The sanctions against Russia are becoming more complex

After three years of war in Ukraine and what is now the 16th sanctions package against Russia, the measures are becoming more comprehensive, but also more complex. Russia is trying to circumvent the sanctions imposed in various ways in order to stabilise its economy and continue the war. To this end, Russia often uses dilapidated ships from third party countries to transport crude oil and possibly illegally declare it as non-Russian oil. In addition, stolen goods are transported from Ukraine or military equipment is brought to Russia. Another problem is that more and more skippers are suspected of damaging submarine cables in the UK and EU communications infrastructure.

As part of the 16th sanctions package, 74 ships were added to Annex XLII of Regulation (EU) 833/2014. Far-reaching restrictions apply to these ships: Access to ports is prohibited, as are a large number of services, including financing, insurance and flag registration. These services may also not be provided outside the EU. In addition, materials used in Iranian and Chinese combat drones are banned, including electronics for video game controllers, software for oil and gas production, chemical precursors and software for CNC machines. Foreign subsidiaries of EU companies are also not allowed to provide this technology in order to prevent circumvention of the sanctions.

In addition to the existing import bans on processed aluminium products, direct imports of unprocessed aluminium from Russia are now also being gradually banned. From the end of 2026, no more Russian aluminium may be imported into the EU. The new export bans also prohibit the transit of the affected goods through countries cooperating with Russia, such as Belarus. New sanctions are also aimed at companies that support the Russian military or circumvent sanctions. In upcoming sanctions packages, air traffic is expected to be more strictly regulated, with sanctions against airlines from third party countries operating in or for Russia.

Existing financial sanctions, including those against transactions involving cryptocurrencies, will be extended. In addition, an amendment to the German Foreign Trade and Payments Act is intended to facilitate the prosecution of circumvention transactions. In view of the growing complexity, it is almost impossible to check sanctions manually. Our M.Secure Trade Export Control and Sanctions List Check tools make it possible to check existing export restrictions directly in SAP without having to re-enter data. Important check steps such as ‘To whom are deliveries made?’, ‘Where are deliveries made to?’ and ‘What is delivered?’ can be included in your Internal Compliance Programme (ICP) so that you can optimally prepare for export control checks by customs.

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