EU Imposes Seventh Round of Sanctions: Ban on Russian Gold; New Asset Freezes; Expansion of Existing Measures

Last week, the European Union imposed its seventh round of sanctions on Russia, imposing a range of new restrictive measures. The new sanctions include a ban on dealings in Russian-origin gold, updates to existing sanctions to bolster the effectiveness of those measures, and an expanded list of parties subject to an EU asset freeze.

Ban on Russia-Origin Gold & Gold Jewelry

The EU’s “maintenance and alignment” sanctions package imposes a ban on Russia-origin gold that broadly prohibits the direct or indirect import, transfer, or purchase of listed Russian-origin gold products (including jewelry) after July 22, 2022. The ban covers gold and jewelry that are processed in third countries and incorporate listed Russian-origin gold products.

Other “Maintenance and Alignment” Sanctions

The European Union took a number of other steps to strengthen existing sanctions against Russia, including the following:

• Expansion of items that are controlled for export to Russia as potentially contributing to Russia’s military capabilities and defense sector;
• Extension of port access ban to lock access;
• Permissions relating to the standard setting activities of the International Civil Aviation Organization;
• Exemption from prohibitions against transactions with Russian public entities that are necessary to ensure access to judicial, administrative or arbitral proceedings;
• Expansion on prohibition against acceptance of deposits to include entities established in third countries and majority owned by Russians, requirement that acceptance of deposits for non-prohibited cross-border trade be subject to prior authorization by competent authorities;
• Extension of exemption to prohibitions against transactions with certain Russian state-owned entities that are necessary for the transport of agricultural and oil products to third countries; and
• Clarification that third countries and their nationals may purchase pharmaceutical and medical products from Russia.

The EU’s latest package of sanctions expanded its list of designations to include additional 48 individuals and 9 entities. The latest expansion notably includes asset freeze restrictions on Sberbank.

As a reminder, all funds and economic resources belonging to designated individuals and entities shall be frozen under EU law, and those subject to EU jurisdiction are forbidden from making funds directly or indirectly available to designated targets.