On Friday 5th May, the Commission adopted its proposal for an 11^th sanctions package.

According to the President of the European Commission, Ursula von der Leyen, “the focus of this package is now on cracking down on circumvention.”

The Commission is proposing the following elements:

• Additional products added to the transit ban, including advanced tech products and aircraft parts;

• Introducing a new tool to combat sanctions circumvention: the listing of products with a high-risk of circumvention to Russia, and the listing of countries involved in circumvention, notably certain third countries which have seen an increase in highly unusual trade flows from the EU in recent months. These countries would no longer be able to receive the listed high-risk circumvention products;

• Measures targeting ships and trucks, to block any ship from using EU ports and locks, if it is determined to be transporting goods whose import, purchase or transfer into the Union is prohibited;

• End of the exemption granted to Germany and Poland for the supply of crude oil;

• Additional asset freezing measures, including against Chinese companies. It has been reported that the companies involved in circumventing sanctions are 3HC Semiconductors and King-Pai Technology, based in mainland China; Sinno Electronics, Sigma Technology, Asia Pacific Links, Tordan Industry, and Alpha Trading Investments in Hong-Kong.

The EU Member States are currently discussing this new round of sanctions. All 27 Member States must give their assent for this to become law.