KPMG report: EU sanctions and export control regulations related to Russia

Adapted from a report prepared by the KPMG member firm in the Netherlands

Adapted from a report prepared by the KPMG member firm in the Netherlands

The European Union (EU) announced significant new sanctions and export control regulations related to Russia. These restrictions may affect companies doing business in Russia and in sanctioned regions.

First package (February 23, 2022)

  • Targeted sanctions: The EU extended the existing sanctions against Russia by including all the 351 members of the Russian State Duma and 27 high profile individuals and entities.
  • Restrictions on economic relations with the Donetsk and Luhansk regions: This concerns trade between the EU and the Donetsk and Luhansk regions, and includes an import and export ban, trade and investment restrictions, and a prohibition on the supply of tourism services.
  • Financial sanctions: The sanctions include a prohibition on financing Russia and its government.

Second package (February 25, 2022)

Individual sanctions

  • Asset freeze: The EU has frozen the assets of President Putin, the Russian Minister of Foreign Affairs, and other individuals (e.g., members of the National Security Council of the Russian Federation).

Economic sanctions

  • Financial sanctions: Further expansion of the existing financial sanctions in order to prevent Russian access to the most important capital markets
  • Energy sector: Prohibition on the sale, supply, transfer or export of specific goods (and related services) and oil refining technologies to Russia
  • Transport sector: An export ban covering goods and technology in the aviation and space industry, as well as a prohibition on the provision of insurance and reinsurance and maintenance services related to those goods and technology—including a prohibition on the provision of related technical and financial assistance
  • Technology sector: Export restrictions on exports of dual-use goods and technologies (e.g., semiconductors and other cutting-edge technologies)
  • Visa policy: Diplomats, Russian officials, and businesspeople no longer able to benefit from visa facilitation provisions allowing privileged access to the EU (ordinary Russian citizens not affected by these measures)

Third package (February 28, 2022)

  • A ban on transactions with the Russian Central Bank
  • A ban on the overflight of EU airspace and on access to EU airports by Russian carriers
  • An additional 26 persons and one entity added to the sanctions lists

Fourth package (March 2, 2022)

  • Seven Russian banks were excluded from SWIFT (Society for Worldwide Interbank Financial Telecommunication).
  • A ban was introduced on investing, participating, or otherwise contributing to future projects co-financed by the Russian Direct Investment Fund.
  • Further, selling, supplying, transferring or exporting euro banknotes to Russia or to any natural or legal person or entity in Russia is now also banned by the EU.
  • Suspension of the broadcasting activities in the EU of certain Russia media outlets.

Read a March 2022 report prepared by the KPMG member firm in the Netherlands


For more information, contact:

Doug Zuvich
Partner and Global Practice Leader
T: 312-665-1022

John L. McLoughlin
Principal and East Coast Leader
T: 267-256-2614

Andy Siciliano
Partner and National Practice Leader
T: 631-425-6057

Steve Brotherton
Principal and Global Export and Sanctions Leader
T: 415-963-7861

Luis (Lou) Abad
Principal, Washington National Tax
T: 212-954-3094

Irina Vaysfeld
T: 212-872-2973

Amie Ahanchian
T: 202-533-3247

Christopher Young
T: 312-665-3229

Gisele Belotto
T: 305-913-2779

George Zaharatos
T: 404-222-3292

Andy Doornaert
Managing Director
T: 313-230-3080

Jessica Libby
T: 612-305-5533

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