The European Commission published a new Guidance note on the implementation of the current EU restrictive measures against Russia. The Commission Guidance note can be found here.
The EU sanctions regime against Russia limits the access of Russian state-owned financial institutions to EU capital markets, imposes an arms embargo and restricts the access of Russian firms to certain sensitive technologies, particularly in the oil sector. The EU restrictive measures against Russia are imposed in response to Russia’s involvement in the Ukraine crisis and are included in Council Regulation (EU) 833/2014 and Council Decision 2014/512/CFSP as amended. On 16 December 2014, the European Commission issued its first guidance note on the implementation of Regulation (EU) 833/2014. The present Guidance note is an updated version of that note and aims to provide further guidance on the application of certain provisions in Regulation (EU) No 833/2014, as amended from time to time, for the purpose of uniform implementation by the national authorities and parties concerned. The notice covers several topics, such as:
• the meaning of providing financial assistance in the context of the arms embargo;
• when financing restrictions apply generally;
• how banks should ensure their compliance;
• how the measures restrict the access to capital markets; and
• the status of pre-existing loans.
Please feel free to contact us should you wish to discuss any of the subjects set forth in this Guidance note.