EU Adopts 12th Package of Economic and Individual Sanctions
EU Adopts 12th Package of Economic and Individual Sanctions
The EU’s 12th Package – Targeting Russia’s Diamond Industry
The EU’s 12th sanctions package against Russia, adopted in December 2023, includes a prohibition on the direct or indirect import, purchase, or transfer of diamonds associated with Russia.
This ban includes diamonds that originated in Russia, diamonds that were exported from Russia, diamonds transiting through Russia, and Russian diamonds processed by third countries.
The EU’s direct ban on Russian diamonds also includes non-industrial natural and synthetic diamonds alongside diamond jewellery.
"No Russia" Clause
The EU’s 12th sanctions package also now requires that EU exporters “contractually prohibit re-exportation to Russia and re-exportation for use in Russia of particularly sensitive goods and technology” when selling, transferring, supplying or exporting to a third country, with an exception for partner countries.
The new clause includes prohibited items utilized within Russian military systems known to be used on the battlefield in Ukraine or are critical to the development, production or use of those Russian military systems, as well as aviation goods and weapons.
Expansion of Enforcement and Anti-Circumvention Measures
The EU has also expanded its transit ban which currently applies to dual use goods and technologies that are exported from the EU to third countries through Russian territory to include all battlefield goods.
To further assist in limiting circumvention, the EU has imposed a ban on Russian nationals from “owning, controlling or holding any posts on the governing bodies of the legal persons, entities or bodies providing crypto-asset wallet, account or custody services to Russian persons and residents.”
Finally, the EU has implemented notification requirements for the transfer of funds outside the EU by any entity established in the EU that is owned or controlled by an entity established in Russia, or by a Russian national or natural person residing in Russia.