On 15 December 2024, the EU adopted its 15th package of restrictive measures against Russia. (Council of the EU Press release; EU Council Regulation (EU) 2024/3189; EU Council Regulation (EU) 2024/3192).
The new measures include:
- Anti-circumvention measures
- Financial sector measures
- Anti-suit injunction measures
- Trade measures.
Anti-circumvention measures
In order to further constrain the activity of vessels associated with Russia, the EU Council banned another 52 vessels from entering ports and locks of the EU member states and prohibited the provision of a broad range of maritime transport services in their respect. The total number of listed vessels is now 79.
Financial sector measures
Due to the increased number of litigations in Russia that involve EU Central Securities Depositories (CSDs), the EU decided to introduce a loss recovery derogation mechanism and no liability clause for the EU CSDs. A loss recovery derogation would allow CSDs to ask competent authorities of the Member States to unfreeze cash balances held by EU CSDs and use them to meet the legal obligations of such depositories. A no liability clause allows no payments of interest or any form of compensation to the Central Bank of Russia, beyond the interest that is due to be paid under a contract.
Anti-suit injunction measures
In its 15th sanctions package, the EU introduced provisions that prohibit enforcement of injunctions, orders, judgments or other court decisions pursuant to or associated with Article 248 of the Russian Arbitration Procedure Code or equivalent Russian legislation.
Article 248 of the Arbitration Procedure Code of the Russian Federation provides for the exclusive jurisdiction of the Russian Arbitrazh (commercial) courts over disputes where the proceedings involve a designated person and/or where the dispute itself arises from sanctions imposed on Russian entities or individuals. The new EU measure seeks to address “disproportionally high financial penalties” issued by Russian courts in the disputes involving European companies.
Trade measures
Under the 15th sanctions package, the EU imposed enhanced export restrictions in respect of 32 new companies. These measures apply to dual-use goods and technology as well as advanced technology items.
Additionally, 54 individuals and 30 entities were added to the EU sanctions list. They are now subject to asset freezes and travel bans. Among those included in the list are Russian manufacturers of aircraft parts, electronics and other equipment as well as senior managers of companies operating in the Russian energy sector.
Some Chinese individuals and entities were also added to the list of EU sanctions against Russia.
How Gherson can help
Gherson lawyers have significant experience in advising on sanctions matters, including sanctions compliance. We can provide training for your staff, help you with developing new sanctions policies and advancing existing programmes. Moreover, our experienced team can assist you with designation challenges and licence applications.
Updated: 4 January 2025
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