On 16 December 2022, the Council of Europe adopted Regulation (EU) 2022/2474, which implemented the ninth series of restrictive measures against Russia, following the conflict with Ukraine that started on 24 February 2022. Regulation 2022/2474 came into force on December 17, 2022.
These new sanctions come on top of the European restrictive measures already imposed on Russia since 2014 following the annexation of Crimea and the lack of implementation of the Minsk agreements. As a reminder, the objective of the international sanctions policy is to impose heavy sanctions on Russia to deprive it of critical technologies and goods, to weaken its economy, and its ability to wage war.
Amending the previous Regulation No. 833/2014, the new Regulation thus extends the list of export restrictions on dual-use goods and technologies as well as on goods and technologies that may contribute to the technological improvement of the Russian defence and security sector. Indeed, essential chemicals, nerve agents, night vision and radio navigation equipment, and electronic and computer components, namely laptops and hard drives that could be used by the Russian war machine, will no longer be able to be exported to Russia.
In addition, these Regulations also provide for the prohibition of exports of goods and technology related to the aviation and space industries in order to include aircraft engines and their spare parts. This ban will apply to manned and unmanned aircraft, which means that there will now be a ban on direct exports of drone engines to Russia and from any third country that may supply drones to Russia.
As a reminder, article 459-1 bis of the Customs Code provides for criminal sanctions in the event of non-compliance by companies with European sanctions. These sanctions may range up to 5 years in prison and a fine equal to at least the amount and at most twice the amount of the offence or alleged offence.
In this context, European companies must be more vigilant in their commercial relationships involving an entity that has a link with Russia and/or its financial system.
For your perfect information, Regulation (EU) 2022/2474 is available on the following link: https://eur-lex.europa.eu/legal-content/FR/TXT/PDF/?uri=CELEX:32022R2474&from=FR
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