EL-i viimaste sanktsioonide ülevaade
So new EU #Russia #sanctions package just dropped yesterday. You're curious what's in it, but don't have the time go through it!
Lucky for you: I've got you covered. I just spend the entire night dissecting every line. Here is what's in it.
EU changed 3 areas of law:
1/ Asset freezes/visa bans, adding new 30 individuals and 7 entities (incl. Alexander Dugin);
2/ Major Russia sanctions law, by adding new restrictions, incl. oil price cap; and
3/ Embargo on Donetsk/Luhansk.
I will analyze these in turn.
As for individuals designations (asset freezes/entry bans), the EU listed additional 30 individuals and 7 entities. The total number is now at 1262 individuals and 118 entities.
Among new individuals we have:
-10 persons involved in conducting illegal referenda in Zaporizhzhia, Kherson, Donetsk & Luhansk (2 from Russian Central Election Commission - Chair & Deputy, 2 from the State Council, 6 from local structures at Zaporizhzhia, Kherson & Donetsk);
- 4 persons from local pseudo-governmental structures in Donetsk & Luhansk;
- 6 Deputy Ministers of Defence (how many do they have in total?
);
- 2 from Russian Army (Gen. Ryzhkov & G. Zhidko);
- 1 from FSB (V Kulishov - Head of RUS Border Service listed for systemic "filtration operations" & forced deportations of Ukrainians from occupied territories)
- 1 from Federal Service for Military Technical Cooperation FSVTS which controls military coop w/ 3rd countries;
- 2 businessmen (Lushnikov - largest shareholder of Kalashnikov Concern & Kochkin - Executive Director of Tecmash - key designer of missiles and munitions used by the Russian army)
- 3 singers/musicians (Yulia Chicherina,Nikolay Rastorguev, Oleg Gazmanov) for participating in pro-war and anti-Ukraine rallies and concerts for soldiers);
- and - last but not least - ALEXANDER DUGIN for promoting ideas that justified annexation of Crimea and attack on Ukraine.
It's just not his year, is it.
The full justification for listing Dugin is below.
EU also listed 7 new entities, incl. 5 defence manufacturers (eg. S300/400 & TOR missile system designer MKB Fakel, manufacturer MMZ Avangard & aircraft manufacturer Irkut), secure documents (passports, banknotes) manufacturer Goznak & Russian Central Election Commission.
Second, related to assess freezes: the EU also created a new grounds for listing (e.g. subjecting to sanctions) of foreign companies and individuals that facilitate EU persons violation of EU sanctions.
There are no specific foreign companies sanctioned yet, but this signals that EU now can - if it decides to - sanction non-EU companies if they are engaged in helping EU entities engage in forbidden transactions.
This is quite a U-turn for EU, which has until recently been complaining abt US applying its sanctions to non-US companies extraterritorially. It now appears EU is discovering it too needs to have a weapon against 3rd country entities entangled in EU sanctions circumvention
Third, EU has also relaxed two asset freeze provisions related to Kamaz and to National Settlement Depository, allowing EU parties to terminate their relationships with these entities. The details are unclear, but I'll take a guess.
With Kamaz, it seems that someone in the EU may have a JV with one of these guys
(may be Kamaz, or someone else) & needs to cash out, but can't find a buyer. So they'll most likely sell to Kamaz, but for this they need an exemption to make the payment.
My guess is that the company needing to get out is Daimler AG.
The other exemption is for Nat'l Settlement Depository, Russia's largest securities depository owned by Moscow Exchange. It functions as RU's domestic paying agent (like Euroclear/Clearstream). It was sanctioned in June 2022 and its challenging these sanctions in EU courts.
The exemption allows unfreezing of frozen assets or payments to NSD necessary for termination, before 7/1/23 of operations, contracts or other agreements concluded before 3/6/22.
So some EU party has three months to wrap things up with NSD.
So now we move to amendments to the big sanctions regulation, Reg. 833, the consolidated version of which now has over 200 pp.
The first big one is the infamous oil price cap. Once a price is established, EU introduces a complete ban on transport, including ship-to-ship transfers, to third countries, of Russian crude oil (from 4/12/22) and petroleum products (from 5/2/23), unless the cap is met.
The cap itself is established by the G7 "Price Cap Coalition" (not defined in EU law) and introduced into the EU legal system unanimously by a Council Decision inserting the price cap into the Annex to the sanctions law.
The EU hasn't introduced a cap yet, but it has already exempted shipments to Japan of crude oil for the Sakhalin-2 project in Russia from any future price cap.
When once-stablished price cap is changed, a 90 day grace period will continue in effect to cover deliveries under pre-existing contracts that meet the previous cap.
Finally, the cap will not extend to shipments of non-Russian crude and petroleum products that were only transshipped through Russia.
The second - minor - is a correction made to ban on assistance and brokering related to petroleum products.
The original ban on imports of crude oil enters into force on 5/12/22, and the ban on imports of petroleum products enters into force on 5/2/23.
The EU also allowed the paying out of insurance claims after the embargo on crude oil and petroleum products enters into force. This is necessary, as it could be deemed prohibited as "financing" or "financial assistance".
(but this too, is minor)
The second big new sanction is - in my view - MONUMENTAL. This is the extension of the steel import embargo, to products "processed in third countries", but incorporating Russian iron and steel products.
I cannot stress this enough. This is BIG. Essentially, under Russian sanctions, the EU is banning imports of certain steel and iron products from ANY COUNTRY, if they are made from Russian steel and iron.
These are secondary sanctions, in a way. Extraterritorial.
https://twitter.com/TomWlost/status/1578452608150212609
Olgu praegu siin.
);
(may be Kamaz, or someone else) & needs to cash out, but can't find a buyer. So they'll most likely sell to Kamaz, but for this they need an exemption to make the payment.