The essence of the act:
This regulation amends EU Regulation 269/2014 concerning sanctions against Russia related to actions undermining Ukraine’s territorial integrity. It introduces new criteria for asset freezing, enhances measures against Russian oil shipping practices, strengthens information sharing between authorities, and provides additional protections for EU operators complying with sanctions.
Structure and main provisions:
1. New listing criteria for sanctions targeting:
– Entities involved in high-risk shipping of Russian oil (“shadow fleet”)
– Persons/entities supporting Russia’s military-industrial complex
2. Enhanced cooperation mechanisms:
– Information sharing between EU authorities and partner countries
– Strengthened role of Financial Intelligence Units
– Commission’s authority to process personal data for sanctions implementation
3. Additional provisions:
– Derogations for Budapest metro system maintenance
– Extended divestment possibilities for certain listed individuals
– New requirements for EU operators to prevent sanctions circumvention by their non-EU subsidiaries
– Enhanced protection for EU operators facing third-country claims
Key important provisions:
1. Specific focus on combating “shadow fleet” operations transporting Russian oil through high-risk shipping practices
2. New obligation for EU companies to ensure their non-EU subsidiaries don’t undermine sanctions
3. Enhanced information sharing between authorities to prevent sanctions circumvention
4. Additional legal protections for EU operators facing claims in third countries related to sanctions compliance
5. Extended authority for competent authorities to authorize certain transactions under specific conditions
