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10th package of sanctions


​Alicja Szyrner

3 marca 2023

The European Commission adopted the 10th package of sanctions against Russia on 25 February 2023. 

The existing restrictive measures have been extended, among other things, as follows:

  • another 121 individuals and entities have been added to the sanction lists;
  • new restrictions concerning dual-use technologies and technologies that contribute to Russia's military capabilities and technological enhancement, including without limitation, drones, missiles, helicopters and thermal cameras;
  • export bans on goods that can be used to support the Russian war effort, including trucks (and their spare parts), semi-trailers, and special vehicles such as snowmobiles, electric generators, binoculars, radars, compass, fort-lift trucks, cranes; 
  • import ban on bitumen, asphalt, synthetic rubber from Russia;
  • three more Russian banks have been added to the list of entities subject to the asset freeze and the prohibition to make funds and economic resources available;
  • prohibition to transit dual-use goods and firearms via the territory of Russia to third countries;
  • private flights between the EU and Russia, directly or via third countries, must be notified in advance.

In view of the new and the existing obligations connected with the imposed sanctions as well as the financial and criminal liability for non-compliance with them, we recommend that you each time verify your contracting parties and the subject matter of your transactions. It may be helpful to introduce relevant internal verification procedures based on the compliance system.

In order to identify the risks and implement appropriate precautions, we encourage you to contact our experts.


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Alicja Szyrner

Attorney at law (Poland)

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