Since February 2022, following the outbreak of the war against Ukraine, the EU adopted its 11th round of sanctions against Russia on 23 June 2023.

The latest sanctions package centres around a newly introduced anti-circumvention tool, described by the European Commission as a measure of last resort that “will allow the EU to restrict the sale, supply, transfer or export of specified sanctions goods and technology to certain third countries whose jurisdictions are considered to be at continued and particularly high risk of circumvention”.

Although the Council has not yet identified the specific third countries and products concerned, this new tool introduces the potential for such designations. In the wake of to the 11th sanctions package, the European Commission has published two separate product lists to support due diligence and effective compliance, by exporters and targeted anti-circumvention actions by customs and enforcement agencies of third countries determined to prevent circumvention through their territories.

Our lawyers delve deeper into the two product lists in their latest publication.