- The EU’s 9th Russia sanctions package (16 December 2022) tightens investment, export, services and financial restrictions and adds major new asset-freeze listings.
- It bans most new EU investment in Russia’s mining and quarrying sector while exempting specified critical raw materials.
- It expands prohibited professional services to Russian entities and bars EU persons from certain governance roles in Russian state-linked entities.
- It introduces time-limited derogations for divestment or wind-down and certain agri-food/non-military trade, alongside stronger enforcement and criminalisation efforts.
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The 9th EU sanctions package is structured as a calibrated escalation: targeting investments, enhancing export controls, and tightening enforcement—all while seeking to preserve channels for strategic materials and humanitarian-critical exports. Specific goals include undermining Russia’s war-machinery inputs, constraining state-controlled entities, and closing professional-service loopholes.
The mining and quarrying ban extends an earlier energy-sector investment prohibition to broader resource extraction, though with important carve-outs for critical raw materials (such as rare earths, copper, aluminium, etc.) cataloged in Annex XXX of Regulation 833/2014. This reflects EU dependence on certain inputs essential for green technologies and digital transition—seeking to limit Russian revenues without compromising supply chains fully.
Ban extensions in professional services and governance aim to degrade Russia’s ability to shape narratives, conduct market analysis, or access technical assessments. Prohibiting EU nationals from serving on governing bodies of Russian state-controlled or closely related entities enhances control over internal decision flow, reduces risk of indirect influence.Open contracts pre-17 December receive wind-down periods, balancing enforceability with legal predictability for firms.
The broad asset freezes—141 individuals, 49 entities—as well as inclusion of additional banks (e.g., Credit Bank of Moscow, Dalnevostochny Bank) and the Russian Regional Development Bank under transaction bans deepen financial isolation. Derogations for agri-food trade reflect concern over global food security. Export bans expanded to include aviation-engine components, dual-use electronics, and printed circuits target Russia’s military supply chain.
Enforcement enhancements signal that the EU wishes to move from sanction imposition to sanction effectiveness. Measures include treating sanctions violations as crimes, enhancing national jurisdiction definitions, and appointing special envoy to oversee global enforcement and avoid circumvention.
Strategically, this package heightens risks for investors and partners operating in or with Russia; supply chain dependencies pose serious questions for EU industries sourcing critical materials. Also, firms engaged in consulting, testing, advertising, etc., must already have compliance road-maps, as enforcement is likely to become more aggressive. Open questions remain regarding the scale of actual disruption to Russian supply and revenue flows, and the ability of alternative markets or illicit channels to mitigate EU’s pressure.
Supporting Notes
- The ban on new investment in Russia’s mining and quarrying sector prohibits acquiring/extending participation, financing, joint ventures, or investment services in entities operating in mining/quarrying, except for those producing listed critical raw materials.
- The specific materials exempted include aluminium (and bauxite), chromium, cobalt, copper, iron ore, mineral fertilisers (including potash and phosphate rock), molybdenum, nickel, palladium, rhodium, scandium, titanium, vanadium, heavy and light rare earths.
- New categories of services banned to Russian entities include market research; public opinion polling; technical testing and analysis; advertising—extending earlier bans on services like IT consultancy, accounting, public relations.
- EU nationals or residents are banned from holding posts in governing bodies of Russian state‐owned or controlled entities, or those with substantial economic relationships with Russia; exemptions for existing joint ventures/subsidiaries established before 17 December 2022, and when necessary for critical energy supplies.
- Asset freeze designations add 141 individuals and 49 entities; including Credit Bank of Moscow, Dalnevostochny Bank, National Media Group, JSC Bryansk Automobile Plant, and Boris Yurievich Kovalchuk.
- Derogations allow suppliers to sell or transfer restricted goods until 30 September 2023, for divestment or wind-down, provided items are owned by EU persons, not for military end-use, and already physically in Russia before export bans.
- Enforcement framework strengthened: EU adopted a decision to add violations of restrictive measures to the list of EU crimes; a draft directive for minimum criminal penalties is in progress; an International Sanctions Special Envoy was appointed.