial base, which are subject to those restrictions prohibits new investments in the russian energy sector, and introduces a comprehensive export restriction on equipment, technology and services for the energy industry in russia, with the exception of nuclear industry and the downstream sector of energy transport introduces further trade restrictions concerning iron and steel, as well as on luxury goods council decision (cfsp) 2022/429 15 march 2022 decision 145 on publication date equivalent to those listed under regulation 427 above. council decision (cfsp) 2022/430 15 march 2022 decision 512 on publication date equivalent to those listed under regulation 428 above. council regulation (eu) 2022/580 8 april 2022 regulation 269 on publication date expands the provisions of article 6b of regulation 269 to provide for further grounds for persons to apply for a licence to be exempted from the asset freeze restrictions. in particular, the amendments introduce: as relevant to the latest russian banks addedto the asset freeze list (i.e. vtb, otkritie, novikombank and sovcombank), the possibility to apply for a licence for those entities to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to those entities, for the purposes of termination by 9 october 2022 of operations, contracts, or other agreements, including correspondent banking relations, concluded with those entities before 8 april 2022 as relevant generally to persons included on the asset freeze list, the possibility to apply for a licence for such asset frozen persons to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to such persons, provided that the relevant competent authority is able to determine that: the funds or economic resources are necessary for the sale and transfer by 9 october 2022 of proprietary rights in a legal person, entity or body established in the union where those proprietary rights are directly or indirectly owned by a natural or legal person, entity or body listed in annex i the proceeds of such sale and transfer remain frozen council implementing regulation (eu) 2022/581 8 april 2022 regulation 269 on publication date adds a further 216 individuals and 18 entities to the asset freeze list, notably including four russian banks (vtb, otkritie, novikombank and sovcombank) as well as further high profile russian government officials and businessmen. council decision (cfsp) 2022/582 8 april 2022 decision 145 on publication date equivalent to those listed under regulation 581 above. council regulation (eu) 2022/576 8 april 2022 regulation 833 on publication date introduces further sectoral prohibitions, as follows: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector introduces additional import restrictions on certain goods from russia, in particular on coal and other solid fossil fuels introduces further export restrictions to russia, in particular on jet fuel and other goods prohibits the award and continued execution of public contracts and concessions with russian nationals and entities or bodies established in russia imposes a prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to russian publicly owned or controlled entities extends the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of the member states extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for the purchase, import or transport of fossil fuels and certain minerals into switzerland, the eea and the western balkans extends the exemptions from the prohibition on transaction with certain russian state-owned enterprises and their subsidiaries to countries in the european economic area and switzerland as well as to the western balkans introduces a prohibition for road transport undertakings established in russia to transport goods by road in the eu prohibits access to ports to vessels registered under the flag of russia notably, introduces a prohibition on acting as a trustee or in similar capacities for russian persons and entities, as well as a prohibition on providing certain services to trusts council regulation (eu) 2022/577 8 april 2022 regulation 765 on publication date introduces further sectoral prohibitions, as follows: imposes further restrictive measures prohibiting the sale to belarus of transferable securities denominated in any official currency of a member state, and prohibiting the sale, supply, transfer or export to belarus of banknotes denominated in any official currency of a member state imposes further restrictive measures prohibiting road transport undertakings established in belarus from transporting goods by road within the territory of the european union council decision (cfsp) 2022/578 8 april 2022 decision 512 on publication date equivalent to those listed under regulation 576 above. council decision (cfsp) 2022/579 8 april 2022 decision 642 on publication date equivalent to those listed under regulation 577 above. council regulation (eu) 2022/625 13 april 2022 regulation 269 on publication date adds exceptions to the freezing of the assets of, and the restrictions on making funds and economic resources available to, designated persons, entities and bodies for certain clearly defined categories of bodies, persons, entities, organisations and agencies for exclusively humanitarian purposes in ukraine. council decision (cfsp) 2022/627 13 april 2022 decision 145 on publication date equivalent to those listed under regulation 625 above. council regulation (eu) 2022/626 13 april 2022 regulation 263 on publication date adds exceptions that allow clearly defined categories of bodies, persons, entities, organisations and agencies to provide goods and technology for use in certain sectors, as well as certain restricted services and assistance related to such goods and technology, to persons, entities and bodies in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine or for use in those areas, where necessary for humanitarian purposes. similarly, the exceptions allow for the provision of specific restricted services and assistance directly relating to certain infrastructure in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine, where necessary for humanitarian purposes. luhansk/donetsk embargo. council decision (cfsp) 2022/628 13 april 2022 decision 266 on publication date equivalent to those listed under regulation 626 above. council regulation (eu) 2022/658 21 april 2022 regulation 269 on publication date adds a further two individuals to the asset freeze list. council decision (cfsp) 2022/660 21 april 2022 decision 145 on publication date equivalent to those listed under regulation 658 above. council regulation (eu) 2022/876 3 june 2022 regulation 765 on publication date adds a further two individuals and eight entities should be included in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 (belarussian asset freeze list). council regulation (eu) 2022/877 3 june 2022 regulation 765 on publication date expands the list of entities subject to restrictions with regard to authorisations for the sale, supply, transfer or export of dual-use goods and technology, and goods and technology which might contribute to belarus’s military and technological enhancement, or to the development of its defence and security sector. this amendment also expands the list of belarusian credit institutions and their belarusian subsidiaries subject to a swift ban. it also includes provisions clarifying and strengthening the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements council regulation (eu) 2022/878 3 june 2022 regulation 269 on publication date adds a further 65 individuals and 18 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 269 (russian asset freeze list). council regulation (eu) 2022/879 3 june 2022 regulation 833 on publication date this is the key legal instrument introducing the new sectoral prohibitions under the sixth package. the new prohibitions consist of: oil imports: introduction of an embargo on the import of crude oil and refined oil products from russia, with a programme to gradually phase out russian oil imports. these provisions include temporary exemptions for certain cases where member states are heavily dependent on russian oil oil transport services: after a wind down period of 6 months, eu operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to third countries financial services: an additional three russian banks, including russia's largest bank sberbank, have been removed from swift business services: the deadline for winding down certain prohibited trust services has been extended to 5 july 2022 and those provisions have been further refined. this latest package also introduces a prohibition on the provision to the russian government, as well as to legal persons, entities or bodies established in russia of certain business-relevant services such as accounting, auditing, statutory audit, bookkeeping and tax consulting services, business and management consulting, and public relations services broadcasting suspension: the broadcasting activities of rossiya rtr/rtr planeta, rossiya 24/russia 24, and tv centre international – have been suspended. the advertising of products or services on sanctioned outlets has also been prohibited export restrictions: the list of advanced technology items banned from export to russia has been expanded to include additional chemicals that could be used in the process of manufacture of chemical weapons penalties: this amendment also clarifies and strengthen the provisions on national penalties for the breach of the sanctions under regulation 833 council regulation (eu) 2022/880 3 june 2022 regulation 269 on publication date introduces further derogation options from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities. this amendment also clarifies and strengthens the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements. council decision (cfsp) 2022/881 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 876 above. council decision (cfsp) 2022/882 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 877 above. council decision (cfsp) 2022/883 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 878 above. council decision (cfsp) 2022/884 3 june 2022 decision 512 on publication date equivalent to those listed under regulation 879 above. council decision (cfsp) 2022/885 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 880 above. regulation (eu) 2022/1280 of the european parliament and of the council 18 july 2022 n/a. new measure on publication date laying down specific and temporary measures, in view of russia’s invasion of ukraine, concerning driver documents issued by ukraine in accordance with its legislation. council regulation (eu) 2022/1269 (regulation 1269) 21 july 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector imposes a prohibition on the direct or indirect import, purchase or transfer of gold, which constitutes russia’s most significant export after energy extends the port access ban to locks allows, the sharing of technical assistance with russia in relation to aviation goods and technology to safeguard the technical industrial standard setting process of the international civil aviation organization (icao) introduces an exemption from the prohibition to enter into any transactions with russian public entities necessary to ensure access to judicial, administrative or arbitral proceedings harmonises the notification requirements for national competent authorities granting authorisations pursuant to derogations provided expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for agricultural products and the supply of oil and petroleum products to third countries this regulation also includes clarifications that the measures in regulation 833 do not prevent third countries and their nationals from trading with russia or trading in russian goods. council implementing regulation (eu) 2022/1270 21 july 2022 regulation 269 on publication date adds a further 48 persons and 9 entities to the asset freeze list under regulation 269, most notably sberbank which to date had not been listed. council decision (cfsp) 2022/1271 21 july 2022 decision 512 on publication date equivalent to those listed under regulation 1269 (amending regulation 833) above. council regulation (eu) 2022/1273 (regulation 1273) 21 july 2022 regulation 269 on publication date introduces a number of derogations to the asset freeze provisions of regulation 269: further derogation from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities in order to urgently prevent or mitigate an event likely to have a serious and significant impact on human health and safety or the environment derogation from the asset freeze and the prohibition to make funds and economic resources available to the key designated russian banks (being bank rossiya, promsvyazbnak, vnesheconombank (veb), otkiritie, novikombank, sovcombank, vtb bank and sberbank derogation from the asset freeze and the prohibition to make funds and economic resources available for the orderly wind-down of operations, including correspondent banking relations with respect to sberbank it additionally introduces requirements on designated persons and entities to report assets held within a member state and further strengthens the reporting obligations on eu operators to prevent breaches and circumvention of the asset freeze. council decision (cfsp) 2022/1272 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1273 (amending regulation 269) above. council implementing regulation (eu) 2022/1274 (regulation 1274) 21 july 2022 regulation 269 on publication date imposes an asset freeze on six individuals and one entity related to syrian regime involved in the recruitment of syrian mercenaries to fight in ukraine alongside russian troops. council decision (cfsp) 2022/1276 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1274 above. regulation (eu) 2022/1278 of the european parliament and of the council 22 july 2022 regulation 508 on publication date introduces measures to mitigate the impact of russia’s war of aggression against ukraine on the fishery and aquaculture sector. council implementing regulation (eu) 2022/1354 (regulation 1354) 4 august 2022 regulation 269 on publication date added two further individuals to the asset freeze list: oleksandr viktorovych yanukovych viktor fedorovych yanukovych council decision (cfsp) 2022/1355 4 august 2022 decision 145 on publication date equivalent to those listed under regulation 1354 above. council decision (cfsp) 2022/1355 (regulation 1446) 1 september 2022 regulation 269 on publication date added three further individuals to the asset freeze list. council decision (cfsp) 2022/1355 1 september 2022 decision 145 on publication date equivalent to those listed under regulation 1446 above. council regulation (eu) 2022/1903 (regulation 1903) 6 october 2022 regulation 263 on publication date extends the geographical scope of the restrictions to cover all the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia. council decision (cfsp) 2022/1908 6 october 2022 decision 266 on publication date equivalent to those listed under regulation 1903 above. council regulation (eu) 2022/1904 (regulation 1904) 6 october 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends the list of restricted items which might contribute to the russian federation’s military and technological enhancement or to the development of its defence and security sector prohibits the sale, supply, transfer or export of firearms, their parts and essential components and ammunition extends the import ban on steel products and imposes import and export prohibitions on further products originating from russia (such as woodpulp, paper and certain elements used in the jewellery industry such as stones and precious metals, among others) as well imposing restrictions on the sale, supply, transfer or export of additional goods used in the aviation sector introduces an exemption from the prohibition to provide technical assistance, brokering services, financing or financial assistance regarding maritime transport to third countries of crude oil or petroleum products which originate or are exported from russia, purchased at or below a pre-established price cap implements various provisions in connection with the introduction of a price cap as agreed by the price cap coalition expands the prohibitions related to the provision of services for the maritime transport of crude oil and certain petroleum products to third countries, to further prohibit the maritime transport of such goods to third countries, subject to implementation of the price cap expands the prohibition to engage in any transaction with certain russian state-owned or controlled legal persons, entities or bodies by including a ban on union nationals to hold any posts on the governing bodies of those legal persons, entities or bodies adds to the list of russian state-owned or controlled entities that are subject to the transaction ban of the russian maritime register of shipping; extends the port access and lock ban in the territory of the union to vessels certified by the russian maritime register of shipping bans the provision on crypto-asset wallet account or custody services, regardless of the total value of crypto assets extends the prohibition on the provision of certain services to the russian federation by including architectural, engineering, it consultancy and legal advisory services council decision (cfsp) 2022/1909 6 october 2022 decision 512 on publication date equivalent to those listed under regulation 1904 above. council regulation (eu) 2022/1905 (regulation 1905) 6 october 2022 regulation 269 on publication date introduced a further criterion for the listing of natural or legal persons, entities or bodies subject to asset freeze and the prohibition to make funds and economic resources available to designated persons and entities, allowing persons identified to facilitate infringements of the prohibition against circumvention of the provisions of regulation 269, to also be listed. it additionally introduces further derogations from the asset freeze and the prohibition to make funds or economic resources available and introduces additional provisions regarding member states’ obligations regarding the granting of derogations. council implementing regulation (eu) 2022/1906 (regulation 1906) 6 october 2022 regulation 269 on publication date adds a further 30 persons and 7 entities to the asset freeze list under regulation 269. council decision (cfsp) 2022/1907 6 october 2022 decision 145 on publication date equivalent to those listed under regulation 1905 and regulation 1906 above. council implementing regulation (eu) 2022/1985 (regulation 1985) 20 october 2022 regulation 269 on publication date adds 3 iranian persons and 1 entity to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/1986 20 october 2022 decision 145 on publication date equivalent to those listed under regulation 1985 above. council implementing regulation (eu) 2022/2229 (regulation 2229) 14 november 2022 regulation 269 on publication date adds 2 iranian individuals and 2 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2233 14 november 2022 decision 145 on publication date equivalent to those listed under regulation 2229 above. council regulation (eu) 2022/2367 (regulation 2367) 3 december 2022 regulation 833 on publication date establishes the price cap, which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. clarifies the existing prohibition on the trading and brokering of russian crude oil and petroleum products and extends the price cap exemption when such goods are traded at or below the price cap. extends the transition period applicable to the transport of crude oil and certain petroleum products after every subsequent change in the price cap for a period of 90 days to the provision, directly or indirectly, of technical assistance, brokering services or financing or financial assistance, related to the transport, subject to the same conditions, to ensure consistent implementation of the price cap by all operators. introduces a transitional period of 45 days for vessels carrying crude oil originating in russia, which was purchased and loaded onto the vessel prior to 5 december 2022 and unloaded at the final port of destination prior to 19 january 2023. clarifies that the prohibition to provide services related to the transport of russian crude oil or petroleum products by a third country flagged vessel applies in relation to vessels which in the past transported such goods purchased above the price cap, provided the operator responsible for that transport knew or had reasonable cause to suspect that this was the case. introduces an exemption from the prohibitions of providing maritime transport and technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries where necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters. introduces a regular review of the price cap mechanism as of mid-january 2023 and every two months thereafter. such review needs to take into account the objectives of the price cap, including its ability to reduce russia’s oil revenues, as well as the principle that the price cap should be at least 5% below the average market price for russian oil and petroleum products. commission implementing regulation (eu) 2022/2368 (regulation 2368) 3 december 2022 regulation 833 on publication date introduces the price cap (usd 60 / barrel) which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. council decision (cfsp) 2022/2369 3 december 2022 decision 512 on publication date equivalent to those listed under regulations 2367 and 2368 above. council implementing regulation (eu) 2022/ 2430 (regulation 2430) 12 december 2022 regulation 269 on publication date adds 4 iranian individuals and 4 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2432 12 december 2022 decision 145 on publication date equivalent to those listed under regulation 2430 above. council regulation (eu) 2022/2474 (regulation 2474) 16 december 2022 regulation 833 on publication date extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding drone engines, further chemical and biological equipment, riot control agents and electronic components. expands the list of entities connected to russia’s military and industrial complex, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed by adding 168 new entities. extends the suspension of the broadcasting licences in the union of certain russian media outlets. furthers the already existing prohibition targeting new investments in the russian energy sector by additionally prohibiting new investments in the russian mining sector, with the exception of mining and quarrying activities involving certain critical raw materials. expands the export ban covering goods and technology suited for use in aviation and the space industry to include aircraft engines and their parts. introduces a derogation allowing the provision of technical assistance related to the use of goods and technology suited for use in aviation or the space industry, when this is necessary to avoid collision between satellites, or their unintended re-entry into the atmosphere. introduces a possibility for the national competent authorities to grant derogations to allow for certain aviation goods, which are also widely used in the medical field, to be exported for medical, pharmaceutical and humanitarian purposes. extends the list of goods which could contribute to the enhancement of russian industrial capacities by including such items as generators, toy drones, laptops, hard drives, it components, night-vision and radio-navigation equipment, cameras and lenses. extends for an additional six months the exemption applicable to the imports of methanol originating in or exported from russia. clarifies that, as is the case for the member states importing russian crude oil by pipeline, bulgaria cannot sell petroleum products obtained from russian crude oil imported on the basis of that derogation to buyers located in other member states or in third countries. bunkering or refuelling of a vehicle or aircraft in the member states which benefit from those derogations does not fall under that prohibition. allows hungary, slovakia and bulgaria to export to ukraine certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question, including, when necessary, by transiting through other member states. allows bulgaria to export to third countries certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question. introduces a reporting obligation for the operators engaged in transactions concerning natural gas condensate from lng productions plants. adds the russian regional development bank to the list of russian state-owned or controlled entities that are subject to the transaction ban. bans union nationals from holding any posts on the governing bodies of all russian state-owned or controlled legal persons, entities or bodies that are established in russia, subject to certain derogations. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. introduces a temporary derogation from the import and export prohibitions, by enabling the sale, supply or transfer of such goods, or their import into the union until 30 september 2023 and applies only to those goods that were already physically located in russia at the time when the relevant prohibitions entered into force. aligns the member states’ reporting obligation on deposits exceeding eur 100 000 from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia, with the similar obligations that already exist for the other types of deposits. extends the existing prohibition on the provision of certain services to the russian federation and to legal persons, entities or bodies established in russia by banning the provision of advertising, market research and public opinion polling services, as well as product testing and technical inspection services. further clarifies and amends the exemptions to the import ban on steel products that either originate in russia or have been exported from russia. council regulation (eu) 2022/2475 (regulation 2475) 16 december 2022 regulation 269 on publication date introduces a new deadline, 17 june 2023, for the derogation allowing divestments by sberbank with a view to winding down its operations. extends to the 2 newly listed entities (being credit bank of moscow and dalnevostochny bank) the derogation from the asset freeze and from the prohibition to make funds and economic resources available, in order to allow the termination of operations, contracts, or other agreements, previously concluded with those entities. introduces a new derogation allowing the unfreezing assets of, and to make funds and economic resources available to, certain individuals who held a significant role in international trade and agricultural and food products, including wheat and fertiliser, prior to their listing. extends the deadline for certain general derogations. council implementing regulation (eu) 2022/2476 (regulation 2476) 16 december 2022 regulation 269 on publication date adds a further 141 individuals and 49 entities to the asset freeze list under regulation 269, including credit bank of moscow and dalnevostochny bank. council decision (cfsp) 2022/2477 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2476 above. council decision (cfsp) 2022/2478 16 december 2022 decision 512 on publication date equivalent to those listed under regulation 2474 above. council decision (cfsp) 2022/2479 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2475 above. council implementing regulation (eu) 2023/192 (regulation 192) 30 january 2023 regulation 269 on publication date adds 1 iranian entity to the asset freeze list under regulation 269 due to its involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2023/193 30 january 2023 decision 145 on publication date equivalent to those listed under regulation 192 above. council regulation (eu) 2023/426 (regulation 426) 25 february 2023 regulation 269 on publication date extends to certain newly-listed banks (rosbank, tinkoff bank and alfa bank) certain licensing grounds for derogations from the asset freeze, and to allow the processing of payments by the jewish claims conference through one of them. extends the deadline to apply for the disposal or the transfer of securities by the national settlement depository (nsd), and which are currently or were previously controlled by vtb bank. introduces a derogation allowing for the termination of operations, contracts or other agreements with limited liability company “commercial vehicles - gaz group”, and extended by three months the deadline for the derogation to allow the sale and transfer of proprietary rights in a legal person, entity or body established in the eu owned by a listed natural or legal person, entity or body. introduces a requirement that natural and legal persons, entities and bodies should supply to the national competent authorities detailed information on funds and economic resources which have been frozen or should have been treated as frozen, as well as information on funds and economic resources belonging to, owned, held or controlled by listed natural or legal persons, entities or bodies which were subject to any move, transfer, alteration, use, access, or dealing shortly before the listing. introduces a requirement that central securities depositories, due to their systemic importance for the functioning of securities markets, should provide the relevant information to the member state concerned and simultaneously to the commission. specifies the type of information to be provided to national competent authorities, which authorities should then transmit that information to the commission, with specific adaptations in the case of criminal proceedings. provides for deferred application of the more detailed reporting requirements, in order to allow time to adapt. clarifies that member states and the relevant natural and legal persons, entities and bodies are required to cooperate with the commission in any verification of such information, and that the commission should be able to request any additional information, while informing the member state concerned of such request. council regulation (eu) 2023/427 (regulation 427) 25 february 2023 regulation 833 on publication date adds 96 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed. adds several iranian entities to the list of natural and legal persons, entities and bodies subject to restrictive measures under decision 512, taking into account the direct connection between iranian manufacturers of unmanned aerial vehicles and the russian military and industrial complex and the concrete risk that certain goods or technology are used for the manufacture of military systems that contribute to russia’s war of aggression against ukraine. extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding rare-earths and compounds, electronic integrated circuits and thermographic cameras, among others. extends the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. prohibits the transit via the territory of russia of dual-use goods and technology and of arms exported from the eu in order to minimise the risk of circumvention of the restrictive measures. extends the suspension of broadcasting licences in the eu of russian media outlets under the permanent control of the russian leadership and the prohibition against broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of such media outlets in the eu, or directed at the eu. the measures should be maintained until the aggression against ukraine is put to an end, and until the russian federation, and its associated media outlets, cease to conduct propaganda actions against the eu and its member states. those measures do not prevent the media outlets and their staff from carrying out activities in the eu other than broadcasting, such as research and interviews. restricts the possibility to hold any posts in the governing bodies of european critical infrastructures and critical infrastructures identified or designated as such under national law. imposes a prohibition on providing gas storage capacity in the eu to russian nationals, natural persons residing in russia or legal persons or entities established in russia. introduces an obligation for aircraft operators to notify non-scheduled flights to their competent authorities the member state concerned should immediately inform other member states, the network manager and the commission where it does not clear such a flight. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. it also extends the duration of the period in which the competent authorities of the member states may authorise transactions which are necessary for the divestment and withdrawal by those russian state-owned entities from eu companies. requires that natural and legal persons, entities and bodies supply to the competent authorities of the member states and simultaneously to the commission information on the management of reserves and assets of the central bank of russia, which they hold or control or are a counterparty to. it is also appropriate to specify the type of information to be provided and how this should be treated and used to ensure the uniform application of this reporting obligation. it should also be clarified that member states and the relevant natural and legal persons, entities and bodies must cooperate with the commission in any verification of such information and that the commission may request any additional information, while informing the member state concerned of such request. in order to allow time to adapt, the new rules provide for deferred application of the new reporting requirements. introduces a temporary derogation from the prohibition on providing accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services, architectural and engineering services, legal advisory services and it consultancy services. in order to facilitate an expeditious exit from the russian market, this derogation is temporary and limited in scope, enabling until 31 december 2023 the continuation of the provision of services to and for the exclusive benefit of the legal persons, entities or bodies resulting from the divestment. additionally, the competent authorities of the member states should ensure that the services are not provided to the government of russia or benefit military end-users or have a military-end use. provides for certain exemptions for eu operators to provide pilot services to vessels in innocent passage as defined by international law which are necessary for reasons of maritime safety. provides for rules on the release by the customs authorities of the member states of goods which are physically in the eu and which had already been presented to customs authorities when they became subject to such restrictions. authorises member states to release goods already brought into the eu in the past. the competent authorities of the member states should ensure that the release of the goods and any payment related thereto comply with the provisions and objectives of eu restrictive measures. similarly, any decision not to release such goods should comply with those objectives and ensure, among others, that the goods are not returned to russia. makes certain technical corrections in the operative text of decision 512. council implementing regulation (eu) 2023/429 (regulation 429) 25 february 2023 regulation 269 on publication date adds a further 87 individuals and 34 entities to the asset freeze list under regulation 269, including most significantly rosbank, tinkoff bank and alfa bank. council implementing regulation (eu) 2023/430 (regulation 430) 25 february 2023 regulation (eu) 2020/1998 on publication date designates the wagner group and three of its members involved in serious human rights violations in different parts of the world. adds 8 individuals and 7 entities in the list of natural persons, legal persons, entities and bodies subject to restrictive measures under regulation (eu) 2020/1998. council decision (cfsp) 2023/432 25 february 2023 decision 145 on publication date equivalent to those listed under regulation 426 above. council decision (cfsp) 2023/433 25 february 2023 decision 1999 on publication date equivalent to those listed under regulation 430 above. council decision (cfsp) 2023/434 25 february 2023 decision 512 on publication date equivalent to those listed under regulation 427 above. council implementing regulation (eu) 2023/419 (regulation 419) 27 february 2023 regulation 765 on publication date renews the restrictive measures imposed on belarus until 28 february 2024. amends the entries relating to 21 individuals and 2 entities included in the list of natural and legal persons, entities and bodies subject to restrictive measures under regulation 765. council decision (cfsp) 2023/421 27 february 2023 decision 642 on publication date equivalent to those listed under regulation 419 above. council regulation (eu) 2023/1214 (regulation 1214) 23 june 2023 regulation 833 on publication date prohibits the transit of goods and technology suited for use in aviation or space industry and jet fuel and fuel additives, exported from the eu to third countries via russia. allows for appropriate individual measures such as designations or trade restrictions, to be adopted to address the involvement of third-country operators facilitating circumvention. introduces the possibility of last-resort measures restricting the sale, supply, transfer or export of sensitive dual-use goods and technology, or goods and technology that might contribute to the enhancement of russia’s military, technological or industrial capacities or to the development of russia’s defence and security sector to third countries used for circumvention. adds 87 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, certain entities from third countries involved in the circumvention of trade restrictions, and certain entities involved in the development, production and supply of electronic components for russia’s military and industrial complex. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which contribute to the development or production of russia’s military systems, including electronic components, semiconductor materials, manufacturing and testing equipment for electronic integrated circuits and printed circuit boards, precursors to energetic materials and precursors to chemical weapons, optical components, navigational instruments, metals used in the defence sector and marine equipment. extends the list of restricted firearms, their parts, essential components and ammunition, and adds other types of arms. imposes further restrictions on exports of goods which could contribute to the enhancement of russian industrial capacities. prohibits the sale, licence or transfer in any other way of intellectual property rights or trade secrets used in connection with restricted goods. extends the suspension of the broadcasting licences in the eu of five russian media outlets under the permanent control of the russian leadership, and the prohibition against broadcasting their content. extends the prohibition on the transport of goods by road in the eu by trailers and semi-trailers. prohibits access to ports and locks in the territory of the eu by vessels engaged in ship-to-ship transfers where the competent authorities have reasonable cause to suspect that a vessel is in breach of the ban on importing seaborne russian crude oil and petroleum products into the eu or is transporting russian crude oil or petroleum products purchased above the price cap agreed by the price cap coalition. prohibits access to ports and locks in the territory of the eu by vessels which competent authorities have reasonable cause to suspect of illegally interfering with, switching off or otherwise disabling their shipborne automatic identification systems (ais) when transporting russian crude oil and petroleum products. that prohibition does not apply in circumstances where the shipborne ais can be legitimately turned off in accordance with international agreements, rules or standards that provide for the protection of navigational information, such as navigation through high-security-risk waters. ends the temporary derogation granted to germany and poland for the supply of crude oil by pipeline from russia through the northern section of the druzhba oil pipeline. the import of oil which originates in kazakhstan or another third country and is transiting through russia via the druzhba oil pipeline is not prohibited. introduces derogations from the prohibitions on the sale, supply, transfer or export directly or indirectly to any natural or legal person, entity or body in russia or for use in russia of certain goods or technology, on the provision of related financing or financial assistance, technical assistance, brokering services or other services, or on the provision of auditing services, engineering services, legal advisory services, technical testing and analysis services which are strictly necessary for that purpose, subject to strict conditions to avoid the risk of circumvention. extends prohibition on providing transferable securities to financial instruments denominated in any currency. introduces a derogation from the prohibition to provide certain services to russian entities required for the setting-up, certification or evaluation of a firewall removing the control exercised by a listed person over the assets of a non-listed eu entity which the listed person owns or controls. clarifies the evidence required for importation of iron and steel products processed in a third country incorporating iron and steel products originating in russia. introduces clarifications regarding the competent authorities which receive notifications of non-scheduled flights between russia and the eu. extends the deadline for the application of a temporary derogation from the prohibition on providing certain services, with the aim of further facilitating divestment from the russian market by union operators. introduces a temporary derogation from the prohibition on providing legal advisory services to legal persons, entities or bodies established in russia. the competent authorities of the member states may authorise the provision, until 31 march 2024, of legal services which are mandatory, under the national legislation of the member state, for such divestments to be completed. adds switzerland to the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. council regulation (eu) 2023/1215 (regulation 1215) 23 june 2023 regulation 269 on publication date introduces a further criterion for the asset freeze listing to allow the designation of legal persons, entities or bodies operating in the russian it sector with a licence from federal security service of the russian federation (fsb) or the russian ministry of industry and trade. amends an existing listing criterion regarding the circumvention of eu sanctions, or significant frustration of eu sanctions by third country operators, including instances where the main activity of a third country operator consists of purchasing restricted goods in the eu that reach russia, the involvement of russian individuals or entities, the recent creation of a company for purposes related to restricted goods reaching russia, or a drastic increase in the turnover of a third country operator involved in such activities. introduces further derogations from the asset freeze to allow for divestment from russian companies and the disposal of certain types of securities held with vtb bank and national settlement depository (nsd). introduces a derogation allowing the provision of services required for the establishment of a firewall removing the control by a listed person over the assets of an eu entity. allows for the provision of pilot services in specific circumstances to safeguard maritime safety. insertion of certain clarifications in the provision on information sharing between competent authorities and regarding the respect of the confidentiality of the communications between lawyers and their clients in the context of reporting obligations. introduces a derogation allowing the release of frozen funds belonging to alexey alexandrovits mordashov after having determined that such funds are necessary for the completion of transactions of a joint venture. introduces a derogation allowing the release of frozen funds for certain banks when such funds are necessary for the purchase, import or transport of agricultural and food products, namely the following entities, bank rossiya, promsvyazbank, veb.rf, otkritie fc bank, novikombank, sovcombank, vtb bank, sberbank, credit bank of moscow, jsc ‘dalnevostochniy bank’, jsc ural civil aviation factory, alfa-bank js, public joint-stock company rosbank, mrb bank and cmr bank. council implementing regulation (eu) 2023/1216 (regulation 1216) 23 june 2023 regulation 269 on publication date adds a further 71 individuals and 33 entities to the asset freeze list under regulation 269, including most significantly mrb bank and cmr bank. council decision (cfsp) 2023/1217 23 june 2023 decision 512 on publication date equivalent to those listed under regulation 1214 above. council decision (cfsp) 2023/1218 23 june 2023 decision 145 on publication date equivalent to those listed under regulation 1215 above. council implementing regulation (eu) 2023/1591 (regulation 1591) 3 august 2023 regulation 765 on publication date adds a further 38 individuals and 3 entities from belarus to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765. council implementing decision (cfsp) 2023/1592 3 august 2023 decision 642 on publication date equivalent to those listed under regulation 1591 above. council regulation (eu) 2023/2873 (regulation 2873) 18 december 2023 regulation 269 on the day following that of its publication date extends the listing criteria to cover natural or legal persons, entities or bodies benefitting from the compulsory transfer of ownership of, or control over, entities established in russia that were previously owned or controlled by eu entities. sets out the conditions on which the council is able to retain the name of a deceased person on the asset freeze list under particular circumstances. introduces a derogation to allow for the release of frozen funds or economic resources, in cases where a member state deprives a listed person of funds or economic resources belonging to, or owned by or controlled by, it, and for making funds and economic resources available to such person for compensation to be paid. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the sale or use of shares in, or assets of, an entity established in russia where the ownership or control by an eu legal person of that entity has been compulsorily transferred by the russian government. that derogation would enable, among others, the payment of agreed adequate compensation to eu legal persons. extends the deadline applicable to the existing derogation allowing the processing of payments by the jewish claims conference until 31 december 2024 through alfa-bank jsc and introduces a derogation to allow for certain payments as an indemnity or benefit for the materialisation of a risk involving a newly listed entity. introduces a temporary derogation from the asset freeze and the prohibition on making funds and economic resources available to allow the sale and transfer of proprietary rights directly or indirectly owned by certain listed persons (namely petr aven, mikhail fridman, gennady timchenko, german khan, alexey kuzmichev, igor kesaev, boris rotenberg, arkady rotenberg, as well as certain legal entities) in a legal person, entity or body established in the eu. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the termination of contracts concluded with a newly listed entity. extends to a newly listed alfastrakhovanie, an insurance company, the existing derogation currently applicable to certain listed banks under certain circumstances. makes technical amendments in the operative text, defines the scope of certain reporting obligations and introduces an obligation for national competent authorities of member states to designate in accordance with national legislation the national authorities competent to identify and trace, where appropriate, funds and economic resources belonging to, or owned, held or controlled by, listed natural or legal persons, entities or bodies, with a view to preventing or detecting instances of a breach or circumvention, or attempts at a breach or circumvention, of regulation 269. council regulation (eu) 2023/2878 (regulation 2878) 18 december 2023 regulation 833 on the day following that of its publication date adds 29 new entities to the list of legal persons, entities and bodies supporting russia’s military and industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemicals, lithium batteries, thermostats, dc motors and servomotors for unmanned aerial vehicles, machine tools and machinery parts. introduces a list of partner countries, being swtizerland and norway, which apply a set of restrictive measures on imports of iron and steel and a set of import control measures. it also extends certain wind-down periods for the import of specific steel products. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. prohibits the transit via the territory of russia of certain goods and technology which could contribute in particular to the enhancement of russian industrial capacities, exported from the eu. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. provides for an exemption for the entry of cars into the eu for specific circumstances. introduces a derogation enabling the granting of loans or credits to entities operating in the russian energy sector which are subject to the transaction ban provided for in regulation 833, under the conditions provided for therein. imposes a prohibition on the direct or indirect import, purchase or transfer of diamonds from russia. that prohibition applies to diamonds originating in russia, diamonds exported from russia, diamonds transiting russia and russian diamonds when processed in third countries other than russia. the prohibition applies to non-industrial natural and synthetic diamonds, as well as diamond jewellery, as of 1 january 2024, and includes a progressive phasing-in, from 1 march 2024 until 1 september 2024, of an indirect import ban on russian diamonds when processed in third countries other than russia, including jewellery incorporating diamonds originating in russia. prolongs by an additional year specific derogations from the prohibition on imports from russia of crude oil and petroleum products in order to ensure the security of supply of certain member states. introduces a requirement that itemised price information for ancillary costs, such as insurance and freight, be shared upon request throughout the supply chain of russian oil trade. competent authorities can request that information from any actor, regardless of their place in the supply chain, at any time, in order to verify compliance with the price cap mechanism. provides for a notification obligation for the sale of tankers to any third country and a derogation from the prohibition on the sale of tankers to russian persons and entities, or for use in russia. this obligation applies to the owner of a tanker who is a national of a member state, to a natural person residing in a member state, and to a legal person, entity or body which is established in the eu. the owner, or anyone acting on his or her behalf, should notify the competent authorities of any such sale concluded since 5 december 2022 and provide all the necessary details. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2024 to ensure japan’s energy security needs. includes a ban on russian nationals or natural persons residing in russia from owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing crypto-asset wallet, account or custody services to russian persons. extends the existing prohibition on the provision of services to also include the provision of software for the management of enterprises and software for industrial design and manufacture, subject to appropriate exemptions and derogations. imposes certain reporting requirements for the transfer of funds out of the eu made by entities established in the eu, including special purpose entities, whose proprietary rights are owned by entities established in russia, by russian nationals or by natural persons residing in russia. requires that exporters contractually prohibit re-exportation to russia and re-exportation for use in russia of certain specific sensitive goods and technology. council implementing regulation (eu) 2023/2875 18 december 2023 regulation 269 on publication date adds a further 61 individuals and 86 entities to the asset freeze list under regulation 269, most notably including alfastrakhovanie group, the insurance arm of alfa bank. council decision (cfsp) 2023/2871 18 december 2023 decision 145 on publication date equivalent to those listed under regulation 2873 above. council decision (cfsp) 2023/2874 18 december 2023 decision 512 on publication date equivalent to those listed under regulation 2878 above. council decision (cfsp) 2024/195 3 january 2024 decision 145 on publication date adds pjsc alrosa and its ceo, pavel alekseevich marinychev, to the asset freeze list under decision 145. council regulation (eu) 2024/745 (regulation 745) 23 february 2024 regulation 833 on the day following that of its publication date adds 27 russian and third country entities to the list of legal persons, entities and bodies associated to russia’s military-industrial complex set out in annex iv of regulation 833. expands the list of controlled items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding components for the development and production of unmanned aerial vehicles. imposes further restrictions on exports of goods which contribute in particular to the enhancement of russian industrial capabilities. adds the united kingdom to the list of partner countries for the iron and steel imports. these partner countries apply a set of restrictive measures on imports of iron and steel and a set of import control measures that are substantially equivalent to those regulation 833. council implementing regulation (eu) 2024/753 (regulation 753) 23 february 2024 regulation 269 on publication date adds a further 106 individuals and 88 entities to the asset freeze list under regulation 269. council decision (cfsp) 2024/746 23 february 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 745 above. council decision (cfsp) 2024/747 23 february 2024 decision 145 on publication date equivalent to those listed under regulation 753 above. council regulation (eu) 2024/1428 (regulation 1428) 17 may 2024 regulation 833 on the day following that of its publication date introduces measures to suspend broadcasting activities within the union or directed at the union by certain media outlets listed in the annex to regulation (eu) 2024/1428. council regulation (eu) 2024/1485 (regulation 1485) 27 may 2024 n/a. new measure on publication date provides for the freezing of funds and economic resources of, and the prohibition to make funds and economic resources available to, natural or legal persons, entities or bodies, certain designated natural or legal persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. these restrictions largely mirror those of regulation 269 in substance. provides for certain sectoral restrictions on exporting equipment, technology or software, which might be used for internal repression, as well as items intended primarily for use in the monitoring or interception of information security and telecommunication and the provision of related technical assistance, brokering services, financing or financial assistance. council decision (cfsp) 2024/1484 27 may 2024 n/a. new measure on publication date provides for a travel ban on certain designated natural persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. contains other measures equivalent to those listed under regulation 1485. council implementing regulation (eu) 2024/1488 (regulation 1488) 27 may 2024 regulation 1485 on publication date adds 19 individuals and 1 entity to the asset freeze list under regulation 1485. council implementing regulation (eu) 2024/1493 (regulation 1493) 27 may 2024 regulation 269 on publication date adds a further 2 individuals and 1 entity to the asset freeze list under regulation 269. council decision (cfsp) 2024/1508 27 may 2024 decision 145 on publication date equivalent to those listed under regulation 1493 above. council regulation (eu) 2024/1739 24 june 2024 regulation 269 on publication date introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. clarifies that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. introduces a provision to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them, provided that the member state national or company concerned does not have effective access to remedies under the relevant jurisdiction. introduces a new reporting obligation on member states to report penalties imposed for violations of the restrictive measures provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties. ensures that any document held by the council, the commission or the high representative of the union for foreign affairs and security policy for the purpose of ensuring the enforcement of the measures set out regulation 269, or of preventing the violation or circumvention thereof, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. that protection also applies to the joint proposals from the high representative of the union for foreign affairs and security policy and the commission for the amendment of regulation 269 and to any preparatory documents related to them. council regulation (eu) 2024/1745 24 june 2024 regulation 833 on the day following that of its publication date amends the prohibition to land in, take off from or overfly the territory of the eu so that it also applies to any aircraft which is used for a non-scheduled flight and with regard to which a russian natural or legal person, entity or body is in a position to effectively determine the place or time of its take-off or landing. also amends the same prohibition to introduce an exemption for certain aircraft when used for private, non-corporate flights carried out within eu territory and airspace for recreational or training purposes. introduces an obligation for operators to provide, for non-scheduled flights, upon request of the competent authorities of the member state of departure, destination or overflying, information needed for the purpose of verifying compliance with the flight ban, including information about ownership of the aircraft and, where reasonable grounds to suspect circumvention of the flight ban exist, about passengers. amends the prohibition on the transport of goods by road within the territory of the eu, including in transit. eu operators which are owned for 25 % or more by a russian natural or legal person should be prohibited from becoming a road transport undertaking or from transporting goods by road in the eu, including in transit. clarifies that rough diamonds imported from russia prior to 1 january 2024 and polished diamonds imported from russia or manufactured before 1 march 2024 or 1 september 2024, depending upon the weight of the diamond, are not covered by the diamond ban. also amends the ban on russian diamonds in order to enable the temporary import or export of jewellery for repairs, auctions and trade fairs and amends the scope of application and the date of entry into force of the requirement to provide traceability-based evidence. provides that the indirect import ban on russian diamonds processed in third countries other than russia, is temporarily not to apply to jewellery incorporating such diamond. prohibits reloading services in the territory of the eu for the purposes of transshipment operations where such services are used to transship russian lng, except in the case of such transshipments to member states. prohibits new investment and the provisions of goods, technology and services for the completion of lng projects. introduces import restrictions on russian lng through union lng terminals that are not connected to the interconnected natural gas system. introduces a sectoral ban prohibiting access to member states’ ports and locks as well as certain services related to maritime transport for vessels which contribute to russia’s ability to wage war against ukraine. clarifies the scope of the port access ban for russian-flagged vessels and adds a derogation. introduces a prohibition on purchasing, importing, transferring or exporting ukrainian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance, where there are reasonable grounds to suspect that the goods have been unlawfully removed from ukraine, along with a prohibition on related services. enables the possibility to subject companies which make use of russian law provisions, which force the satisfaction of claims against assets of eu companies in a foreign jurisdiction, claims which they would otherwise be prohibited from satisfying pursuant to regulation 833 or regulation 269, to a transaction ban. prohibits eu entities which operate outside of russia from directly connecting to the ‘system for transfer of financial messages’ (spfs) or equivalent specialised financial messaging services set up by the central bank of russia, and adds a transaction ban on eu operators with specifically listed entities using that system outside russia. eu entities however are not prohibited from dealing with russian entities which use the spfs, provided that those eu entities do not connect to the spfs themselves. establishes a transaction ban on eu operators with credit and financial institutions as well as crypto assets providers, established outside of the eu, when the council has determined that those entities facilitate transactions that support russia’s defence-industrial base through the export, supply, sale, transfer or transport towards russia of dual-use goods and technology, common high priority items or firearms and ammunition. broadens the existing prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to any legal person, entity or body established in russia or to any legal person, entity or body majority owned by them. creates an exemption to the prohibition to provide certain services to the government of russia or to legal persons, entities or bodies established in russia, for eu nationals who resided in russia before february 2022 and who are employed by subsidiaries of eu and partner countries’ entities. imposes restrictions on accepting applications for registrations in the eu of certain intellectual property rights by russian nationals, natural persons resident in russia and russian companies. in particular, and without prejudice to their procedural rules, intellectual property offices and other competent institutions should not allow the filing of such applications. introduces a prohibition on the acceptance, by political parties, foundations, alliances, non-governmental organisations, including think tanks, and media service providers in the eu, of financing, donations or any other economic benefits or support from russia, whether directly or indirectly. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. provides for member states to report about penalties imposed for violations of restrictive measures. ensures that the documents held by the council, the commission and the high representative of the union for foreign affairs and security policy concerning the enforcement of the restrictive measures set out in regulation 833, or concerning the prevention of the violation or circumvention of those measures, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. introduces provisions to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them. provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties, as appropriate, in accordance with national administrative law or with other relevant national law or rules requires eu operators to undertake their best efforts to ensure that legal persons, entities and bodies established outside the eu that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 833. requires eu operators to contractually prohibit their commercial counterparts in third countries from using, or allowing the use of, the intellectual property rights, trade secrets or material or information protected by intellectual property rights or protected as trade secret transferred to them in connection with common high priority items to be sold, supplied or exported to russia or for use in russia. requires eu operators that are selling, supplying, transferring or exporting common high priority items to third countries, other than the partner countries listed in annex viii regulation 833, to implement due diligence mechanisms capable of identifying and assessing risks of exportation to russia and mitigating such risks. eu operators must also ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. adds 61 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512. also includes on that list certain entities in third countries other than russia that are involved in the circumvention of trade restrictions and that engage in the procurement of sensitive items used for. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. adds five common high priority items to the restrictions on exports of goods. introduces further restrictions on the import of helium. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2025 to ensure japan’s energy security needs. makes certain technical amendments in the operative text and annexes, deleting references to transitional periods which have expired introduces a horizontal exemption from the prohibitions in this regulation for the paks ii nuclear project, with a notification obligation for such activities. expands the lists of partner countries that apply a set of export control measures or a set of restrictive measures on imports of iron and steel and a set of import control measures which are substantially equivalent to those set out in regulation 833. council implementing regulation (eu) 2024/1746 24 june 2024 regulation 269 on publication date adds a further 69 persons and 47 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/1776 24 june 2024 regulation 833/regulation 1428 on the day following that of its publication date provides that the measures in relation to broadcasting in regulation 833 apply from 25 june 2024 in respect of all entities referred to in the annex to regulation 1428 and can be found here. council decision (cfsp) 2024/1738 24 june 2024 decision 145 on publication date equivalent to those listed under regulations 1739 and 1746 above. council decision (cfsp) 2024/1744 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1745 above. council decision (cfsp) 2024/1770 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1776 above. council regulation (eu) 2024/3189 (regulation 3189) 16 december 2024 regulation 269 on publication date introduces a derogation allowing the release of cash balances that are held by central securities depositories and attributable to the nsd. introduces a derogation allowing the release of frozen funds to arkady rotenberg, boris rotenberg and gennady timchenko. council regulation (eu) 2024/3192 (regulation 3192) 16 december 2024 regulation 833 on the day following that of its publication date adds 32 new entities to the list of persons, entities and bodies supporting russia’s military-industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles or missiles. adds further vessels to the list of vessels on which a ban from member states’ ports and locks, as well as a ban on the provision of a broad range of services related to maritime transport, are imposed. adds that certain actions by a central securities depository carried out in good faith do not give rise to liability of any kind on the part of that depository, or of its directors or employees, unless it is proved that the action was a result of negligence. introduces a prohibition on the recognition or enforcement in the union of injunctions, orders, judgments or other court decisions pursuant to or in relation to article 248 of the arbitration procedure code of the russian federation or equivalent russian legislation. makes certain technical amendments to regulation 833, including to extend the deadlines applicable to certain derogations needed for divestments from russia or for member states’ security of supply of certain petroleum products. council implementing regulation (eu) 2024/3177 (regulation 3177) 16 december 2024 article 8a(1) of regulation (ec) no 765/2006 on publication date adds 26 individuals and 2 entities in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 in view of the situations in belarus. council implementing regulation (eu) 2024/3183 (regulation 3183) 16 december 2024 regulation 269 on publication date adds a further 54 individuals and 30 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/3188 (regulation 3188) 16 december 2024 regulation 2642 on publication date adds 16 individuals and 3 entities to the list of natural and legal persons, entities and bodies set out in annex i to regulation (eu) 2024/2642. council decision (cfsp) 2024/3174 16 december 2024 decision 2643 on publication date equivalent to those listed under regulation 3188 above. council decision (cfsp) 2024/3182 16 december 2024 decision 145 on publication date equivalent to those listed under regulation 3189 and regulation 3183 above. council decision (cfsp) 2024/3187 16 december 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 3192 above. council implementing decision (cfsp) 2024/3175 16 december 2024 decision 642 on publication date equivalent to those listed under regulation 3177 above. council regulation (eu) 2025/390 (regulation 390) 24 february 2025 regulation 269 on publication date introduces two further criteria for the listing of natural or legal persons, entities or bodies in relation vessels involved in certain activities or who form part of, supporting, materially or financially, or benefitting from russia’s military and industrial complex. extends an existing divestment derogation to three additional listed individuals. extends the scope of two existing derogations regarding certain transfers of funds and payments. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries as referred to in annex viii of regulation 833 that apply similar restrictive measures. enables the commission to process personal data in relation to the due diligence required from union operators in respect of potential business partners. allows union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages. introduces a best-efforts obligation to union operators undertake such best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 269. further expands on the scope of the best efforts obligation. makes a number of technical amendments in order to ensure the clarity of certain provisions of regulation 269 including those concerning documents held by the union institutions and the processing of personal data. council regulation (eu) 2025/392 (regulation 392) 24 february 2025 regulation 765 on publication date strengthens the prohibition on the export of dual-use goods and technology and of goods and technology which might contribute to the technological enhancement of belarus’s defence and security sector. expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including chemical precursors to riot control agents, software related to computer numerical control machines, chromium ores and compounds and controllers used to guide unmanned aerial vehicles. imposes further restrictions on exports of goods which could contribute to the enhancement of belarusian industrial capacities, such as chemical elements, pyrotechnic articles and combustible materials. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus of machinery and of goods which could contribute, in particular, to the enhancement of belarusian industrial capacities. establishes derogations for the provision of certain goods and machinery necessary for civilian non-publicly available electronic communications networks. introduces further restrictions on the import of primary aluminium, which allows belarus to diversify its sources of revenue, thereby enabling its involvement in the russian aggression against ukraine. imposes a restriction on the sale, supply, transfer, export or provision of software related to oil and gas exploration in order to further restrict the oil and gas exploration and production capacities of belarus and minimise the risk of circumvention of restrictive measures via the territory of belarus. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, licence or transfer in any other way of intellectual property rights or trade secrets related to a software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of belarus located in a member state. expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by belarusian nationals or natural persons residing in belarus. subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities. prohibits the provision of crypto-asset wallet, account or custody services to belarusian persons and residents and includes a prohibition on belarusian nationals or natural persons residing in belarus owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing such services. introduces an exemption from the prohibition on the sale, supply, transfer or export of banknotes denominated in any official currency of a member state to or for use in belarus, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in belarus, under certain conditions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a belarusian natural or legal person. provides for the freezing of funds and economic resources of, and prohibits making funds or economic resources available to, designated persons, entities and bodies. introduces an additional designation criterion which applies to those forming part of, supporting, materially or financially, or benefiting from the military and industrial complex of belarus. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. union operators can seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as result of claims lodged by the entities or persons. union operators can seek damages from certain persons, entities or bodies that own or control the entities or bodies. introduces provisions in relation to the exchange of information and reporting requirements. union operators that are selling, supplying, transferring or exporting such goods to third countries are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to belarus and mitigating such risks. union operators are required to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions. includes technical amendments. council regulation (eu) 2025/395 (regulation 395) 24 february 2025 regulation 833 on publication date extends the suspension of the broadcasting licences in the union of russian media outlets under the permanent control of the russian leadership, and the prohibition on broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of certain media outlets in the union, or directed at the union. adds 53 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512 on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. also includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles (uavs) or missiles. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemical precursors to riot control agents, software related to computer numerical control (cnc) machines, chromium compounds and controllers used to guide uavs. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as chemicals, some plastics and rubber. further extends the list of goods and technology subject to the prohibition on transit via the territory of russia. empowers competent authorities to authorise the sale and export, and related technical assistance, of information security systems, equipment and components, for non-military use and for a non-military end user, after having determined that such goods or technology or the related technical assistance are intended for a civilian non-publicly available electronic communications network, and provided that that network is not the property of an entity that is publicly controlled or with over 50 % public ownership, such authorisations can be granted in particular to providers of specialised financial messaging services. introduces further restrictions on the import of primary aluminium, which generates significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. introduces a new targeted derogation from the prohibition on importing certain items that are strictly necessary for the operation of the druzhba pipeline. limits the application of an exemption to the flight ban on manned aircraft by introducing the need for an authorisation by the competent authorities. extends the flight ban to listed air carriers operating domestic flights within russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to a russian air carrier or for flights within russia, as well as to any entity owned or controlled by such air carrier. imposes further restriction on exports of goods and technology, in particular software related to oil and gas exploration, in order to further restrict russia’s oil and gas exploration and production capacities. provides for a derogation for the sale, supply, transfer or export from slovakia to hungary or from hungary to slovakia of certain petroleum products as listed in annex xxxi to regulation 833 which are obtained from crude oil imported by pipeline. introduces a prohibition on the provision of temporary storage for russian crude oil and petroleum products within the union, irrespective of the purchase price of the oil and of the final destination of those products. clarifies that reloading services for the purposes of transshipment operations of russian lng are allowed if necessary for its transport between ports of the same member state, including from the mainland of a member state to its outermost regions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a russian natural or legal person. entities established in the union before 8 april 2022 and already operating as road transport undertakings should be prohibited from making any changes to their capital structure that would increase the percentage share owned by a russian natural or legal person, entity or body, unless that percentage share remains below 25 % following such a change. extends prohibitions to the completion of crude oil projects in russia, such as the vostok oil project. introduces a derogation from the prohibition that can be granted by a member state that is not connected to the interconnected natural gas system when the lng is purchased, imported or transferred from a terminal located in another member state that is connected to the interconnected natural gas system in order to ensure its energy supply. requires imports of rough diamonds to be accompanied by a certificate in which the country of mining origin or the countries of mining origin are clearly stated. postpones the date of entry into force of the requirement to provide traceability-based evidence for imports of polished diamonds. furthermore, addressing governance issues associated with the traceability system will require ongoing cooperation with the g7 and third countries. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, license or transfer in any other way of intellectual property rights or trade secrets related to that software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of russia located in a member state. introduces a prohibition on any transaction with ports and locks and airports in russia that are used for the transfer of uavs or missiles or related technology or components thereof to russia, or for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices or of other restrictive measures. imposes restrictions on legal persons, entities or bodies established outside russia that use the system for transfer of financial messages of the central bank of russia. introduces a derogation allowing the execution of transactions with a specific entity included in annex xliv to regulation 833 that are necessary for the repayment of guarantees granted by a member state, divestment from russia or the wind-down of business activities in russia, or execution of certain contracts. further extends the transaction ban on credit institutions, financial institutions and entities providing crypto assets services that support transactions in relation to any listed vessel, thus frustrating the prohibition set out in article 3s of regulation 833. imposes restrictions on legal persons, entities and bodies, as listed in annex xlv to regulation 833, established outside of the union that are credit or financial institutions or entities providing crypto assets services involved in transactions that facilitate, directly or indirectly, the circumvention of the prohibitions set out in article 3n of regulation 833. extends the restrictive measures in relation to the provision of specialised financial messaging services to certain russian credit institutions or entities subscribing to financial messaging services or russian subsidiaries of third-country credit institutions, which are relevant for the russian financial and banking system, and are either large and important regional banks, which consequently facilitate regional and federal finances and business, or banks which facilitate significant cross-border payments or banks which are already the subject of restrictive measures imposed by the union or by partner countries. adds a derogation for the acceptance of deposits otherwise restricted for operations necessary for the restructuring or liquidation of a legal person associated with an entity listed in annex i to regulation 269. introduces an exemption from the prohibition on the sale, supply, transfer or export to russia of banknotes denominated in any official currency of a member state, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in russia under certain conditions. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries that apply similar restrictive measures. extends the provision in regulation 833 on recognition of a claim for damages suffered by union operators as a consequence of a decision pursuant to specific russian legislation to those persons who are responsible for issuing that decision. adds to this provision a reference to russian legislation that allows for the corporate rights of foreign holding structures in economically significant russian organisations to be restricted, as well as for the direct foreign ownership in such organisations to be acquired by russian beneficiaries and for them to receive dividends directly. entitles union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as a result of claims lodged by certain entities or person. enables the commission to assist union operators facilitate their due diligence in respect of potential business partners and enables the commission to process personal data for this purpose. union operators that are selling, supplying, transferring or exporting such goods to third countries, other than the partner countries listed in annex viii to regulation 833, are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to russia and mitigating such risks. requires union operators to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies, and replaces exemptions from certain prohibitions by derogations. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions of regulation 833. adds specific references to the applicable russian legislation in order to update some provisions concerning the protection of union operators. includes technical amendments to improve the accuracy of certain provisions of regulation 833 concerning personal data and documents held by the institutions of the union and to improve the linguistic clarity of certain other provisions. council regulation (eu) 2025/398 (regulation 398) 24 february 2025 regulation 263 on publication date prohibits, subject to certain exceptions, the supply to the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia of banknotes denominated in any official currency of a member state. introduces restrictions on the export to the non-government controlled areas of certain goods and technology that are also restricted by regulation 833. prohibits the provision to the non-government controlled areas of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. it also prohibits the provision to the non-government controlled areas of certain software for the management of enterprises and software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and amends the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. requires that union operators undertake their best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation (eu) 2022/263. member states report about penalties imposed for violations of the restrictive measures. clarifies that the protection against liability that is granted to union operators if they did not know, and had no reasonable cause to suspect, that their actions would infringe union restrictive measures cannot be invoked where union operators have failed to carry out appropriate due diligence. council regulation (eu) 2025/401 (regulation 401) 24 february 2025 regulation 692 on publication date prohibits, subject to certain exceptions, the supply to crimea and sevastopol of banknotes denominated in any official currency of a member state. restricts the export to crimea and sevastopol of certain goods and technology that are also restricted by regulation 833. prohibits the provision to crimea and sevastopol of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. prohibits the provision to crimea and sevastopol of certain software for the management of enterprises and of software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and to amend the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. introduces a best-efforts obligation to union operators. introduces reporting obligations for member states in relation to penalties imposed for violations of restrictive measures. council implementing regulation (eu) 2025/389 (regulation 389) 24 february 2025 regulation 269 on publication date adds a further 48 individuals and 35 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/388 24 february 2025 decision 145 on publication date equivalent to those listed under regulation 389 and 390 above. council decision (cfsp) 2025/391 24 february 2025 decision 642 on publication date equivalent to those listed under regulation 392 above. council decision (cfsp) 2025/394 24 february 2025 decision 512 on publication date equivalent to those listed under regulation 395 above. council decision (cfsp) 2025/396 24 february 2025 decision 266 on publication date equivalent to those listed under regulation 398 above. council decision (cfsp) 2025/397 24 february 2025 decision 386 on publication date equivalent to those listed under regulation 401 above. council implementing regulation (eu) 2025/527 (regulation 527) 14 march 2025 regulation 269 on the day following that of its publication date adds further 126 individuals and 36 entities to the asset freeze list under regulation 269. deletes 3 deceased persons, 4 other persons and 3 duplicate entries from the asset freeze list under regulation 269. council decision (cfsp) 2025/528 14 march 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 527 above. council implementing regulation (eu) 2025/631 (regulation 631) 27 march 2025 article 8a(1) of regulation (ec) no 765/2006 on publication date adds further 25 individuals and 7 legal persons in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 in view of the situations in belarus. council implementing decision (cfsp) 2025/632 27 march 2025 decision 642 on publication date equivalent to those listed under regulation 631 above. council implementing regulation (eu) 2025/701 (regulation 701) 8 april 2025 regulation 833 on the day following that of its publication date provides that the restrictive measures to suspend the broadcasting activities in the eu, or directed at the eu, of certain media outlets listed in annex v to regulation 395 should apply as of 9 april 2025. council decision (cfsp) 2025/700 8 april 2025 article 4g of decision 2014/512/cfsp on the day following that of its publication date equivalent to those listed under regulation 701 above. council regulation (eu) 2025/903 (regulation 903) 14 may 2025 regulation 269 on the day following that of its publication date introduces a new listing criterion to include natural or legal persons, entities or bodies that have participated in or enabled transfers of ownership, control or economic benefit of the business interests of leading businesspersons operating in russia. sets outs the burden of proof required for the council to maintain the inclusion of leading businesspersons on the list of natural or legal persons, entities or bodies subject to restrictive measures. council decision (cfsp) 2025/904 14 may 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 903 above. council regulation (eu) 2025/932 (regulation 932) 20 may 2025 regulation 833 on the day following that of its publication date adds 31 new entities to the list of natural or legal persons, entities or bodies set out in annex iv to regulation 833, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. also includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on unmanned aerial vehicles or computer numerical control machine tools. expands the list in annex vii of regulation 833 of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemical precursors to energetic materials and spare parts for machine tools. extends the duration of an exemption from the oil price cap which allows, in view of energy security concerns, the transport, by vessel, of crude oil originating in the sakhalin-2 project in russia to japan. adds 189 vessels to the list of vessels set out in annex xlii to regulation 833, which are banned from accessing member states’ ports and locks, as well as from receiving a broad range of services related to maritime transport. council regulation (eu) 2025/964 (regulation 964) 20 may 2025 regulation 2642 on the day following that of its publication date amends the criteria guiding individual designations in the listings freezing assets and the prohibition from making funds and economic resources available to listed persons bodies and entities. introduces additional measures prohibiting transactions with tangible assets supporting russia-driven destabilising activities, such as vessels, aircraft, real estate, ports, airports, physical elements of digital and communication networks. prohibits broadcasting in the eu by specifically-designated media outlets. suspends the broadcasting licences in the eu of the specifically-designated media outlets, and prohibits the broadcasting of their content in the eu directing it to the eu. council implementing regulation (eu) 2025/933 (regulation 933) 20 may 2025 regulation 269 on publication date adds a further 17 individuals and 58 entities to the asset freeze list under regulation 269 council implementing regulation (eu) 2025/958 (regulation 958) 20 may 2025 regulation 1485 on publication date adds 28 individuals to the asset freeze list under regulation 1485. council implementing regulation (eu) 2025/965 (regulation 965) 20 may 2025 regulation 2642 on publication date adds 21 individuals and 6 entities to the asset freeze list under regulation 2642. council implementing regulation (eu) 2025/959 (regulation 959) 20 may 2025 regulation 1542 on publication date adds 3 entities to the asset freeze list under regulation 1542. council decision (cfsp) 2025/931 20 may 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 932 above. council decision (cfsp) 2025/936 20 may 2025 decision 145 on publication date equivalent to those listed under regulation 933 above. council decision (cfsp) 2025/957 20 may 2025 decision 1484 on publication date equivalent to those listed under regulation 958 above. council decision (cfsp) 2025/963 20 may 2025 decision 2643 on the day following that of its publication date equivalent to those listed under regulation 964 above. council decision (cfsp) 2025/966 20 may 2025 decision 2643 on publication date equivalent to those listed under regulation 965 above. council decision (cfsp) 2025/960 20 may 2025 decision 1544 on publication date equivalent to those listed under regulation 959 above. council implementing regulation (eu) 2025/1438 (regulation 1438) 15 july 2025 regulation 1485 on publication date adds 5 individuals to the list of natural and legal persons, entities and bodies set out in annex iv to regulation 1485. council implementing regulation (eu) 2025/1444 (regulation 1444) 15 july 2025 regulation 2642 on publication date adds 9 individuals and 6 entities to the list of natural and legal persons, entities and bodies set out in annex i to regulation 2642. council decision (cfsp) 2025/1425 15 july 2025 decision 1484 on publication date equivalent to those listed under regulation 1438 above. council decision (cfsp) 2025/1443 15 july 2025 decision 2643 on publication date equivalent to those listed under regulation 1444 above. council regulation (eu) 2025/1472 (regulation 1472) 18 july 2025 regulation 765 on the day following that of its publication date prohibits the sale, supply, transfer or export to belarus of arms and related materiel of all types. further prohibits the procurement from belarus of arms and related materiel of all types. provides member states with an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in annex va to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in belarus or that the end-use of the items may be for belarusian entities. expands into a transaction ban the existing prohibition to provide specialised financial messaging services to certain belarusian credit institutions and their belarusian subsidiaries, which are relevant for the belarusian financial system, and which are already the subject of restrictive measures imposed by the eu. adds exemptions related to the functioning of diplomatic and consular representations of the eu and of the member states or of partner countries in belarus, and, to transactions made by nationals of a member state who are residents in belarus. adds a derogation for transactions which are strictly necessary for the divestment from belarus or for the wind-down of business activities in belarus. prohibits member states from recognising or enforcing any injunction, order, relief, judgment of a court other than a court of a member state or other court, arbitral or administrative decision issued in proceedings other than those in the member states pursuant to or derived from investor-state dispute settlement proceedings in connection with measures imposed under regulation 765. enables competent authorities or the eu, where applicable, to recover in proceedings before a court of a member state any damages caused, including legal costs and costs incurred in the event of non-compliance with the arbitral award by the other party, from those persons, entities or bodies and from persons, entities or bodies that own or control those persons, entities or bodies, as a consequence of an investor-state dispute settlement in connection with measures imposed under regulation 765, provided that all available legal remedies in the relevant jurisdiction have been exercised. enables member states to invoke any objection available to them in domestic or foreign proceedings for the recognition and enforcement of such awards when member states are confronted with arbitral awards rendered against them in investor-state dispute settlement proceedings in connection with measures imposed under regulation 765. extends the application of the forum necessitatis provision to article 8l. adds a new entity to the list of natural and legal persons, entities and bodies set out in annex ii to decision 2012/642/cfsp. expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including chemical precursors to energetic materials, spare parts for machine tools, additional computer numerical control (cnc) machines and constituent chemicals for propellants. expands the list of goods subject to export restrictions which might contribute to the enhancement of belarusian industrial capacities, such as machinery, chemicals, some metals and plastics. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus. council regulation (eu) 2025/1494 (regulation 1494) 18 july 2025 regulation 833 on the day following that of its publication date prohibits the sale, supply, transfer or export to russia of arms and related materiel of all types, and the procurement from russia of arms and related materiel of all types. adds 26 to the list of persons, entities and bodies supporting russia’s military and industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on unmanned aerial vehicles. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector, by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including additional computer numerical control machines and constituent chemicals for propellants. introduces an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in annex vii to regulation 833 to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in russia or that the end-use of the items may be for russian entities. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as machinery, chemicals, some metals and plastics. further extends the list of goods and technology subject to the prohibition on transit via the territory of russia. ends the temporary derogation granted to czechia for the supply of crude oil by pipeline from russia. imposes a prohibition on the purchase, import, or transfer, directly or indirectly into the eu, of petroleum products obtained in a third country from russian crude oil, as well as on the provision of related technical or financial assistance. introduces a list of partner countries which have a set of restrictive measures that are substantially equivalent to those imposed by the eu on imports of russian oil and petroleum products. introduces a derogation from the prohibition that can be granted by a member state that is not directly connected to the interconnected natural gas system of any other member state and that receives the first commercial supply of its first long-term natural gas supply contract after 20 july 2025 in order to ensure its energy supply. introduces an exemption from the transaction ban, provided that a competent authority has imposed a public trusteeship or similar public firewall measure or the competent authority has authorised a similar firewall measure. amends the conditions for imposing a transaction ban on persons, entities or bodies established outside russia that use the system for transfer of financial messages (spfs) of the central bank of russia or equivalent specialised financial messaging services set up by the central bank of russia. provides for an exemption from the transaction ban on certain ports for kazakh coal based on the eu’s commitment to prevent negative impacts on energy security of third countries around the globe. provides for an exemption from the transaction ban on certain airports with regard to civil nuclear capabilities and facilities. introduces restrictive measures banning any transaction that is directly or indirectly connected to the natural gas pipelines nord stream and nord stream 2 and that concerns the completion, operation, maintenance or use of the pipelines or parts of the pipelines. expands the transaction ban on third-country credit and financial institutions and crypto assets services providers to include entities that are significantly frustrating the purpose of the prohibitions in regulations 833 and 269 adds 2 entities to the list of third country financial institutions subject to that ban. expands into a transaction ban the existing prohibition on the provision of specialised financial messaging services to certain russian credit or financial institutions or other entities subscribing to financial messaging services or to russian subsidiaries of third-country credit or financial institutions. adds 22 credit or financial institutions and other entities to the list of legal persons, entities or bodies subject to that transaction ban. adds exemptions related to the functioning of diplomatic and consular representations of the eu and of the member states or of partner countries in russia and to transactions made by nationals of a member state who are residents in russia. adds a derogation for transactions which are strictly necessary for divestment from russia or for the wind-down of business activities in russia. provides for a dynamic automatic procedure to modify the price cap for russian crude oil depending on the average market price of russian crude oil. introduces a transaction ban targeting the rdif, its subsidiaries, its significant investments and anyone providing those entities with investment services or other financial services. adds 4 entities to the list of legal persons, entities and bodies, in which rdif has made significant investments, that are subject to the transaction ban. adds 105 vessels to the list of vessels set out in annex xvi to decision 512 which are banned from member states’ ports and locks, as well as from receiving a broad range of services related to maritime transport. imposes a prohibition on the provision of software with certain uses in the banking and financial sector. prohibits member states from recognising or enforcing any injunction, order, relief, judgment of a court other than a court of a member state or other court, arbitral or administrative decision issued in proceedings other than those in the member states pursuant to or derived from investor-state dispute settlement proceedings in connection with measures imposed under regulations 833 or 269. enables enable competent authorities or the eu, where applicable, to recover in proceedings before a court of a member state any damages caused, including legal costs and costs incurred in the event of non-compliance with the arbitral award by the other party, from those persons, entities or bodies and from persons, entities or bodies that own or control those persons, entities or bodies, as a consequence of an investor-state dispute settlement in connection with measures imposed under regulations 833 or 269, provided that all available legal remedies in the relevant jurisdiction have been exercised. enables member states to invoke any objection available to them in domestic or foreign proceedings for the recognition and enforcement of such awards when they are confronted with arbitral awards rendered against them in investor-state dispute settlement proceedings in connection with measures imposed under regulation 269 or 833. extends the application of the forum necessitatis provision to article 11e. council implementing regulation (eu) 2025/1469 (regulation 1469) 18 july 2025 article 8a(1) of regulation 765 on publication date adds 8 entities to the asset freeze list under regulation 765. council implementing regulation (eu) 2025/1476 (regulation 1476) 18 july 2025 regulation 269 on publication date adds 14 individuals and 41 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/1471 18 july 2025 decision 642 on the day following that of its publication date equivalent to those listed under regulation 1472 above. council decision (cfsp) 2025/1478 18 july 2025 decision 145 on publication date equivalent to those listed under regulation 1476 above. council decision (cfsp) 2025/1495 18 july 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1494 above. council implementing decision (cfsp) 2025/1461 18 july 2025 decision 642 on publication date equivalent to those listed under regulation 1469 above. council implementing regulation (eu) 2025/1894 (regulation 1894) 12 september 2025 regulation 269 on the day following that of its publication date adds 142 individuals and 134 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/1895 12 september 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 1894 above. council regulation (eu) 2025/2033 (regulation 2033) 23 october 2025 regulation 833 on the day following that of its publication date adds 45 entities to the list of legal persons, entities or bodies on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. this list includes certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on computer numerical controlled machine tools, on microelectronics, unmanned aerial vehicles, and other dual-use and advanced technology items. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides and alloys used in the manufacturing of military systems. introduces a new targeted derogation from the prohibition on purchasing, importing or transferring certain items -which generate significant revenues for russia and which are necessary for the operation, maintenance or repair of ultra-violet lamps used for the disinfection of drinking water. amends the derogation from the prohibition on purchasing, importing or transferring certain items which generate significant revenues for russia, and which are necessary for the operation, maintenance or repair of budapest metro line 3 cars. extends the prohibition to purchase, import or transfer certain items which generate significant revenues for russia to all acyclic hydrocarbons. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as salts and ores, articles of rubber, tubes, tyres, millstones and construction materials. extends the list of partner countries for importation of petroleum products. imposes a prohibition on the purchase, import, or transfer, directly or indirectly into the eu of liquified natural gas originating or exported from russia, as well as on the provision of related technical or financial assistance. introduces additional designations of vessels, amends one of the designation criteria and amends related provisions on prohibited services for designated vessels. removes certain energy-related exemptions from the transaction ban for two specific state-owned enterprises. expands the transaction ban that applies to legal persons, entities or bodies that are connecting to the system for transfer of financial messages of the central bank of the russian federation or equivalent specialised financial messaging services set up by the central bank of russia, to other payment services, such as the russian national payment card system or the fast payments system set up by the central bank of russia or by other russian entities. adds exemptions for transactions that are necessary for the functioning of diplomatic and consular representations of the eu and of the member states in third countries and for transactions made by nationals of a member state who are residents of a third country, for transactions that are necessary for existing contracts and the reception of payments, and for member states’ ethnic minorities in russia. expands the transaction ban on third-country credit and financial institutions and crypto-asset service providers to also include entities that provide payment services, and in particular entities that provide crypto-asset and payment services to listed entities. expands the transaction ban to cover equivalent entities if certain criteria are met. adds 8 new entities to the list in annex xlv to regulation 833. adds exemptions for transactions that are necessary for existing contracts and the reception of payments. extends the transaction ban to any ports and locks in third countries other than russia that are used for the transfer of unmanned arial vehicles or missiles or related technology or components thereof to russia, or for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices, or for the circumvention of other restrictive measures. prohibits any new participation in, the creation of joint ventures with, and the provision of financing to, any enterprise established in or operating through certain special economic, innovation or preferential zones, as well as prohibiting entering into new contracts with such enterprises prohibits the maintaining of any participation in, or of joint ventures or contracts with, any enterprise established in or operating through certain special economic, innovation or preferential zones. adds appropriate exemptions and derogations to prevent undesirable effects of those prohibitions. imposes restrictions on the provision of crypto-asset services, on the provision of certain payment services and on the issuing of electronic money to russia nationals, natural persons residing in russia, and legal persons, entities or bodies established in russia, in view of the importance of those services to the development of russia’s financial technology and e-commerce sectors and the potential use of crypto-asset services to circumvent restrictive measures. prohibits transactions involving certain crypto-assets, while also allowing for a limited period of time to enable the orderly termination of existing contracts. adds five credit or financial institutions to the list of legal persons, entities or bodies subject to a transaction ban. adds exemptions necessary for humanitarian purposes, for the export, sale, supply, transfer or transport of pharmaceutical, medical or agricultural and food products, to ensure access to judicial, administrative or arbitral proceedings in a member state, as well as for the recognition or enforcement of a judgment or an arbitration award rendered in a member state, for the reception of payments due by the legal persons, entities or bodies controlled by the russian government pursuant to contracts performed before 15 may 2022, and for the implementation of certain authorisations granted pursuant to regulation 269 and for member states’ ethnic minorities in russia. imposes further restrictions on the provision, to the government of russia or to legal persons, entities or bodies established in russia, of services that contribute to enhancing russia’s technological capabilities, namely the provision of certain commercial space-based services, certain artificial intelligence services, and high-performance computing and quantum computing services. expands the scope of current restrictions to cover not only technical testing and analysis, but also other services which form group 867 of the central products classification. restricts the provision of services directly related to tourism activities in russia. introduces a requirement for prior authorisation by the competent authority for any services provided to the government of russia which are not already subject to the restrictive measures set out in regulation 833. prohibits providing reinsurance for russian used aircraft or vessels during a period of five years following the sale or lease arrangement of those aircraft or vessels made after the entry into force of this regulation. establishes a prior notification mechanism for russian diplomats and consular officers, as well as for members of the administrative and technical staff or of the service staff of diplomatic missions or consular posts of russia, and for their family members within the schengen area and when traveling to a member state other than that of their accreditation. provides that member states willing to do so, may impose an authorisation requirement for travel to their territories of such individuals, based on visas or residence permits issued by another state. makes certain technical amendments including extending the deadlines applicable to certain derogations needed for divestments from russia. council regulation (eu) 2025/2037 (regulation 2037) 23 october 2025 regulation 269 on the day of its publication introduces an additional criterion for the listing of natural or legal persons, entities or bodies responsible for, supporting or implementing actions or policies contributing to the deportation, forced transfer, forced assimilation, including indoctrination, or militarised education of ukrainian minors. extends to two listed insurance companies the existing derogation related to payments constituting an indemnity or benefit provided further to the materialisation of a risk. includes definitions of ‘owning’ and ‘controlling’ a legal person, entity or body. clarifies the provision on the freezing of funds and economic resources of listed persons and the prohibition on making funds and economic resources available to such persons. council regulation (eu) 2025/2041 (regulation 2041) 23 october 2025 regulation (ec) 765 on the day following that of its publication date expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by adding items which include electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides and alloys used in the manufacturing of military systems. expands the list of goods subject to export restrictions which might contribute to the enhancement of belarusian industrial capacities, such as salts and ores, articles of rubber, tubes, tyres, millstones and construction materials. imposes further restrictions on the provision, to the republic of belarus, its government, its public bodies, corporations or agencies or to any natural or legal person, entity or body acting on their behalf or at their direction, of software with certain uses in the banking and financial sector and services that contribute to enhancing belarus’ technological capacities, namely the provision of certain commercial space-based services, certain artificial intelligence services, and high-performance computing and quantum computing services. expands the scope of current restrictions to cover not only technical testing and analysis, but also other services, which notably include, the following engineering related scientific and technical consulting services: geological, geophysical and other scientific prospecting, subsurface surveying, surface surveying and map-making services. introduces requirement for prior authorisation by the competent authority for any services provided to the republic of belarus, its government, its public bodies, corporations or agencies which are not already subject to the restrictive measures set out in 765. imposes restrictions on the provision of crypto-asset services, on the provision of certain payment services and on the issuing of electronic money to belarusian nationals, natural persons residing in belarus, and legal persons, entities or bodies established in belarus, in view of the importance of those services to the development of belarus’s financial technology and e-commerce sectors and the potential use of crypto-asset services to circumvent restrictive measures. adds exemptions necessary for humanitarian purposes, for the export, sale, supply, transfer or transport of pharmaceutical, medical or agricultural and food products, to ensure access to judicial, administrative or arbitral proceedings in a member state, as well as for the recognition or enforcement of a judgment or an arbitration award rendered in a member state. extends the prohibition to purchase, import or transfer certain items which allow belarus to diversify its sources of revenue to all acyclic hydrocarbons. makes certain technical amendments in the operative text and annexes to improve the accuracy and clarity of certain provisions of regulation 765 council implementing regulation (eu) 2025/2035 23 october 2025 regulation 269 on the day of its publication adds 22 individuals and 42 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2025/2039 (regulation 239) 23 october 2025 article 8a(1) of regulation (ec) 765/2006 on the day of its publication adds 2 individuals and 3 entities to the asset freeze list under regulation 765. council decision (cfsp) 2025/2032 23 october 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 2033 above. council decision (cfsp) 2025/2036 23 october 2025 decision 145 on the day of its publication equivalent to those listed under regulation 2037 above. council decision (cfsp) 2025/2040 23 october 2025 decision 642 on the day following that of its publication date equivalent to those listed under regulation 2041 above. council implementing decision (cfsp) 23 october 2025 decision 642 on the day of its publication equivalent to those listed under regulation 2039 above. council implementing regulation (eu) 2025/2356 (regulation 2356) 20 november 2025 regulation 1485 on the day of its publication adds 10 individuals the list of natural and legal persons, entities and bodies set out in annex iv to regulation 1485. council decision (cfsp) 2025/2357 20 november 2025 decision 1484 on the day of its publication equivalent to those listed under regulation 2356 above. council implementing regulation (eu) 2025/2568 (regulation 2568) 15 december 2025 regulation 2642 on the day of its publication adds 12 individuals and 3 entities to the asset freeze list under regulation (eu) 2024/2642. council implementing regulation (eu) 2025/2588 (regulation 2588) 15 december 2025 regulation 269 on the day of its publication adds 5 individuals and 4 entities to the asset freeze list regulation 269. council decision (cfsp) 2025/2572 15 december 2025 decision 2643 on the day of its publication equivalent to those listed under regulation 2568 above. council decision (cfsp) 2025/2594 15 december 2025 decision 145 on the day of its publication equivalent to those listed under regulation 2588 above. council regulation (cfsp) 2025/2601 (regulation 2601) 15 december 2025 regulation 765 on the day following that of its publication date introduces an additional criterion for the listing of natural or legal persons, entities or bodies responsible for, implementing, supporting, benefitting from, involved in or facilitating actions or policies attributable to the republic of belarus which undermine or threaten democracy, the rule of law, stability or security in the union or in one or several of its member states, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of one or several of its member states, or of a third country, including in cases where it results in the disruption of the functioning of critical infrastructure, where it is reasonable to believe the natural or legal persons, entities or bodies were at least aware of the potential effects. council decision (cfsp) 2025/2585 15 december 2025 decision 642 on the day following that of its publication date equivalent to those listed under regulation 2601 above. council regulation (eu) 2025/2618 (regulation 2618) 18 december 2025 regulation 833 on the day following that of its publication date adds 41 vessels to the list of vessels set out in annex xvi to decision 512, which are banned from member states’ ports and locks as well as from receiving a broad range of services related to maritime transport. council decision (cfsp) 2025/2617 18 december 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 2618 above. council implementing regulation (eu) 2026/613 (regulation 613) 16 march 2026 regulation 269 on the date of its publication adds 9 individuals to the asset freeze list under regulation 269. council implementing regulation (eu) 2026/647 (regulation 647) 16 march 2026 regulation 2642 on the date of its publication adds 4 individuals to the asset freeze list under regulation (eu) 2024/2642. council decision (cfsp) 2026/614 16 march 2026 decision 145 on the date of its publication equivalent to those listed under regulation 613 above. council decision (cfsp) 2026/646 16 march 2026 decision 2643 on the date of its publication equivalent to those listed under regulation 647 above. council regulation (eu) 2026/506 (regulation 506) 23 april 2026 regulation 833 on the day following that of its publication adds 60 entities to the list on whom and on which tighter export restrictions are imposed regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including those on computer numerical controlled (cnc) machine tools, microelectronics, components for unmanned aerial vehicles, microelectronic products, maritime equipment, and components for other vehicles and machinery. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector, by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including laboratory glassware, certain high performance lubricants and their additives, and energetic materials. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of russia’s war of aggression against ukraine, including restrictions on certain raw materials, metals, certain minerals, on scrap of steel and other metals, on chemicals, on articles of vulcanised rubber and on tanned furskins. extends the list of goods and technology subject to the prohibition on transit via the territory of russia. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as chemicals, rubber and articles of vulcanised rubber, articles of steel, tools for metal production and industrial tractors. expands the existing broadcasting prohibition to also restrict broadcasting and the facilitation of broadcasting in the eu of content of entities which mirror the content of other entities that are already subject to the prohibition, in order to tackle attempts to circumvent the restrictive measure. introduces a prohibition on providing liquified natural gas (lng) terminal services to russian entities or to entities owned or controlled by russian nationals or operators. amends the price cap for russian crude oil and petroleum products. amends the obligation to provide traceability evidence by requiring importers of polished diamonds, including diamonds polished in third countries, to provide a due-diligence statement confirming that the diamonds were not mined, processed or produced in russia. enables the council to draw up a list of russian companies, which are subject to a transaction ban, that benefit from such illegitimate so-called ‘temporary management’, in particular by ‘temporarily’ taking over the management in russia of the property and entities owned or controlled by entities established in the eu, or by operating in the same market sector as those eu owned or controlled entities. removes the listings of five entities from the relevant annex to decision 512. identifies four financial entities with a view to prohibiting transactions between them and persons located in the eu by listing the four financial entities in the relevant annexes to decision 512. prohibits engaging, directly or indirectly, in any transaction involving central bank digital currencies such as the digital rouble or providing support to the development of such projects. expands the list of crypto-assets the use of which is prohibited in transactions. prohibits engaging with any crypto-asset service provider that is established in russia, and making use of any platform that is established in russia, which facilitates the transfer and exchange of crypto-assets. adds 20 credit or financial institutions to the transaction ban. amends an exemption that is necessary for the reception of payments due and the fulfilment of prior obligations by the legal persons, entities or bodies referred to in the relevant annex to decision 512. adds an exemption for the payment of reasonable professional fees or the reimbursement of incurred expenses associated with the provision of legal services, as well as an exemption related to the needs of state-funded intermediate organisations for the foreign cultural policy of the member states in russia. imposes additional restrictions on the provision to the government of russia and to legal persons, entities or bodies established in russia of services that contribute to enhancing russia’s technological capabilities, in particular the provision of managed security services. introduces an exemption from the requirement for prior authorisation for services provided to the government of russia which are not already subject to the restrictive measures set out in regulation 833 where those services are strictly necessary for the functioning of a consular or diplomatic representation of russia located in a member state. broadens the existing prohibition on the acceptance of financing, donations or any other economic benefits or support from russia, whether directly or indirectly, by extending it to public and private research institutions, universities, higher education establishments, research and technology organisations, non-governmental organisations, public bodies and agencies, to undertakings and other entities in the industrial and commercial sectors, including micro, small, medium-sized and large enterprises, that carry out research and innovation action, as well as to natural persons associated with such legal persons, entities or bodies. clarifies that reporting obligations concerning information which would facilitate the implementation of decision 512 and regulation 833 should encompass the duty to report about persons that engage in attempts at circumvention schemes, or on transactions deemed suspicious. introduces new restrictions on ice-breaker vessels operating in russia. strengthens the eu’s framework of restrictive measures by extending the scope of the prohibition on the satisfaction of such claims in connection with any contract or transaction the performance of which has been affected, directly or indirectly, in whole or in part, by eu restrictive measures. amends the prior notification mechanism for russian diplomats and consular officers, as well as for members of the administrative and technical staff or of the service staff of diplomatic missions or consular posts of russia, and for their family members, when travelling to a member state other than that of their accreditation or residence. adds two combined nomenclature (cn) codes and the kyrgyz republic to the list of goods and technology and countries set out in the relevant annex to decision 512. extends the list of partner countries for importation of petroleum products. lists two ports and locks in russia, and one port and lock in a third country other than russia that are used for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices. this concerns the karimun oil terminal in indonesia. council regulation (eu) 2026/511 (regulation 511) 23 april 2026 regulation 269 on the date of its publication amends the listing criterion for natural or legal persons, entities or bodies owning, controlling, managing or operating vessels involved in certain activities or that otherwise provide material, technical or financial support to the operations of such vessels. extends to a newly listed insurance company the existing derogation related to payments constituting an indemnity or benefit provided further to the materialisation of a risk. introduces additional derogations from the asset freeze and the prohibition on making funds and economic resources available to designated persons and entities for the work of state-funded intermediators for the foreign cultural policy of the member states in russia, such as cultural institutions, schools or organisations supporting member states’ ethnic minorities. provides for a derogation allowing, under certain conditions, the release of frozen funds or economic resources solely for the payment of costs of arbitral proceedings awarded against such listed persons and to the benefit of parties that are neither persons listed in the asset freeze list of regulation 269 nor owned or controlled by listed persons subject to the restrictive measures set out in in regulation 269, or that are not russian nationals nor established in russia and that are not subject to the restrictive measures set out in regulation 833. introduces a new derogation to enable the release of frozen funds of a listed entity or the provision of economic resources thereto, where this is essential to facilitate a reduction by that entity, in the intake of, or reliance on, russian crude oil imports. extends an existing derogation for the supply of specific goods and services necessary for the sofia metro system. strengthens the eu’s framework of restrictive measures by extending the scope of the prohibition on the satisfaction of such claims in connection with any contract or transaction the performance of which has been affected, directly or indirectly, in whole or in part, by eu restrictive measures, in order to better protect eu operators. council regulation (eu) 2026/513 (regulation 513) 23 april 2026 regulation 765 on the day following that of its publication expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector, by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including laboratory glassware, and certain high performance lubricants and their additives. expands the list of goods subject to export restrictions which might contribute to the enhancement of belarusian industrial capacities, such as chemicals, rubber and articles of vulcanised rubber, articles of steel, tools for metal production and industrial tractors. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus. imposes additional restrictions on the provision to the republic of belarus, its government, its public bodies, corporations or agencies and to natural or legal persons, entities or bodies acting on their behalf or at their direction of services that contribute to enhancing belarus’s technological capabilities, in particular the provision of managed security services. restricts the provision of services directly related to tourism activities in belarus. introduces an exemption from the requirement for prior authorisation for services provided to the republic of belarus, its government, its public bodies, corporations or agencies which are not already subject to the restrictive measures set out in regulation 765 where those services are strictly necessary for the functioning of a consular or diplomatic representation of belarus located in a member state. introduces further import bans on goods which allow belarus to diversify its sources of revenue, thereby enabling its involvement in the russian aggression against ukraine, including on certain raw materials, metals, certain minerals, scrap of steel and other metals, chemicals, articles of vulcanised rubber and tanned furskins. strengthens the eu’s framework of restrictive measures by extending the scope of the prohibition on the satisfaction of such claims in connection with any contract or transaction the performance of which has been affected, directly or indirectly, in whole or in part, by eu restrictive measures. imposes a prohibition on engaging, directly or indirectly, in any transaction involving such a belarusian central bank digital currency or providing any support to the development of such a project. prohibits transactions with any crypto-asset service providers established in belarus or with any decentralised platforms established in belarus that enable the exchange or transfer of crypto-assets. council implementing regulation (eu) 2026/505 (regulation 505) 23 april 2026 implementing article 8a(1) of regulation 765 on the date of its publication adds 3 entities to the belarussian asset freeze list under regulation 765. council implementing regulation (eu) 2026/509 (regulation 509) 23 april 2026 regulation 269 on the date of its publication adds 37 individuals and 80 entities to the asset freeze list under regulation 269. council decision (cfsp) 2026/504 23 april 2026 decision 145 on the date of its publication equivalent to those listed under regulation 511 above. council decision (cfsp) 2026/508 23 april 2026 decision 512 on the day following that of its publication equivalent to those listed under regulation 506 above. council decision (cfsp) 2026/512 23 april 2026 decision 642 on the day following that of its publication equivalent to those listed under regulation 513 above. council implementing decision (cfsp) 2026/503 23 april 2026 implementing decision 642 on the date of its publication equivalent to those listed under regulation 505 above.

on 23 april 2026, the council of the european union formally adopted its 20th package of restrictive measures against the russian federation in response to russia's ongoing war of aggression against ukraine. it features 120 additional individual listings, the largest number in two years, and multi-layered economic sanctions the measures specifically target strategic sectors underpinning russia's military and economic resilience, including the energy sector, financial services (notably with an expansion on crypto-asset restrictions), international trade networks, and the military-industrial complex. these sanctions aim to further isolate russia from global markets, restrict access to vital resources and revenue streams, and close critical compliance gaps exploited via third countries. these regulations will require global compliance frameworks to evolve in several critical areas. energy revenues and the shadow fleet the new measures include 36 designations across the russian energy sector, covering everything from oil extraction to transport. key updates include: shadow fleet bans: an additional 46 vessels face port access and service bans, bringing the total restricted shadow fleet to 632 vessels. lng and port restrictions: the package bans maintenance services for russian lng tankers and ice-breakers. it also blocks transactions with specific ports used to bypass the oil price cap, including murmansk, tuapse, and the karimun oil terminal in indonesia. maritime services: the framework lays the groundwork for a future ban on maritime services for russian crude oil and petroleum products. financial services and digital assets the eu has extended its transaction ban to 20 russian banks, bringing the total number of excluded russian financial institutions to 70. furthermore, the measures impose transaction bans on four financial institutions in third countries, including kyrgyzstan, laos, and azerbaijan, identified as facilitating the circumvention of eu sanctions or supporting the russian system for transfer of financial messages. given russia's increasing reliance on cryptocurrencies for international transactions the package implements a total sectoral ban on exchanges and transactions with any russian crypto asset service provider, as well as decentralised platforms enabling crypto trading. the package enforces new crypto measures including: a total sectoral ban on crypto-asset service providers and exchanges established in russia. designation of a kyrgyz entity operating a platform used to trade the government-backed stablecoin a7a5 (previously prohibited under the 19th package), and a prohibition on the rubx digital currency pegged to the rouble. a complete ban on eu support for the development of the russian digital rouble. trade limits and the military-industrial complex the eu has designated 58 companies and individuals involved in producing military goods, such as drones. additionally, 16 entities based in third countries including china, the uae, uzbekistan, kazakhstan and belarus now face restrictions for supplying dual-use goods. new export bans to russia on goods, from rubber to tractors, worth over eur 365 million. furthermore, a new restriction prohibits the provision of cybersecurity services to russia. unprecedented anti-circumvention measures for the first time, the eu activated its dedicated anti-circumvention tool. authorities applied this mechanism directly against kyrgyzstan to stop the re-export of critical telecommunications equipment and computer numerical control machines. the package also lists 60 entities as providing direct or indirect support to russia's military industrial complex or engaged in sanctions circumvention. accountability and legal protections beyond economic controls, the package targets severe human rights and legal violations. the eu added 120 new individual and entity listings across multiple categories. among these, the package specifically targets individuals enabling the forced transfer of ukrainian children, the looting of cultural heritage, and the spread of state propaganda. these sanctions are complemented by new legal safeguards bolstering the protection of eu companies from illegitimate expropriation, abusive litigation, and intellectual property infringements brought before russian courts or enforced in third countries. the measures empower member state courts to impose fines on russian entities that initiate abusive lawsuits and enable eu businesses to seek damages arising from enforcement of such judgments in jurisdictions outside russia. belarus certain provisions of the package have been mirrored in the belarus sanctions regime, including trade, finance, services, and legal protection measures. for the first time, a chinese state-owned entity has been designated under the belarus sanctions regime for its role in the production of belarusian military goods. the belarus sanctions regime has been extended by the eu council until 28 february 2027. the european council’s press release can be found here and the european commission’s press release here

the organisation for economic co-operation and development (oecd) released its 2025 update to the model tax convention on income and on capital on 18 november 2025, introducing significant changes that will reshape the international tax landscape. these updates provide critical guidance on the taxation of cross-border remote work and income from natural resource extraction, aiming to offer greater certainty for governments and businesses alike. for multinational corporations, tax professionals, and policymakers, understanding these changes is paramount. this post breaks down the key updates, explores their implications, and offers actionable recommendations for navigating this new era of international tax policy. key updates in the 2025 oecd model tax convention the 2025 update introduces several pivotal changes designed to modernise international tax rules. the core amendments address four main areas: the rise of remote work, the taxation of natural resources, dispute resolution, and transfer pricing. taxation of cross-border remote work the global shift towards remote work arrangements has created significant uncertainty regarding tax obligations. the new guidance provides much-needed clarity on when a home office or other remote workspace constitutes a "permanent establishment" (pe) for a business, thereby creating a taxable presence in another country. the 50 per cent threshold as safe harbour: a central feature is a new benchmark specifying that, in general, a home office will not be considered a place of business for an enterprise if the employee works from there for less than 50 per cent of their total working time in a 12-month period. this introduces a practical safe harbour for businesses monitoring remote work arrangements. if this threshold is exceeded, whether the enterprise has a place of business at such location will be determined by the facts and circumstances, including consideration of whether there is a commercial reason for the activities. commercial reason test: the update introduces the concept of a "commercial reason" for an individual’s presence in a specific country. if an employee’s location facilitates key business activities, such as direct client engagement, management of local suppliers, or access to business-critical resources, this increases the likelihood of a taxable presence. in contrast, remote work solely for employee convenience, cost-saving, or retention generally does not create a pe. clarity for employers and employees: this framework enables organisations and staff to better manage tax risk and minimise the possibility of unexpected tax liabilities or double taxation. a new framework for natural resource taxation for decades, allocating taxing rights over income from natural resources like oil, gas, and minerals has been a complex issue, particularly for developing nations. the 2025 update introduces a new alternative provision that strengthens the taxing rights of the country where the resources are located (the source country). reinforcing source-country rights: the new provision ensures that income from activities carried on in connection with the extraction and exploitation of extractable natural resources is taxed where those activities occur. this measure is especially significant for resource-endowed developing economies, helping them secure a fairer share of revenue from their finite resources. lower “permanent establishment” threshold: the alternative provision establishes a lower threshold for creating a pe for extractive industries. non-resident enterprises will be deemed to have a taxable presence after operating in a country for a bilaterally agreed period, which is often shorter than the standard pe threshold. gains from asset disposal: the update also clarifies rules for taxing gains from the sale of assets related to extractive activities, including shares in companies whose value is derived from natural resources. enhancing dispute resolution and tax certainty tax disputes between countries can be lengthy and costly. the 2025 update strengthens the mutual agreement procedure (map) under article 25 to improve the efficiency and effectiveness of dispute resolution. refining transfer pricing and financial transactions transfer pricing remains a major focus for tax authorities. the updates to article 9 provide clearer guidance on financial transactions. interest deductibility: the commentary clarifies how domestic interest deduction limitation rules, such as those recommended under the beps action 4 report, interact with tax treaty provisions. this helps prevent companies from using excessive interest payments to erode their taxable base. debt vs. equity: the update addresses the re-characterisation of debt as equity, giving tax administrations a stronger basis for challenging financing arrangements that are not commercially sound. this ensures that the allocation of profits reflects the true economic substance of the transactions. exchange of information the 2025 update includes important changes regarding the exchange of information between tax authorities. use of exchanged information: information received through an exchange can be used for tax matters concerning persons other than those in respect of which the information was initially received. taxpayer access and disclosure: the update reflects agreed interpretative guidance on taxpayer access to exchanged information and the disclosure of reflective non-taxpayer specific information about or generated on the basis of exchanged information. such reflective information may be disclosed to third parties if it does not reveal taxpayer's identity implications for stakeholders these updates carry significant implications for governments, multinational enterprises, and developing countries. for governments:the new rules offer enhanced tools to protect their tax base and ensure fair taxation of cross-border activities. the guidance on remote work provides a modern framework, while the provisions on natural resources empower source countries to claim a greater share of revenue. for businesses:while the updates provide welcome clarity, they also introduce new compliance challenges. companies must review their remote work policies, transfer pricing strategies, and operations in the extractive sector to align with the new standards. proactive planning will be essential to manage tax risks and avoid disputes. for developing economies:the focus on source taxation for natural resources is a major victory. by adopting these new provisions in their tax treaties, developing nations can significantly bolster their revenue streams from the extractive industries, providing vital funds for public services and infrastructure. recommendations for a smooth transition to effectively adapt to the 2025 oecd model tax convention update, consider the following oecd-supported actions: review and update cross-border employment policies: businesses should carefully assess existing remote work arrangements and cross-border employment contracts to ensure alignment with the new permanent establishment thresholds and the "commercial reason" test introduced by the oecd. analyse extractive industry operations: for companies involved in the extraction of natural resources, it is essential to evaluate projects and service agreements under the revised, lower permanent establishment thresholds, ensuring activities are structured in compliance with the updated guidance. companies should note that the provision covers both offshore and onshore activities incorporate updates into bilateral tax treaties: governments are encouraged by the oecd to adopt the revised model tax convention provisions in their bilateral tax treaties, enhancing consistency and legal certainty in cross-border tax matters. the 2025 oecd model tax convention update is a landmark development in international taxation. by providing clarity on modern economic challenges, it sets a new standard for fairness and cooperation. as a full-service offshore law firm, we are uniquely positioned to help you navigate these changes and ensure your operations remain compliant and strategically optimised. for more information, the oecds press release can be found here and the publications here and here.

on 13 april 2026, the bermuda monetary authority (bma) announced the phased introduction of a new regulatory filing platform, submit, which will replace the current integra® system for submissions under the investment funds act 2006. submit is designed to enhance user experience with a more intuitive and streamlined process, while also improving supervisory efficiency. although the specific modules for the initial release are yet to be confirmed, the bma aims to provide stakeholders with early notice to prepare for the transition. detailed guidance, timelines, and transition arrangements will be shared in due course to ensure a smooth migration. the notice can be found here.

on 13 april 2026, the bermuda monetary authority (bma) announced the phased introduction of a new regulatory filing platform, submit, which will replace the current integra® system for submissions under the investment funds act 2006. submit is designed to enhance user experience with a more intuitive and streamlined process, while also improving supervisory efficiency. on 13 april 2026, the bermuda monetary authority announced the phased introduction of a new regulatory filing platform, submit, which will replace the current integra® system for submissions under the investment funds act 2006. submit is designed to enhance user experience with a more intuitive and streamlined process, while also improving supervisory efficiency. simplifying fund filings: bma's new submit platform on 13 april 2026, the bermuda monetary authority (bma) announced the phased introduction of a new regulatory filing platform, submit, which will replace the current integra® system for submissions under the investment funds act 2006. submit is designed to enhance user experience with a more intuitive and streamlined process, while also improving supervisory efficiency.

on 19 march 2026, the cayman islands government published amendments to three key legislative acts to establish a clear regulatory framework for tokenised investment fund structures. these amendments were enacted through the mutual funds (amendment) act, 2026, the private funds (amendment) act, 2026, and the virtual asset (service providers) (amendment) act, 2026. effective from 24 march 2026, these changes provide regulatory certainty for fund professionals and investors by confirming how tokenised investment fund structures should be considered. previously, the lack of explicit statutory provisions created ambiguity, particularly regarding the applicability of the virtual asset (service providers) act (vasp act), to digital tokens representing ownership interests in funds. the mutual funds (amendment) act, 2026 introduces specific provisions to ensure that tokenised mutual funds are subject to the same regulatory oversight as traditional mutual funds. this amendment reduces the risk of a more onerous compliance burden by aligning tokenised fund structures with established compliance and reporting standards. the private funds (amendment) act, 2026 extends regulatory requirements to tokenised private funds, ensuring that these innovative structures adhere to the same governance, operational, and transparency principles as conventional private funds. this amendment aims to safeguard investor interests while supporting the growth of tokenised fund offerings by providing certainty as to the compliance and regulatory requirements. the virtual asset (service providers) (amendment) act, 2026 clarifies the scope of the virtual asset (service providers) act, explicitly confirming that the issuance of digital tokens representing ownership interests in funds is not considered to be an “issuance of virtual assets” or “virtual asset issuance”. this amendment resolves prior uncertainties and aligns the cayman islands’ regulatory framework with international standards for virtual assets. together, these legislative updates aim to foster innovation while maintaining robust regulatory oversight. for more information the industry advisory can be found here