The essence of the act:
This regulation amends EU Regulation 2022/263 concerning restrictive measures against Russian-occupied areas of Ukraine. It introduces new prohibitions on supplying banknotes, certain goods, technology, and services to non-government controlled areas in Donetsk, Kherson, Luhansk and Zaporizhzhia regions. The regulation also strengthens enforcement mechanisms and clarifies provisions on circumvention of sanctions.
Structure and main provisions:
1. The regulation expands existing restrictions by:
– Prohibiting supply of EU member states’ banknotes to occupied territories
– Banning export of specific goods and technology listed in detailed annexes
– Restricting provision of professional services like accounting, consulting, IT, legal and engineering services
– Adding new provisions on software for enterprise management and industrial design
2. Key changes compared to previous version:
– Introduces comprehensive lists of restricted goods and technology in new annexes
– Adds detailed provisions on circumvention and enforcement
– Clarifies responsibilities of EU operators regarding entities they control outside EU
– Strengthens reporting requirements for member states on penalties
Main important provisions:
– Detailed lists of prohibited goods, technology and services in multiple sectors
– Clear definition of circumvention including both intentional and unintentional actions
– Requirements for EU companies to prevent circumvention by entities they control
– Provisions for exceptions related to humanitarian needs, civil society support and critical infrastructure
– Enhanced enforcement mechanisms including self-disclosure of violations
– Specific provisions on data protection and information sharing between authorities
The regulation provides comprehensive framework for implementing restrictions while maintaining humanitarian exceptions and ensuring effective enforcement.
