What fundamental aspects should be taken into account in connection with the twelfth package of sanctions?

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In the course of the ongoing war of aggression against Ukraine, the Council has adopted a 12th package of economic and individual restrictive measures, which will focus on high-value sectors of the Russian economy and create a framework to prevent circumvention of EU sanctions.

The twelfth EU sanctions package focuses on additional listings of Russian individuals and companies and new import and export bans – such as banning the export of Russian diamonds to Europe. In addition, the package tightens the implementation of the oil price cap by monitoring more closely how tankers can be used to circumvent the cap. It also includes stricter asset tracing obligations and tough measures against third country companies that evade sanctions.

The agreed package includes the following measures:
  • Diamonds
  • No Russia clause
  • Import-export controls restrictions
  • Enforcement and anti-circumvention measures
  • Enforcement of oil price cap
  • Restrictions on iron and steel
  • Individual listings

Therefore each EU operators at risk of breaching sanctions have to take proactive steps in order to mitigate sanctions-related risks and avoid potential fines and damage to reputation. 

WHAT STEPS SHOULD BE TAKEN INTO CONSIDERATION IN ORDER TO MITIGATE SANCTION-RELATED RISKS? 


Although it depends on the company industry, geography, customers and many other factors, these may include:
  • Screening of business partners 
  • Creation of sanctions policy, procedures and trainings
  • Constant monitoring of applicable sanctions regulations 
  • Due diligence on business partners, suppliers, and customers
  • Consulting with legal professionals or sanctions compliance experts.

Contact

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Julius Lastauskas

AML and Sanctions Consultant

+370 5 212 35 90

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