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Council Regulation (EU) 2025/401 of 24 February 2025 amending Regulation (EU) No 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol

1. Essence of the act:
This regulation amends EU Regulation 692/2014 concerning restrictive measures related to the illegal annexation of Crimea and Sevastopol. It introduces new prohibitions on supplying banknotes, providing various professional services, and exporting certain goods and technology to Crimea and Sevastopol. The regulation also strengthens provisions against circumvention and establishes requirements for EU operators regarding entities they control outside the EU.

2. Structure and main provisions:
The regulation consists of 2 articles and 3 annexes:
– Article 1 introduces amendments to Regulation 692/2014, including new prohibitions and restrictions
– Article 2 sets the entry into force
– Annex I lists restricted goods and technology
– Annex II specifies prohibited software
– Annex III lists countries exempted from certain restrictions

Key changes compared to previous version:
– New ban on supplying EU member states’ banknotes
– Extended list of prohibited professional services (accounting, legal, IT, etc.)
– New restrictions on software for enterprise management and industrial design
– Enhanced anti-circumvention provisions
– New requirements for EU operators regarding controlled entities outside EU

3. Most important provisions:
– Prohibition to supply banknotes denominated in any official EU currency to Crimea/Sevastopol
– Ban on providing wide range of professional services including accounting, legal, IT consulting, engineering
– Restrictions on export of specific goods and technology in transport, telecommunications, energy sectors
– Requirement for EU operators to prevent circumvention through entities they control outside EU
– Detailed provisions on processing personal data for implementation purposes
– Enhanced enforcement mechanisms including penalties and self-disclosure provisions

The regulation significantly expands the scope of restrictions while providing certain humanitarian exemptions and establishing clearer implementation framework.

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