EU's 11th Sanctions Package Cracks Down On Sanctions Circumvention

On 23 June 2023, the European Commission adopted its 11th package of sanctions targeting Russia and Belarus. The new package focuses on tackling the circumvention of trade sanctions through third countries and increasing the number of items subject to the European Union transit ban. The package also includes expansion of restrictions on the sale and export of certain goods and technology, as well as targeted sanctions against individuals and entities. Below we set out the key measures of the package.

Combatting sanctions circumvention

One critical element of this sanctions package is the introduction of a new anti-circumvention mechanism. The EU has identified that several prohibited goods are still being sold to Russia via certain third countries, undermining the effectiveness of the prohibitions and sanctions in place. In response to this ongoing issue, the EU has taken significant steps to introduce for the first time this anti-circumvention tool.