On June 3, 2022, the European Union Council adopted a sixth package of sanctions against Russia, which will phase-out the import of Russian oil and petroleum products over the next six to eight months. This particular round of sanctions will not restrict the import of gas, but official guidance warns that “nothing is off the table”.
The package of sanctions E.U. has prohibits the import (or purchase or transfer, directly or indirectly) of Russian crude oil and certain petroleum products into member states, as well as the seaborne delivery of such goods to third countries. Any insurance, reinsurance, technical assistance, brokering services, financing, financial assistance or any other related services, direct or indirect, are also prohibited. A wind-down period of six to eight months applies to existing contracts and “one-off” spot contracts, provided certain reporting requirements are met.
Again, it is prohibited to provide insurance or reinsurance for maritime transport of crude oil and refined petroleum products to third countries. European Union operators and entities may not provide any new insurance or finance contracts for the transport, in particular through maritime routes, of Russian oil to third countries. The Council has included a wind-down period of six months (until 5 December 2022) for closing out any existing contracts executed before 4 June 2022.
For land-locked Hungary, the Czech Republic, and Slovakia, a temporary exemption will allow them to continue to import Russian oil via pipeline. Bulgaria and Croatia will also benefit from exemptions to allow the seaborne import of Russian oil and vacuum gas respectively. After eight months, European Union countries that benefit from these carve-outs may not sell or transfer Russian oil or petroleum products onwards to other European countries.
In addition to the new oil import restrictions, the sixth package of sanctions includes the following measures:
- Expulsion of Russia’s largest bank, Sberbank, from the SWIFT international bank messaging service, along with two smaller Russian banks, Credit Bank of Moscow and the Russian Agricultural Bank, and the Belarusian Bank for Development and Reconstruction;
- Suspension of broadcasting services in the European Union for three more Russian state-owned entities due to their dissemination of Russian propaganda, being Rossiya RTR/RTR Planeta, Rossiya 24/ Russia 24, and TV Centre International;
- Further export restrictions on dual-use goods and technology, including 80 chemicals used in the production of chemical weapons;
- Prohibition of bookkeeping, audit, tax advice, accounting services, consultancy services business and management consulting, and public relations services to the Russian government, or to other persons and entities established in Russia; and
- Additional sanctions against individuals and entities related to the Russian assault on Ukraine, including in relation to atrocities committed by Russian troops in Bucha and Mariupol.