Sanctions database

Shall not apply in the case of an emergency landing or an emergency overflight.

The competent authorities may authorise an aircraft to land in, take off from, or overfly, the territory of the Union if the competent authorities have determined that such landing, take-off or overflight is required for humanitarian purposes or for any other purpose consistent with the objectives of this Regulation.

From 9 April, the EU introduced an exemption to the prohibitions relating to the aviation and space industry for aircraft financial leases. Specifically, EU Member State authorities may authorise the execution of an aircraft financial lease concluded before 26 February 2022 if strictly necessary to ensure lease re-payments to an EU legal entity that is not targeted by any other EU sanctions, and provided that no economic resources will be made available to the Russian counterparty, with the exception of the transfer of ownership of the aircraft after full reimbursement of the financial lease. (COUNCIL REGULATION (EU) 2022/576 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022R0576&from=EN; COUNCIL DECISION (CFSP) 2022/578 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32022D0578&from=EN)

The competent authorities may authorise, under such conditions as they deem appropriate, an investment participation in, or contribution to, projects co-financed by the Russian Direct Investment Fund, after having determined that such an investment participation or contribution is due under contracts concluded before 2 March 2022 or ancillary contracts necessary for the execution of such contracts,

Exceptions for:
– the personal use of individuals travelling to Russia or members of their immediate families travelling with them; or
– the official purposes of diplomatic missions, consular posts or international organisations in Russia,

Prohibition does not apply to nationals of a Member State or natural persons having a temporary or permanent residence permit in a Member State,
Prohibition also does not apply to deposits which are necessary for non-prohibited cross-border trade in goods and services between the Union and Russia.
The competent authorities may authorise the acceptance of such a deposit, under such conditions as they deem appropriate, after having determined that the acceptance of such a deposit is: (a) necessary to satisfy some excluding basic purposes (payments for food, rent or mortgage, medicines and medical treatment, taxes, insurance premiums, and public utility charges); (b) intended exclusively for the payment of reasonable professional fees or the reimbursement of incurred expenses associated with the provision of legal services; (c) necessary for extraordinary expenses; (d) necessary for official purposes of a diplomatic mission or consular post or international organisation; (e) necessary for humanitarian purposes, such as delivering or facilitating the delivery of assistance, including medical supplies, food, or the transfer of humanitarian workers and related assistance or for evacuations; (f) necessary for civil society activities that directly promote democracy, human rights or the rule of law in Russia.

Shall not apply to nationals of a Member State or natural persons having a temporary or permanent residence permit in a Member State.

Exemptions are available for:
– binding financing or financial assistance commitments established prior to 26 February 2022,
– the provision of public financing or financial assistance to SMEs established in the EU of up to the total value of EUR 10 mn per project,
– the provision of public financing or financial assistance for trade in food or for agricultural, medical and humanitarian purposes.

The prohibitions shall not apply to the sale, supply, transfer or export of goods or technology, or to the provision of technical or financial assistance, necessary for:
(a) the transport of fossil fuels, in particular coal, oil and natural gas, from or through Russia into the Union; or
(b) the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment

the competent authorities may authorise, under such conditions as they deem appropriate, the sale, supply, transfer or export of the goods and technology listed in Annex X or the provision of related technical or financial assistance, after having determined that such goods or technology or the provision of related technical or financial assistance are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment.

There are certain exceptions, including for humanitarian, medical and/or consumer purposes (subject to approvals),

There are certain exceptions, including for humanitarian, medical and/or consumer purposes (subject to approvals),