Anticipated arrival in June: The 14th EU Sanctions package and the plan to make EU operators responsible for sanctions violations


​​​​​The EU has already adopted 13 sanctions packages, which have expanded the scope of applicable EU restrictive measures. Consequently, ongoing due diligence is essential for all EU operators to ensure proper sanctions risk management and screening. It's crucial to stay vigilant and prepared, especially considering that the forthcoming EU 14th sanctions package is expected to be adopted in June. This new package is anticipated to introduce fresh prohibitions and list new sanctioned individuals.

The proposed restrictive measures by the European Commission are set to encompass a range of areas, including restrictions on energy exports, tackling sanctions circumvention by third countries like Belarus, and addressing Russian liquefied natural gas (LNG) exports, particularly regarding transshipment. Moreover, controls on the export of critical technologies used in Russia's military equipment are on the agenda.

One of the most important parts of the new sanctions package for EU businesses is that the imposition of responsibility on EU operators to be adopted. If their subsidiaries or partners in third countries breach sanctions, then EU operators may face certain negative consequences. However, the full extent of responsibility for sanctions violations will be clear only after the official adoption of the new sanctions package.

Among the other significant sanctions to be adopted are:

  • Inclusion of new names on the sanctions list
  • Ban on new investments and the provision of goods, technology, and services by EU operators related to LNG projects
  • Introduction of a new sectoral ban on shipping related to Russia's military vessels, goods, or technology used in the defense and security sector
  • Restrictions on the transport of goods by road, excluding companies in which Russian persons or companies own 25 per cent or more
  • Other restrictions on the import and export of goods that could impact the Russian economic industry.

Considering the above, continued vigilance and adherence to due diligence procedures are paramount for all EU operators.​​​​​​​


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Tobias Kohler

Attorney at Law


+370 5 212 35 90

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Ignas Tamašauskas

Senior Legal Consultant

+370 5 212 3590

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