on 14 august 2025, the cyprus ministry of finance (mof) has formally determined the competent authorities which would be responsible to ensure compliance with regulation (eu) 2022/2554 on digital operational resilience for the financial sector (dora) on the basis of the regulatory administrative act 252/2025 (raa 252/2025). under the raa 252/2025, the relevant competent authorities are: a) the registrar of occupational retirement benefit funds responsible for the supervision of: occupational pension institutions b) the superintendent of insurance responsible for the supervision of: cypriot insurance and reinsurance undertakings insurance and reinsurance mediators who have cyprus as their member state cyprus mediators engaged in insurance mediation as a secondary activity c) the cyprus securities and exchange commission (cysec), responsible for the supervision of: cyprus investment firms (cifs) crypto-asset service providers (casps) licensed by cysec issuers of asset-referenced tokens (arts) licensed by cysec central securities depositories licensed by cysec central counterparties established in cyprus trading venues in cyprus cyprus alternative investment fund managers crowdfunding service providers licensed by cysec management companies licensed by cysec performance of the functions of the relevant competent authority as provided in article 19 of dora concerning central securities depositaries licensed or supervised by both cysec and the central bank of cyprus (cbc) d) the cbc responsible for the supervision of: credit institutions, including the ones providing crypto-asset services after notification to the cbc issuers of arts with reference to assets which are credit institutions trading venues of cyprus that are credit institutions payment institutions (pis), including exemptions as well as those authorised by cbc to provide crypto asset services or to issue arts. electronic money institutions (emis), including exemptions as well as emis providing crypto asset services following notification by cbc and arts that are emis. account information service providers central securities depositories licensed by cbc providing banking-type ancillary services performance of the functions of the relevant competent authority as provided in article 19 of the regulation, for entities jointly supervised with cysec these supervisory assignments ensure that every part of the financial sector in cyprus – from banks and insurers to pension funds, investment firms, and crypto providers – has a clear regulator overseeing its compliance with dora. the raa 252/2025 can be found (in greek) here

on 15 september 2025, the french (amf), austrian (fma), and italian (consob) financial authorities issued a joint letter and press release calling for critical adjustments to the mica regulation. these proposals aim to address certain gaps which the regulators state they have identified in the current framework. the press release highlights the lessons learned from the first months of mica’s implementation, with the authorities noting significant differences in how national authorities supervise crypto-asset service providers (casps) and crypto markets in general. key proposals: centralised supervision by esma for significant casps the authorities advocate for direct esma oversight of significant crypto-asset service providers (casps). this would prevent regulatory fragmentation, ensure uniform rule enforcement and reduce supervision costs, drawing inspiration from the supervisory models for significant stablecoin (emts / arts) issuers. mandatory execution of orders by eu casps on mica-compliant trading platforms or equivalent the authorities cite weaknesses of the “reverse solicitation” exemption in crypto-asset activities and the potential for non-eu platforms indirectly serving eu investors at a large scale. in addition, delegation of core functions to third-country entities should meet strict criteria, including equivalent legislation or direct esma supervision, to prevent regulatory arbitrage. mandatory cybersecurity audits under mica the authorities propose that an express requirement for casps to undergo mandatory, independent cybersecurity audits before authorisation and at regular intervals is introduced at the mica regulation level. this would address gaps in licensing and supervisory requirements by eu competent authorities, where divergent approaches have been adopted on this issue given that mica regulation does not currently include such an express requirement. centralised token offerings / listings process through esma those regulators claim that centralising token offering filings under esma would simplify processes, reduce administrative burdens, and ensure consistent application of rules across eu member states, avoiding market fragmentation. again, these regulators claim that these proposals align with international recommendations from the financial stability board (fsb) and the international organisation of securities commissions (iosco). the joint letter can be found here and the press release here

on 29 september 2025, the bermuda monetary authority (bma) published a letter to stakeholders responding to the public consultation paper entitled “proposed enhancements to public disclosure regime: public disclosure of assets and liabilities for commercial long-term insurers.” the bma has proposed updates to the public disclosure regime for bermuda-regulated commercial long-term insurers (excluding domestic insurers). key goals include improving transparency of asset disclosures and supporting informed decision-making for policyholders. key highlights: transparency vs. competitiveness: while stakeholders support transparency, concerns about revealing proprietary strategies were raised. the bma may allow modified disclosures in exceptional cases. granularity of data: detailed disclosures, including investment strategies, aim to enhance clarity. a summary sheet will simplify insights for general audiences. operational feasibility: proportionality will be considered, leveraging existing regulatory data to reduce burdens. duration metrics: effective duration will replace weighted average life for asset and liability disclosures. next steps include publishing draft rules and guidance to ensure compliance. the bma remains committed to stakeholder collaboration to finalise these enhancements. bma’s stakeholder letter can be found here

on 6 august 2025, bermuda hosted key digital finance leaders for two pivotal events: the launch of the bermuda stablecoin association (bsa) and a digital finance roundtable led by the ministry of finance. the digital finance roundtable, held at the cabinet office, brought together the bermuda monetary authority, global digital asset leaders, and local banking representatives. discussions focussed on advancing bermuda's digital finance ecosystem, addressing local banking challenges, and improving its global competitiveness. the bsa, launched by apex group and penrose partners, aims to establish industry standards for stablecoins through collaboration on compliance, technical standards, policy, and education. premier david burt emphasised bermuda's dedication to fostering a thriving digital economy, ensuring global competitiveness and empowering local businesses. these efforts solidify bermuda's commitment to regulated digital assets and stablecoin innovation. the bermuda government’s article can be found here.

on 11 july 2025, the european securities and markets authority (esma) issued a warning to investors about the risks associated with unregulated products offered by regulated crypto-asset service providers (casps). this "halo effect" can lead to confusion, as clients may mistakenly believe that all products and services offered by a regulated casp are protected under the markets in crypto-assets regulation (mica). guidance for casps: clearly communicate which entity is providing a product or service as well as the regulatory status of each product or service at every stage of the sales process and in all marketing materials and documentation. avoid using regulated status as a promotional tool for unregulated products. information on a casp’s website on unregulated activities should be clearly separated from the sections dealing with regulated activities. implement measures like pop-up disclaimers to ensure clients acknowledge the unregulated nature of certain products before proceeding. unregulated entities (whether in the same group as the casp or not) should not be able to offer services and/or products regulated or unauthorised under mica using the same interface. it is evident that the guidance also seeks to target casps belonging to global crypto-exchange groups, where it is often the case that a shared domain or interface is used for multiple entities to provide both services regulated under mica and unregulated services. esma urges investors to stay vigilant and be aware that protections under mica, such as conflict management, asset safeguarding and complaint handling, do not apply to unregulated products or services. esma’s new release can be found here and the statement here

on 4 september 2025, the court of justice of the european union (ecj) issued a pivotal judgment in case c-726/23 (sc arcomet towercranes srl v direcţia generală regională a finanţelor publice bucureşti, administraţia fiscală pentru contribuabili mijlocii bucureşti), addressing the vat implications of transfer pricing (tp) adjustments within multinational groups. this decision clarifies the vat treatment of intra-group transactions and the evidentiary requirements for vat deductions. key findings transfer pricing adjustments as vat-taxable services: the ecj ruled that remuneration calculated under the oecd’s transfer pricing guidelines, such as the transactional net margin method (tnmm), constitutes consideration for services subject to vat. the court emphasised that: services must be identifiable and economically real, even if the remuneration is structured as a tp adjustment. a direct link must exist between the services provided and the remuneration received, regardless of variability in the payment structure. right to deduct input vat: tax authorities may require additional documentation beyond invoices to verify the existence and use of services for taxable transactions. such requirements must be necessary and proportionate, ensuring compliance with articles 168 and 178 of the vat directive. implications for businesses: this decision resolves longstanding uncertainty regarding the vat treatment of tp adjustments. it underscores the importance of: properly documenting intra-group transactions to demonstrate their taxable nature. ensuring contracts clearly define the scope of services and remuneration mechanisms. businesses should review their transfer pricing and vat compliance frameworks to align with this ruling and mitigate potential risks. the ecj’s decision can be found here and here

cyprus has transposed the corporate sustainability reporting directive (csrd) into national law, marking a significant step towards enhanced corporate transparency and sustainability. the amendments to the companies law, among others, were published in the official gazette on 29 july 2025. the implementation of the csrd introduces staggered compliance dates for the different categories of companies to report information necessary to understand their sustainability impact, as well as their development, performance and position. the timeline for reporting is structured as follows: for the financial year commencing on 1 january 2025: reporting requirements will first apply to large-sized and public-interest entities already subject to the non-financial reporting directive (nfrd). for the financial year commencing on 1 january 2027: the scope expands to include all other large-sized companies and parent companies of large groups that were not previously covered. for the financial year commencing on 1 january 2028: the final date brings small and medium-sized enterprises (smes), small and non-complex institutions and designated insurance and reinsurance undertakings, listed on regulated markets into the reporting framework. the amendments to the companies law (only in greek) can be found here the non-financial reporting directive (directive 2014/95/eu) can be found here the "stop-the-clock" directive (directive eu 2025/794 can be found here

on 3 october 2025, the luxembourg government introduced draft bill no. 8628 to transpose aifmd ii (directive (eu) 2024/927) into national law. the key takeaway: luxembourg is adopting aifmd ii “as is”, without adding extra national burdens (“no gold-plating”). for aifms, this provides certainty and keeps luxembourg attractive as europe’s hub for alternative funds. extended services for aifms authorised aifms have always been able to: manage individual portfolios under mandate (discretionary portfolio management) in addition to managing aifs. under aifmd ii, the list of additional services expands further. luxembourg aifms may now also: administer benchmarks (but not those used by their own aifs). provide credit servicing under the eu credit servicers directive (2021/2167), continue ancillary services such as investment advice, safekeeping of fund units, and order transmission. this broadened scope allows aifms to capture new business opportunities, particularly in private credit and related services. delegation, substance and distribution delegation is one of the most closely watched areas of aifmd ii. the directive strengthens requirements around: documenting and justifying delegation structures and reporting; and ensuring that an aifm retains sufficient resources and cannot be reduced to a letter-box entity. for luxembourg aifms, this is not new. the cssf has long required that aifms demonstrate real substance in luxembourg, with sufficient staff, senior management, and oversight functions. the draft bill essentially codifies eu rules that luxembourg was already applying in practice, meaning there is no additional burden for local managers. luxembourg clarification reflects the aifmd: distribution by mifid ii firms or insurers under idd, acting on their own behalf, is not treated as delegation. this distinction provides certainty for aifms relying on third-party distribution channels. loan origination regime aifmd ii introduces an eu-wide regime for loan-originating aifs, and luxembourg has adopted it without additional burdens. core requirements: borrower limits: no loans to the aifm, its staff, depositary, delegates, or group companies (unless at arm’s length). consumer carve-out: no loans to natural persons (consumers) under luxembourg law. concentration: max 20 per cent of aif capital per borrower (except financial institutions that on-lend). retention: aifs must retain 5 per cent of loans originated and sold. leverage caps: 175 per cent of nav (open-ended aifs) and 300 per cent of nav (closed-ended aifs). policies: robust credit assessment, monitoring, and default management procedures are required. transitional period: existing loan funds: 5 years from entry into force to comply. new loan funds: must comply immediately. why it matters luxembourg is europe’s top centre for private credit funds. by transposing aifmd ii on a one-to-one basis, luxembourg avoids creating additional hurdles. on delegation and substance, luxembourg aifms are already operating under these standards, so no change in practice is required. the only specific national carve-out is the explicit ban on consumer lending, aligned with luxembourg commercial and consumer law. bill of law no. 8628 can be found here (only in french)

on 23 september 2025, the cyprus securities and exchange commission (cysec) issued circular c728, drawing attention to the recent amendments to article 5h of regulation (eu) 833/2014. these changes significantly expand the scope of restrictive measures against russia in response to its military aggression against ukraine. key highlights: transaction ban: a full prohibition on transactions with legal persons, entities or bodies listed in annex xiv (previously only a swift ban), including any russian entities owned by more than 50 per cent of these listed entities. the list is expansive and includes 45 russian banks. licensing grounds: certain transactions may be authorised, such as: divestment or wind-down of business activities in russia, subject to approval by competent authorities. specific transactions with bank zenit for the necessary execution of pre-2025 contracts or for the payment of essential goods. exemptions: certain transactions are exempt from the prohibition, such as: activities necessary for diplomatic and consular functions. transactions by eu nationals residing in russia before 24 february 2022. compliance reminder: cysec urges all regulated entities, including cifs, aifms, ucits managers and casps, to review and update their compliance measures, emphasising that the scope of the article 5h prohibition was changed from a prohibition to provide specialised financial messaging services (swift) to a complete transaction ban. entities are also encouraged by cysec to consult the eu’s consolidated faqs for detailed guidance on article 5h and related provisions. these measures reflect the eu’s commitment to enforcing stricter sanctions and ensuring alignment across member states. regulated entities must act promptly to harmonise their procedures with the updated requirements. cysec’s circular c728 can be accessed here and article 5h of council regulation (eu) 833/2014 here eu’s consolidated faqs can be found here

the eu advocate general's opinion in case c-483/23 sheds light on the application of the eu’s core sanctions regime under regulation 269/2014 as regards assets placed in trusts by sanctioned individuals. the case was referred to the cjeu by the regional administrative court of lazio, italy and examines whether such assets placed into a trust can still be considered "owned, held, or controlled" by the settlor and therefore subject to freezing measures. the opinion follows on from, and is largely compatible with the recent jurisprudence in this area in the english high court in eurochem v société générale which we previously issued a blog about here. key insights of the ag opinion: substance over form: the opinion emphasises that the legal structure of a trust does not necessarily sever the settlor's ties to the assets. ownership and control must be assessed based on the trust's terms and the settlor's retained powers, such as the ability to revoke the trust, appoint trustees, or influence beneficiaries. trusts and circumvention risks: the ag noted that trusts can be used “relatively easily” to avoid the freezing of economic resources and funds, which has been acknowledged by the european commission, in its russia sanctions guidance, as potentially entailing circumvention. more broadly, the opinion aligns with the eu's broader policy goal of preventing russia sanctions evasion. it underscores the need to take a systematic and purposive approach and to look beyond formal legal arrangements to the underlying factual circumstances of each trust, including the reality of control, ensuring that sanctions are not circumvented through what can be complex legal structures. offshore trusts: the trust in question, governed by bermuda law, was perceived as being flexible in nature, a feature often promoted to ensure products are appropriately tailored for family offices, but with the consequence being here that the settlor had not appropriately severed ties to the assets for the purposes of the ownership and control test in sanctions law. despite amendments to exclude the settlor as a beneficiary, the ag noted that the settlor retained significant powers, such as being able to appoint trustees and protectors, which could indicate continued control over the assets. in a nod towards offshore trusts however, the ag did state that trusts for these purposes should be reviewed and assessed through the lens of the governing or “proper” law, not the trusts law where the trust undertook business, in italy. practical challenges: while the approach is consistent with eu sanctions policy objectives, it raises challenges for firms and institutions engaging in due diligence with trusts. without clear regulatory guidance, parties are likely to adopt overly cautious stances, increasing the risk of over-compliance and litigation. for more details, read the full case analysis here.

on 10 july 2025, the european securities and markets authority (esma) published a peer review on the malta financial services authority's (mfsa) authorisation of crypto asset service providers (casps) under the markets in crypto-assets regulation (mica). the review also identifies areas for improvement, including risk assessment and resolution of material issues during authorisation. a central observation of the review was the timing of the casp authorisation issued by the mfsa, ahead of other member states and that the mfsa’s assessment process should have been more thorough. in particular, the review provides that no evidence was found on the authorisation files that certain key matters were adequately assessed by the mfsa, which esma recommends that eu national competent authorities (ncas) focus on. these include: the casp’s business plan and adequacy of resources, approaches and systems to support the business’ growth potential conflicts of interest governance and intragroup arrangements risks relating to ict infrastructure, custody, the booking model used risks relating to web 3.0 services and decentralised products, including promotion or reliance on unregulated products or services certain aml/cft matters ncas are urged to integrate these recommendations into their practices to strengthen oversight in this high-risk sector. esma’s news release can be found here and the executive summary of the peer review here.

the cyprus department of the registrar of companies and intellectual property (registrar) recently issued a set of key reminders for all companies, partnerships, and european public limited companies that are subject to reporting obligations with respect to the beneficial ownership register (bo register) in cyprus. compliance obligations: between 1 october 2025 and 31 december 2025, organisations are required to perform the following actions in the bo register system, subject to requirements: confirm the details of their beneficial owners; or confirm the details of their senior management officials; or confirm that appropriate due diligence was carried out in respect of the organisation in lieu of the above. confirmation of such details is required only once during this period, even if changes occur after submission. penalties for non-compliance: the registrar reminds companies that there is a fine of €100 for the first day of non-compliance and €50 for each additional day, up to a maximum of €5,000, separately to any applicable criminal liability. address updates: many official communications have failed due to outdated registered office and workplace addresses. organisations are urged to verify and update their address details in the register of business entities to ensure accurate records. consequences of non-compliance: failure to update beneficial ownership information or address details may result in the striking off the entity from the register of business entities. steps to confirm information in the bor system can be found in the “faqs – ubos”, under the section “confirmation of information on the ubos register” here. our previous blog posts can be found here and here. for more details, the news releases can be found here and here.

following the triggering of the snapback mechanism in august 2025 by the uk, germany and france (the e3) under the 2015 joint comprehensive plan of action (jcpoa), the un security council (unsc) has now reimposed sanctions on iran. the eu and the uk have also reimposed their own autonomous measures, which are super-equivalent to the sanctions imposed by the unsc. we provide an overview of each regime below. a. un sanctions reimposed as of 27 september 2025, the snapback reinstates six key unsc resolutions. these measures restore comprehensive restrictions and prohibitions, including: unsc 1696 (2006): targeting iran’s nuclear development by demanding a halt of its uranium enrichment program. unsc 1737 (2006): asset freezes and restrictions on nuclear-related goods. unsc 1747 (2007): an expanded arms embargo and financial restrictions. unsc 1803 (2008): call on states to exercise vigilance in providing public support for trade with iran and to also exercise vigilance over financial institutions active in iran. unsc 1835 (2008): reaffirmed existing sanctions. unsc 1929 (2010): further broadened sanctions, including a ban on ballistic missile technology and a comprehensive arms embargo. all un member states must fully implement sanctions imposed by the unsc, so these measures apply, in effect, on a global basis. b. eu autonomous measures: on 29 september 2025, the eu reinstated its own autonomous measures on iran which were in place prior to the implementation of the jcpoa through: council regulation (eu) 2025/1975, accessible here. council implementing regulation (eu) 2025/1980, accessible here. council implementing regulation (eu) 2025/1982, accessible here. the reinstated measures, amongst other things, reintroduce the following restrictions and prohibitions: financial sector: an asset freeze on the central bank of iran and other major iranian commercial banks as well as a swift ban. transfers of funds: subject to licensing requirements and exceptions, there is now a prohibition on transfers of funds between eu financial / credit institutions and credit and financial institutions or bureaux de change domiciled in iran or, in certain instances, elsewhere or their branches or subsidiaries. targeted sanctions: travel bans and asset freezes for listed individuals and entities, with a prohibition on making funds or economic resources available to them. various trade, financing, investment and services restrictions in sectors involving iranian crude oil, natural gas, petrochemical products and key energy sector equipment, precious metals, certain naval equipment and specific software. transport sector: restrictions preventing iranian cargo flights from accessing eu airports and a prohibition on the maintenance of vessels and aircraft carrying prohibited goods. other restrictions: prohibitions relating to transactions in iranian government bonds and others. c. uk autonomous measures: concurrently with the eu, the uk has also reinstated sanctions on iran through the iran (sanctions) (nuclear) (eu exit) (amendment) regulations 2025, see here, amending the iran (sanctions) (nuclear) (eu exit) regulations 2019. the amendments entail sanctions on individuals and entities. they target 71 individuals and organisations linked to iran’s nuclear programme, including major financial institutions and energy companies, including asset freezes, director disqualifications and travel bans. currently, the uk government has not yet reinstated sectoral sanctions on iran, at the same scale as the eu regime. however, it has stated its intention to introduce additional measures in due course, focusing on key sectors including finance, energy, shipping, and software. in addition, for the purposes of supporting the structured completion of prior transactions, the office of financial sanctions implementation (ofsi) has issued four general licences authorising, subject to certain conditions, the following activities for a limited period of time: the wind down of transaction with specified uk-based iranian banks, accessible here. the wind down of transactions with certain iranian banks established both inside and outside iran, accessible here. the wind down or divestment of transactions involving the iran insurance company and the national iranian oil company, international affairs ltd, accessible here. the continued provision of goods, services and financing regarding the shah deniz gas project, accessible here. finally, ofsi also published faq 168 to clarify that all specific licences issued by hm treasury under the un regime prior to 2015 have ceased to have effect upon the designated person being delisted and new ofsi licence applications should be made where needed. see here. d. eu and uk blocking regulations remain in force although the us welcomed the activation of the snapback mechanism, the eu and uk blocking regulations in relation to iran (and cuba) currently remain in place to counter the extraterritorial effect of us secondary sanctions. it remains to be seen whether the eu and uk will scale back the blocking effect of the eu and uk blocking regulations in the coming weeks. for more details, refer to the council of the eu’s press release here and the uk government’s press releases here and here

further to our blog post on eu russia sanctions, please find below an updated table of sanctions. table.instrument-table { table-layout: auto; border-collapse: collapse; width: 100%; max-width: 100%; margin-left: auto; margin-right: auto; margin-bottom: 10px; border: 1px solid #000000; overflow-x: auto; } table.instrument-table th, table.instrument-table td { border: 1px solid #000000; padding: 5px; vertical-align: top; } table.instrument-table thead tr { color: #ffffff; background-color: #3a5dae; } table.instrument-table tbody tr:nth-child(even) { background-color: #f1f1f1; /* light grey */ } table.instrument-table h5 { font-size: 1.15em; margin: 0; } table.instrument-table p { font-size: 14px; color: #000000; margin: 0; line-height: 1.6; } table.instrument-table a { color: inherit; text-decoration: underline; } table.instrument-table li { font-size: 14px; color: #000000; padding-top: 2px; line-height: 1.6; } name of instrument date published amends or implements? comes into force summary of key provisions council regulation (eu) 2022/259 23 february 2022 regulation (eu) no 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (regulation 269) on publication date but with reference to 24 august 2022 new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. council implementing regulation (eu) 2022/260 23 february 2022 regulation 269 on publication date addition of 22 russian government figures/individuals and four entities added to the asset freeze list under regulation 269, related to the recognition by russia of donetsk and luhansk breakaway republics. council implementing regulation (eu) 2022/261 23 february 2022 regulation 269 on publication date addition of 336 members of the russian state duma to the asset freeze list under regulation 269, related to the vote on recognition of the breakaway republics. council decision (cfsp) 2022/265 23 february 2022 decision 2014/145/cfsp concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of ukraine (decision 145) on publication date new licensing safe-harbour relating to terminating pre-existing business with certain banks by 24 august 2022. addition of 22 russian government figures/individuals and four entities added to the asset freeze list under decision 145, related to the recognition by russia of donetsk and luhansk breakaway republics. council decision (cfsp) 2022/267 23 february 2022 decision 145 on publication date addition of 336 members of the russian state duma to the asset freeze list under decision 145, related to the vote on recognition of the breakaway republics. council regulation (eu) 2022/262 23 february 2022 regulation (eu) no 833/2014 concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (regulation 833) on publication date but with reference to 9 march 2022 new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council decision (cfsp) 2022/264 23 february 2022 decision 2014/512/cfsp concerning restrictive measures in view of russia’s actions destabilising the situation in ukraine (decision 512) on publication date new article 5a. prohibition to deal with transferable securities and money-market instruments issued after 9 march 2022 by (a) russia and its government; or (b) the central bank of russia. expansion of anti-circumvention and related provisions. note: not the same as the central bank sanctions issued on 28 february 2022. see below. council regulation (eu) 2022/263 concerning restrictive measures in response to the recognition of the non-government controlled areas of the donetsk and luhansk oblasts of ukraine and the ordering of russian armed forces into those areas 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. luhansk/donetsk embargo. council decision (cfsp) 2022/266 concerning restrictive measures in response to the recognition of the non-government controlled areas of the donetsk and luhansk oblasts of ukraine and the ordering of russian armed forces into those areas 23 february 2022 n/a. new measure on day following publication date imposes an embargo over any dealings with the breakaway republics and any industries within them. similar to the crimea embargo sanctions. council implementing regulation (eu) 2022/300 (regulation 300) 24 february 2022 regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus (regulation 765) on day following publication date implementing article 8a of regulation (ec) no 765/2006 concerning restrictive measures in view of the situation in belarus. some changes to reasoning of designation. not directly relevant to russia-ukraine conflict but contemporaneous with it. council decision (cfsp) 2022/307 24 february 2022 decision 2012/642/cfsp concerning restrictive measures in view of the situation in belarus (decision 642) on day following publication date materially equivalent to measures referred to in regulation 300. not directly relevant to russia-ukraine conflict but contemporaneous with it. decision (eu) 2022/313 of the european parliament and of the council of 24 february 2022 providing macro-financial assistance to ukraine 24 february 2022 n/a. new measure on day following publication date provision of macro-financial assistance to support ukraine’s commitment to values shared with the eu, including democracy, the rule of law, good governance, respect for human rights, sustainable development and poverty reduction, as well as its commitment to the principles of open, rule-based and fair trade. not directly relevant to russia-ukraine conflict but contemporaneous with it. council regulation (eu) 2022/328 (regulation 328) 25 february 2022 regulation 833 on day following publication date, however many measure come into force from 12 april 2022 imposition of numerous restrictive measures in various sectors of the russian economy, specifically defence, energy, aviation and finance. restrictions and prohibitions on: exports of dual-use goods and technology and on the provision of related services, as well as restrictions on exports of certain goods and technology which might contribute to russia’s technological enhancement of its defence and security sector (articles 2, 2a, 2b, 2c) the provision of public financing or financial assistance for trade with, or investment in, russia, subject to certain exceptions (article 2e) the sale, supply, transfer or export to russia of specific goods and technologies for use in oil refining, together with restrictions on the provision of related services (article 3b) export ban covering goods and technology suited for use in aviation and the space industry and prohibits the provision of insurance and reinsurance and maintenance services in relation to those goods and technology (article 3c) expanding the existing financial restrictions, in particular those on access by certain russian entities to the capital markets – including elimination of maturity periods for debt issued after 12 april 2022 (article 5) addition of new annex xii (now includes alfa bank and otkritie bank) the listing and provision of services in relation to shares of russian state-owned entities on union trading venues (article 5(5)) the acceptance of deposits exceeding certain values from russian nationals or residents (article 5b), the holding of accounts of russian clients by eu based central securities depositories (article 5e) as well as the sale of euro-denominated securities to russian clients (article 5e) bank account reporting requirements where eu bank accounts hold in excess of €100,000 (article 5g) council decision (cfsp) 2022/327 25 february 2022 decision 512 on day following publication date, however many measure come into force from 12 april 2022 equivalent to those listed under regulation 328. council regulation (eu) 2022/330 25 february 2022 regulation 269 on publication date recasting and expanding designation criteria for asset freeze under regulation 269. council decision (cfsp) 2022/329 25 february 2022 decision 145 on publication date recasting and expanding designation criteria to include persons and entities supporting and benefitting from the government of the russian federation as well as persons and entities providing a substantial source of revenue to it, and natural or legal persons associated with listed persons or entities. council implementing regulation (eu) 2022/332 (regulation 332) 25 february 2022 regulation 269 on publication date addition of: members of the russian national security council who supported russia's immediate recognition of the two self-proclaimed republics donetsk and luhansk persons who facilitated the russian military aggression from belarus, as well as those members of the state duma not yet included in that list who ratified the government decisions of the 'treaty of friendship, cooperation and mutual assistance between the russian federation and the donetsk people's republic and between the russian federation and the luhansk people's republic comprises 98 new individuals including president vladimir putin and minister of foreign affairs sergei lavrov. council decision (cfsp) 2022/331 25 february 2022 decision 145 on publication date measures equivalent to those in regulation 332. council decision (eu) 2022/333 on the partial suspension of the application of the agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia 25 february 2022 2007 agreement between the ec and russia on the facilitation of the issuance of visas to the citizens of the eu and russia (2007 visa agreement) on publication date suspends application of 2007 visa agreement, including as relevant to business people and representatives of business organisations. council regulation (eu) 2022/334 28 february 2022 regulation 833 on publication date prohibition for any aircraft operated by russian air carriers, including as a marketing carrier in codesharing or blocked-space arrangements, or for any russian registered aircraft, or for any non-russian-registered aircraft which is owned or chartered, or otherwise controlled by any russian natural or legal person, entity or body, to land in, take off from or overfly the territory of the eu (article 3d). prohibition on transactions related to the management of reserves as well as of assets of the central bank of russia, including transactions with any legal person, entity or body acting on behalf of, or at the direction of, the central bank of russia, are prohibited (article 5a(4)). council decision (cfsp) 2022/335 28 february 2022 decision 512 on publication date prohibition of any transactions with the central bank of russia. russia central bank asset freeze (article 1a). denial of permission to land in, take off from, or overfly, their territories to any aircraft operated by russian air carriers, including as a marketing carrier, to any russian-registered aircraft, and to non-russian-registered aircraft which are owned or chartered, or otherwise controlled by a russian legal or natural person (article 4e). council decision (cfsp) 2022/338 on an assistance measure under the european peace facility for the supply to the ukrainian armed forces of military equipment, and platforms, designed to deliver lethal force 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 establishment of an assistance measure benefitting ukraine financed under the european peace facility (epf). the objective of the assistance measure is to contribute to strengthening the capabilities and resilience of the ukrainian armed forces to defend the territorial integrity and sovereignty of ukraine and protect the civilian population against the ongoing military aggression. provides for a centralised budget framework and reporting coordination between ministries of defence of the eu member states. council decision (cfsp) 2022/339 on an assistance measure under the european peace facility to support the ukrainian armed forces 28 february 2022 n/a. new measure retroactive effect from 1 january 2022 provision of assistance measures calling for contributions up to €50,000,000. the funds called by the administrator for assistance measures to be used to pay expenditure within the limits approved by the committee established by decision (cfsp) 2021/509 in the 2022 amending budget corresponding to the assistance measure. council implementing regulation (eu) 2022/336 28 february 2022 regulation 269 on publication date addition of: numerous ultra-high net worth russian businessmen (oligarchs) including igor sechin, chief executive of rosneft oil co. alexey mordashov, the majority owner of steel giant severstal pao alisher usmanov mikhail fridman and petr aven, founders of alfa bank the measures also target key kremlin officials including dimitry peskov, vladimir putin’s press secretary; several journalists the eu accuses of anti-ukrainian propaganda; and military officers council decision (cfsp) 2022/337 28 february 2022 regulation 269 on publication date measures equivalent to those in regulation 336. council regulation (eu) 2022/345 1 march 2022 regulation 833 on publication date imposing further restrictive measures with regard to the provision of specialised financial messaging services to certain russian credit institutions and their russian subsidiaries, which are relevant for the russian financial system and which are already the subject of restrictive measures imposed by the union or by partner countries and, subject to certain exceptions, with regard to engagement with the russian direct investment fund. it also prohibits, subject to certain exceptions, the supply of euro banknotes to russia. these measures fall within the scope of the treaty and, therefore, in particular with a view to ensuring their uniform application in all member states, regulatory action at the level of the union is necessary. council decision (cfsp) 2022/346 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 345. council regulation (eu) 2022/350 1 march 2022 regulation 833 on publication date prohibition on the broadcasting and the facilitation of broadcasting by the following media outlets, including through transmission/distribution by any means such as cable, satellite, ip-tv, internet service providers, internet video-sharing platforms or apps: sputnik rt – russia today english rt – russia today uk rt – russia today germany rt – russia today france rt – russia today spanish these measures also suspend any broadcasting licence, authorisation or arrangement with the above entities. council decision (cfsp) 2022/351 1 march 2022 decision 512 on publication date measures equivalent to those in regulation 350. council regulation (eu) 2022/353 2 march 2022 regulation 269 on publication date addition of 22 belarusian individuals to the asset freeze list under regulation 269. council decision (cfsp) 2022/354 2 march 2022 decision 145 on publication date equivalent to those listed under regulation 353 above. council regulation (eu) 2022/355 2 march 2022 regulation 765 on publication date renames the regulation 765 to refer expressly to the fact that these measures relate also to the involvement of belarus in the russian aggression against ukraine. introduces extensive new prohibitions with respect to dealing with belarus, some of these equivalent to the prohibitions introduced on russia under regulation 328 (eg in relation to dual-use goods and technology, goods and technology which might contribute to belarus’s military and technological enhancement), as well as a number of prohibitions with respect to wood, cement, iron, steel and rubber products and specific machinery as listed in the regulation. council decision (cfsp) 2022/356 2 march 2022 decision 642 on publication date equivalent to those listed under regulation 356 above. council implementing regulation (eu) 2022/375 4 march 2022 (but dated 3 march) regulation (eu) no 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date update following a review by the council, on the rights of defence and effective judicial protection on individuals charged with the misappropriation of ukrainian state funds, including former ukrainian president yanukovych (now thought to be in hiding in russia). council decision (cfsp) 2022/376 4 march 2022 (but dated 3 march) decision 2014/119/cfsp concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in ukraine on publication date equivalent to those listed under implementing regulation 375 above. council implementing regulation (eu) 2022/396 9 march 2022 regulation 269 on publication date adds a further 160 persons to the asset freeze list under regulation 269, including persons owning or holding senior management positions or otherwise connected to prominent russian businesses considered to support the russian government, as well as a number of persons of the federation council who ratified the government decisions to recognise the declaration of independence of the donetsk and luhansk regions. council decision (cfsp) 2022/397 9 march 2022 decision 145 on publication date equivalent to those listed under implementing regulation 397 above. council regulation (eu) 2022/394 9 march 2022 regulation 833 on publication date extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets”. this regulation also introduces a new prohibitions in relation to maritime navigation goods and technology to any natural or legal person, entity or body in russia, for use in russia, or for the placing on board of a russian-flagged vessel. council decision (cfsp) 2022/395 9 march 2022 decision 512 on publication date equivalent to those listed under regulation 394 above. council regulation (eu) 2022/398 9 march 2022 regulation 765 on publication date expands the existing financial restrictions under the belarus sanctions to include prohibitions similar to those already included under regulation 833 on russia. in particular, it prohibits the listing and provision of services in relation to shares of belarusian state-owned entities on eu trading venues. in addition, it introduces new measures which significantly limit the financial inflows from belarus to the union by prohibiting the acceptance of deposits exceeding certain values from belarusian nationals or residents, the holding of accounts of belarusian clients by the eu central securities depositories as well as the selling of euro-denominated securities to belarusian clients. it also prohibits transactions with the central bank of belarus related to the management of reserves or assets, the provision of public financing for trade with and investment in belarus, with limited exceptions, and the provision of euro denominated banknotes to belarus or for use in belarus it also imposes further restrictive measures with regard to the provision of specialised financial messaging services to certain belarusian credit institutions and their belarusian subsidiaries, which are relevant for the belarusian financial system and which are already the subject of restrictive measures imposed by the union it also extends the definition of transferable securities to include such classes of securities “including in the form of crypto-assets” this also adds obligations on the network manager for air traffic management network functions of the single european sky regarding overflight prohibitions and amend the provisions on non-circumvention council decision (cfsp) 2022/399 9 march 2022 decision 642 on publication date equivalent to those listed under regulation 398 above. council regulation (eu) 2022/408 11 march 2022 regulation 269 on publication date amends the information concerning 37 individuals and six entities already included under regulation 269. council decision (cfsp) 2022/411 11 march 2022 decision 145 on publication date equivalent to those listed under regulation 408 above. council regulation (eu) 2022/427 15 march 2022 regulation 269 on publication date adds a further 15 individuals and 9 entities to the asset freeze list under regulation 269, including among others prominent figures such as roman abramovich. council regulation (eu) 2022/428 15 march 2022 regulation 833 on publication date introduces further sectoral restrictive measures, as follows: prohibits all transactions with certain state-owned companies prohibit the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities, to any russian person or entity tightens export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, and expands the list of persons connected to russia’s defence and industrial base, which are subject to those restrictions prohibits new investments in the russian energy sector, and introduces a comprehensive export restriction on equipment, technology and services for the energy industry in russia, with the exception of nuclear industry and the downstream sector of energy transport introduces further trade restrictions concerning iron and steel, as well as on luxury goods council decision (cfsp) 2022/429 15 march 2022 decision 145 on publication date equivalent to those listed under regulation 427 above. council decision (cfsp) 2022/430 15 march 2022 decision 512 on publication date equivalent to those listed under regulation 428 above. council regulation (eu) 2022/580 8 april 2022 regulation 269 on publication date expands the provisions of article 6b of regulation 269 to provide for further grounds for persons to apply for a licence to be exempted from the asset freeze restrictions. in particular, the amendments introduce: as relevant to the latest russian banks addedto the asset freeze list (i.e. vtb, otkritie, novikombank and sovcombank), the possibility to apply for a licence for those entities to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to those entities, for the purposes of termination by 9 october 2022 of operations, contracts, or other agreements, including correspondent banking relations, concluded with those entities before 8 april 2022 as relevant generally to persons included on the asset freeze list, the possibility to apply for a licence for such asset frozen persons to use frozen funds or economic resources or otherwise to make available certain funds or economic resources to such persons, provided that the relevant competent authority is able to determine that: the funds or economic resources are necessary for the sale and transfer by 9 october 2022 of proprietary rights in a legal person, entity or body established in the union where those proprietary rights are directly or indirectly owned by a natural or legal person, entity or body listed in annex i the proceeds of such sale and transfer remain frozen council implementing regulation (eu) 2022/581 8 april 2022 regulation 269 on publication date adds a further 216 individuals and 18 entities to the asset freeze list, notably including four russian banks (vtb, otkritie, novikombank and sovcombank) as well as further high profile russian government officials and businessmen. council decision (cfsp) 2022/582 8 april 2022 decision 145 on publication date equivalent to those listed under regulation 581 above. council regulation (eu) 2022/576 8 april 2022 regulation 833 on publication date introduces further sectoral prohibitions, as follows: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector introduces additional import restrictions on certain goods from russia, in particular on coal and other solid fossil fuels introduces further export restrictions to russia, in particular on jet fuel and other goods prohibits the award and continued execution of public contracts and concessions with russian nationals and entities or bodies established in russia imposes a prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to russian publicly owned or controlled entities extends the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of the member states extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for the purchase, import or transport of fossil fuels and certain minerals into switzerland, the eea and the western balkans extends the exemptions from the prohibition on transaction with certain russian state-owned enterprises and their subsidiaries to countries in the european economic area and switzerland as well as to the western balkans introduces a prohibition for road transport undertakings established in russia to transport goods by road in the eu prohibits access to ports to vessels registered under the flag of russia notably, introduces a prohibition on acting as a trustee or in similar capacities for russian persons and entities, as well as a prohibition on providing certain services to trusts council regulation (eu) 2022/577 8 april 2022 regulation 765 on publication date introduces further sectoral prohibitions, as follows: imposes further restrictive measures prohibiting the sale to belarus of transferable securities denominated in any official currency of a member state, and prohibiting the sale, supply, transfer or export to belarus of banknotes denominated in any official currency of a member state imposes further restrictive measures prohibiting road transport undertakings established in belarus from transporting goods by road within the territory of the european union council decision (cfsp) 2022/578 8 april 2022 decision 512 on publication date equivalent to those listed under regulation 576 above. council decision (cfsp) 2022/579 8 april 2022 decision 642 on publication date equivalent to those listed under regulation 577 above. council regulation (eu) 2022/625 13 april 2022 regulation 269 on publication date adds exceptions to the freezing of the assets of, and the restrictions on making funds and economic resources available to, designated persons, entities and bodies for certain clearly defined categories of bodies, persons, entities, organisations and agencies for exclusively humanitarian purposes in ukraine. council decision (cfsp) 2022/627 13 april 2022 decision 145 on publication date equivalent to those listed under regulation 625 above. council regulation (eu) 2022/626 13 april 2022 regulation 263 on publication date adds exceptions that allow clearly defined categories of bodies, persons, entities, organisations and agencies to provide goods and technology for use in certain sectors, as well as certain restricted services and assistance related to such goods and technology, to persons, entities and bodies in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine or for use in those areas, where necessary for humanitarian purposes. similarly, the exceptions allow for the provision of specific restricted services and assistance directly relating to certain infrastructure in the non-government-controlled areas of the donetsk and luhansk oblasts of ukraine, where necessary for humanitarian purposes. luhansk/donetsk embargo. council decision (cfsp) 2022/628 13 april 2022 decision 266 on publication date equivalent to those listed under regulation 626 above. council regulation (eu) 2022/658 21 april 2022 regulation 269 on publication date adds a further two individuals to the asset freeze list. council decision (cfsp) 2022/660 21 april 2022 decision 145 on publication date equivalent to those listed under regulation 658 above. council regulation (eu) 2022/876 3 june 2022 regulation 765 on publication date adds a further two individuals and eight entities should be included in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 (belarussian asset freeze list). council regulation (eu) 2022/877 3 june 2022 regulation 765 on publication date expands the list of entities subject to restrictions with regard to authorisations for the sale, supply, transfer or export of dual-use goods and technology, and goods and technology which might contribute to belarus’s military and technological enhancement, or to the development of its defence and security sector. this amendment also expands the list of belarusian credit institutions and their belarusian subsidiaries subject to a swift ban. it also includes provisions clarifying and strengthening the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements council regulation (eu) 2022/878 3 june 2022 regulation 269 on publication date adds a further 65 individuals and 18 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 269 (russian asset freeze list). council regulation (eu) 2022/879 3 june 2022 regulation 833 on publication date this is the key legal instrument introducing the new sectoral prohibitions under the sixth package. the new prohibitions consist of: oil imports: introduction of an embargo on the import of crude oil and refined oil products from russia, with a programme to gradually phase out russian oil imports. these provisions include temporary exemptions for certain cases where member states are heavily dependent on russian oil oil transport services: after a wind down period of 6 months, eu operators will be prohibited from insuring and financing the transport, in particular through maritime routes, of oil to third countries financial services: an additional three russian banks, including russia's largest bank sberbank, have been removed from swift business services: the deadline for winding down certain prohibited trust services has been extended to 5 july 2022 and those provisions have been further refined. this latest package also introduces a prohibition on the provision to the russian government, as well as to legal persons, entities or bodies established in russia of certain business-relevant services such as accounting, auditing, statutory audit, bookkeeping and tax consulting services, business and management consulting, and public relations services broadcasting suspension: the broadcasting activities of rossiya rtr/rtr planeta, rossiya 24/russia 24, and tv centre international – have been suspended. the advertising of products or services on sanctioned outlets has also been prohibited export restrictions: the list of advanced technology items banned from export to russia has been expanded to include additional chemicals that could be used in the process of manufacture of chemical weapons penalties: this amendment also clarifies and strengthen the provisions on national penalties for the breach of the sanctions under regulation 833 council regulation (eu) 2022/880 3 june 2022 regulation 269 on publication date introduces further derogation options from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities. this amendment also clarifies and strengthens the provisions on national penalties for the breach of the measures under regulation 269, namely including provisions for member states to introduce in their national regimes criminal penalties for the breach of sanctions and further to introduce appropriate measures for confiscation of the proceeds of such infringements. council decision (cfsp) 2022/881 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 876 above. council decision (cfsp) 2022/882 3 june 2022 decision 642 on publication date equivalent to those listed under regulation 877 above. council decision (cfsp) 2022/883 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 878 above. council decision (cfsp) 2022/884 3 june 2022 decision 512 on publication date equivalent to those listed under regulation 879 above. council decision (cfsp) 2022/885 3 june 2022 decision 145 on publication date equivalent to those listed under regulation 880 above. regulation (eu) 2022/1280 of the european parliament and of the council 18 july 2022 n/a. new measure on publication date laying down specific and temporary measures, in view of russia’s invasion of ukraine, concerning driver documents issued by ukraine in accordance with its legislation. council regulation (eu) 2022/1269 (regulation 1269) 21 july 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends the list of controlled items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector imposes a prohibition on the direct or indirect import, purchase or transfer of gold, which constitutes russia’s most significant export after energy extends the port access ban to locks allows, the sharing of technical assistance with russia in relation to aviation goods and technology to safeguard the technical industrial standard setting process of the international civil aviation organization (icao) introduces an exemption from the prohibition to enter into any transactions with russian public entities necessary to ensure access to judicial, administrative or arbitral proceedings harmonises the notification requirements for national competent authorities granting authorisations pursuant to derogations provided expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities extends the exemption from the prohibition to engage in transactions with certain state-owned entities as regards transactions for agricultural products and the supply of oil and petroleum products to third countries this regulation also includes clarifications that the measures in regulation 833 do not prevent third countries and their nationals from trading with russia or trading in russian goods. council implementing regulation (eu) 2022/1270 21 july 2022 regulation 269 on publication date adds a further 48 persons and 9 entities to the asset freeze list under regulation 269, most notably sberbank which to date had not been listed. council decision (cfsp) 2022/1271 21 july 2022 decision 512 on publication date equivalent to those listed under regulation 1269 (amending regulation 833) above. council regulation (eu) 2022/1273 (regulation 1273) 21 july 2022 regulation 269 on publication date introduces a number of derogations to the asset freeze provisions of regulation 269: further derogation from the asset freeze and the prohibition to make funds and economic resources available to designated persons and entities in order to urgently prevent or mitigate an event likely to have a serious and significant impact on human health and safety or the environment derogation from the asset freeze and the prohibition to make funds and economic resources available to the key designated russian banks (being bank rossiya, promsvyazbnak, vnesheconombank (veb), otkiritie, novikombank, sovcombank, vtb bank and sberbank derogation from the asset freeze and the prohibition to make funds and economic resources available for the orderly wind-down of operations, including correspondent banking relations with respect to sberbank it additionally introduces requirements on designated persons and entities to report assets held within a member state and further strengthens the reporting obligations on eu operators to prevent breaches and circumvention of the asset freeze. council decision (cfsp) 2022/1272 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1273 (amending regulation 269) above. council implementing regulation (eu) 2022/1274 (regulation 1274) 21 july 2022 regulation 269 on publication date imposes an asset freeze on six individuals and one entity related to syrian regime involved in the recruitment of syrian mercenaries to fight in ukraine alongside russian troops. council decision (cfsp) 2022/1276 21 july 2022 decision 145 on publication date equivalent to those listed under regulation 1274 above. regulation (eu) 2022/1278 of the european parliament and of the council 22 july 2022 regulation 508 on publication date introduces measures to mitigate the impact of russia’s war of aggression against ukraine on the fishery and aquaculture sector. council implementing regulation (eu) 2022/1354 (regulation 1354) 4 august 2022 regulation 269 on publication date added two further individuals to the asset freeze list: oleksandr viktorovych yanukovych viktor fedorovych yanukovych council decision (cfsp) 2022/1355 4 august 2022 decision 145 on publication date equivalent to those listed under regulation 1354 above. council decision (cfsp) 2022/1355 (regulation 1446) 1 september 2022 regulation 269 on publication date added three further individuals to the asset freeze list. council decision (cfsp) 2022/1355 1 september 2022 decision 145 on publication date equivalent to those listed under regulation 1446 above. council regulation (eu) 2022/1903 (regulation 1903) 6 october 2022 regulation 263 on publication date extends the geographical scope of the restrictions to cover all the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia. council decision (cfsp) 2022/1908 6 october 2022 decision 266 on publication date equivalent to those listed under regulation 1903 above. council regulation (eu) 2022/1904 (regulation 1904) 6 october 2022 regulation 833 on publication date introduces the following additional provisions to regulation 833: extends the list of restricted items which might contribute to the russian federation’s military and technological enhancement or to the development of its defence and security sector prohibits the sale, supply, transfer or export of firearms, their parts and essential components and ammunition extends the import ban on steel products and imposes import and export prohibitions on further products originating from russia (such as woodpulp, paper and certain elements used in the jewellery industry such as stones and precious metals, among others) as well imposing restrictions on the sale, supply, transfer or export of additional goods used in the aviation sector introduces an exemption from the prohibition to provide technical assistance, brokering services, financing or financial assistance regarding maritime transport to third countries of crude oil or petroleum products which originate or are exported from russia, purchased at or below a pre-established price cap implements various provisions in connection with the introduction of a price cap as agreed by the price cap coalition expands the prohibitions related to the provision of services for the maritime transport of crude oil and certain petroleum products to third countries, to further prohibit the maritime transport of such goods to third countries, subject to implementation of the price cap expands the prohibition to engage in any transaction with certain russian state-owned or controlled legal persons, entities or bodies by including a ban on union nationals to hold any posts on the governing bodies of those legal persons, entities or bodies adds to the list of russian state-owned or controlled entities that are subject to the transaction ban of the russian maritime register of shipping; extends the port access and lock ban in the territory of the union to vessels certified by the russian maritime register of shipping bans the provision on crypto-asset wallet account or custody services, regardless of the total value of crypto assets extends the prohibition on the provision of certain services to the russian federation by including architectural, engineering, it consultancy and legal advisory services council decision (cfsp) 2022/1909 6 october 2022 decision 512 on publication date equivalent to those listed under regulation 1904 above. council regulation (eu) 2022/1905 (regulation 1905) 6 october 2022 regulation 269 on publication date introduced a further criterion for the listing of natural or legal persons, entities or bodies subject to asset freeze and the prohibition to make funds and economic resources available to designated persons and entities, allowing persons identified to facilitate infringements of the prohibition against circumvention of the provisions of regulation 269, to also be listed. it additionally introduces further derogations from the asset freeze and the prohibition to make funds or economic resources available and introduces additional provisions regarding member states’ obligations regarding the granting of derogations. council implementing regulation (eu) 2022/1906 (regulation 1906) 6 october 2022 regulation 269 on publication date adds a further 30 persons and 7 entities to the asset freeze list under regulation 269. council decision (cfsp) 2022/1907 6 october 2022 decision 145 on publication date equivalent to those listed under regulation 1905 and regulation 1906 above. council implementing regulation (eu) 2022/1985 (regulation 1985) 20 october 2022 regulation 269 on publication date adds 3 iranian persons and 1 entity to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/1986 20 october 2022 decision 145 on publication date equivalent to those listed under regulation 1985 above. council implementing regulation (eu) 2022/2229 (regulation 2229) 14 november 2022 regulation 269 on publication date adds 2 iranian individuals and 2 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2233 14 november 2022 decision 145 on publication date equivalent to those listed under regulation 2229 above. council regulation (eu) 2022/2367 (regulation 2367) 3 december 2022 regulation 833 on publication date establishes the price cap, which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. clarifies the existing prohibition on the trading and brokering of russian crude oil and petroleum products and extends the price cap exemption when such goods are traded at or below the price cap. extends the transition period applicable to the transport of crude oil and certain petroleum products after every subsequent change in the price cap for a period of 90 days to the provision, directly or indirectly, of technical assistance, brokering services or financing or financial assistance, related to the transport, subject to the same conditions, to ensure consistent implementation of the price cap by all operators. introduces a transitional period of 45 days for vessels carrying crude oil originating in russia, which was purchased and loaded onto the vessel prior to 5 december 2022 and unloaded at the final port of destination prior to 19 january 2023. clarifies that the prohibition to provide services related to the transport of russian crude oil or petroleum products by a third country flagged vessel applies in relation to vessels which in the past transported such goods purchased above the price cap, provided the operator responsible for that transport knew or had reasonable cause to suspect that this was the case. introduces an exemption from the prohibitions of providing maritime transport and technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries where 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, or as a response to natural disasters. introduces a regular review of the price cap mechanism as of mid-january 2023 and every two months thereafter. such review needs to take into account the objectives of the price cap, including its ability to reduce russia’s oil revenues, as well as the principle that the price cap should be at least 5% below the average market price for russian oil and petroleum products. commission implementing regulation (eu) 2022/2368 (regulation 2368) 3 december 2022 regulation 833 on publication date introduces the price cap (usd 60 / barrel) which is the price per barrel at or below which crude oil from russia is exempt from the prohibition to provide maritime transport and the prohibition to provide technical assistance, brokering services or financing or financial assistance, related to the maritime transport to third countries. council decision (cfsp) 2022/2369 3 december 2022 decision 512 on publication date equivalent to those listed under regulations 2367 and 2368 above. council implementing regulation (eu) 2022/ 2430 (regulation 2430) 12 december 2022 regulation 269 on publication date adds 4 iranian individuals and 4 entities to the asset freeze list under regulation 269 due to their involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2022/2432 12 december 2022 decision 145 on publication date equivalent to those listed under regulation 2430 above. council regulation (eu) 2022/2474 (regulation 2474) 16 december 2022 regulation 833 on publication date extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding drone engines, further chemical and biological equipment, riot control agents and electronic components. expands the list of entities connected to russia’s military and industrial complex, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed by adding 168 new entities. extends the suspension of the broadcasting licences in the union of certain russian media outlets. furthers the already existing prohibition targeting new investments in the russian energy sector by additionally prohibiting new investments in the russian mining sector, with the exception of mining and quarrying activities involving certain critical raw materials. expands the export ban covering goods and technology suited for use in aviation and the space industry to include aircraft engines and their parts. introduces a derogation allowing the provision of technical assistance related to the use of goods and technology suited for use in aviation or the space industry, when this is necessary to avoid collision between satellites, or their unintended re-entry into the atmosphere. introduces a possibility for the national competent authorities to grant derogations to allow for certain aviation goods, which are also widely used in the medical field, to be exported for medical, pharmaceutical and humanitarian purposes. extends the list of goods which could contribute to the enhancement of russian industrial capacities by including such items as generators, toy drones, laptops, hard drives, it components, night-vision and radio-navigation equipment, cameras and lenses. extends for an additional six months the exemption applicable to the imports of methanol originating in or exported from russia. clarifies that, as is the case for the member states importing russian crude oil by pipeline, bulgaria cannot sell petroleum products obtained from russian crude oil imported on the basis of that derogation to buyers located in other member states or in third countries. bunkering or refuelling of a vehicle or aircraft in the member states which benefit from those derogations does not fall under that prohibition. allows hungary, slovakia and bulgaria to export to ukraine certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question, including, when necessary, by transiting through other member states. allows bulgaria to export to third countries certain refined petroleum products obtained from russian crude oil imported on the basis of the derogations in question. introduces a reporting obligation for the operators engaged in transactions concerning natural gas condensate from lng productions plants. adds the russian regional development bank to the list of russian state-owned or controlled entities that are subject to the transaction ban. bans union nationals from holding any posts on the governing bodies of all russian state-owned or controlled legal persons, entities or bodies that are established in russia, subject to certain derogations. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. introduces a temporary derogation from the import and export prohibitions, by enabling the sale, supply or transfer of such goods, or their import into the union until 30 september 2023 and applies only to those goods that were already physically located in russia at the time when the relevant prohibitions entered into force. aligns the member states’ reporting obligation on deposits exceeding eur 100 000 from legal persons, entities or bodies established in third countries and majority-owned by russian nationals or natural persons residing in russia, with the similar obligations that already exist for the other types of deposits. extends the existing prohibition on the provision of certain services to the russian federation and to legal persons, entities or bodies established in russia by banning the provision of advertising, market research and public opinion polling services, as well as product testing and technical inspection services. further clarifies and amends the exemptions to the import ban on steel products that either originate in russia or have been exported from russia. council regulation (eu) 2022/2475 (regulation 2475) 16 december 2022 regulation 269 on publication date introduces a new deadline, 17 june 2023, for the derogation allowing divestments by sberbank with a view to winding down its operations. extends to the 2 newly listed entities (being credit bank of moscow and dalnevostochny bank) the derogation from the asset freeze and from the prohibition to make funds and economic resources available, in order to allow the termination of operations, contracts, or other agreements, previously concluded with those entities. introduces a new derogation allowing the unfreezing assets of, and to make funds and economic resources available to, certain individuals who held a significant role in international trade and agricultural and food products, including wheat and fertiliser, prior to their listing. extends the deadline for certain general derogations. council implementing regulation (eu) 2022/2476 (regulation 2476) 16 december 2022 regulation 269 on publication date adds a further 141 individuals and 49 entities to the asset freeze list under regulation 269, including credit bank of moscow and dalnevostochny bank. council decision (cfsp) 2022/2477 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2476 above. council decision (cfsp) 2022/2478 16 december 2022 decision 512 on publication date equivalent to those listed under regulation 2474 above. council decision (cfsp) 2022/2479 16 december 2022 decision 145 on publication date equivalent to those listed under regulation 2475 above. council implementing regulation (eu) 2023/192 (regulation 192) 30 january 2023 regulation 269 on publication date adds 1 iranian entity to the asset freeze list under regulation 269 due to its involvement in the development and delivery of unmanned aerial vehicles to russia. council decision (cfsp) 2023/193 30 january 2023 decision 145 on publication date equivalent to those listed under regulation 192 above. council regulation (eu) 2023/426 (regulation 426) 25 february 2023 regulation 269 on publication date extends to certain newly-listed banks (rosbank, tinkoff bank and alfa bank) certain licensing grounds for derogations from the asset freeze, and to allow the processing of payments by the jewish claims conference through one of them. extends the deadline to apply for the disposal or the transfer of securities by the national settlement depository (nsd), and which are currently or were previously controlled by vtb bank. introduces a derogation allowing for the termination of operations, contracts or other agreements with limited liability company “commercial vehicles - gaz group”, and extended by three months the deadline for the derogation to allow the sale and transfer of proprietary rights in a legal person, entity or body established in the eu owned by a listed natural or legal person, entity or body. introduces a requirement that natural and legal persons, entities and bodies should supply to the national competent authorities detailed information on funds and economic resources which have been frozen or should have been treated as frozen, as well as information on funds and economic resources belonging to, owned, held or controlled by listed natural or legal persons, entities or bodies which were subject to any move, transfer, alteration, use, access, or dealing shortly before the listing. introduces a requirement that central securities depositories, due to their systemic importance for the functioning of securities markets, should provide the relevant information to the member state concerned and simultaneously to the commission. specifies the type of information to be provided to national competent authorities, which authorities should then transmit that information to the commission, with specific adaptations in the case of criminal proceedings. provides for deferred application of the more detailed reporting requirements, in order to allow time to adapt. clarifies that member states and the relevant natural and legal persons, entities and bodies are required to cooperate with the commission in any verification of such information, and that the commission should be able to request any additional information, while informing the member state concerned of such request. council regulation (eu) 2023/427 (regulation 427) 25 february 2023 regulation 833 on publication date adds 96 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, on whom tighter export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector are imposed. adds several iranian entities to the list of natural and legal persons, entities and bodies subject to restrictive measures under decision 512, taking into account the direct connection between iranian manufacturers of unmanned aerial vehicles and the russian military and industrial complex and the concrete risk that certain goods or technology are used for the manufacture of military systems that contribute to russia’s war of aggression against ukraine. extends the list of restricted items which might contribute to russia’s military and technological enhancement or the development of its defence and security sector, by adding rare-earths and compounds, electronic integrated circuits and thermographic cameras, among others. extends the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. prohibits the transit via the territory of russia of dual-use goods and technology and of arms exported from the eu in order to minimise the risk of circumvention of the restrictive measures. extends the suspension of broadcasting licences in the eu of russian media outlets under the permanent control of the russian leadership and the prohibition against broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of such media outlets in the eu, or directed at the eu. the measures should be maintained until the aggression against ukraine is put to an end, and until the russian federation, and its associated media outlets, cease to conduct propaganda actions against the eu and its member states. those measures do not prevent the media outlets and their staff from carrying out activities in the eu other than broadcasting, such as research and interviews. restricts the possibility to hold any posts in the governing bodies of european critical infrastructures and critical infrastructures identified or designated as such under national law. imposes a prohibition on providing gas storage capacity in the eu to russian nationals, natural persons residing in russia or legal persons or entities established in russia. introduces an obligation for aircraft operators to notify non-scheduled flights to their competent authorities the member state concerned should immediately inform other member states, the network manager and the commission where it does not clear such a flight. extends the duration of the exemption from the prohibition to enter into any transactions with certain russian state-owned entities if such a transaction is strictly necessary for the wind-down of a joint venture or similar legal arrangement. it also extends the duration of the period in which the competent authorities of the member states may authorise transactions which are necessary for the divestment and withdrawal by those russian state-owned entities from eu companies. requires that natural and legal persons, entities and bodies supply to the competent authorities of the member states and simultaneously to the commission information on the management of reserves and assets of the central bank of russia, which they hold or control or are a counterparty to. it is also appropriate to specify the type of information to be provided and how this should be treated and used to ensure the uniform application of this reporting obligation. it should also be clarified that member states and the relevant natural and legal persons, entities and bodies must cooperate with the commission in any verification of such information and that the commission may request any additional information, while informing the member state concerned of such request. in order to allow time to adapt, the new rules provide for deferred application of the new reporting requirements. introduces a temporary derogation from the prohibition on providing accounting, auditing, including statutory audit, bookkeeping or tax consulting services, or business and management consulting or public relations services, architectural and engineering services, legal advisory services and it consultancy services. in order to facilitate an expeditious exit from the russian market, this derogation is temporary and limited in scope, enabling until 31 december 2023 the continuation of the provision of services to and for the exclusive benefit of the legal persons, entities or bodies resulting from the divestment. additionally, the competent authorities of the member states should ensure that the services are not provided to the government of russia or benefit military end-users or have a military-end use. provides for certain exemptions for eu operators to provide pilot services to vessels in innocent passage as defined by international law which are necessary for reasons of maritime safety. provides for rules on the release by the customs authorities of the member states of goods which are physically in the eu and which had already been presented to customs authorities when they became subject to such restrictions. authorises member states to release goods already brought into the eu in the past. the competent authorities of the member states should ensure that the release of the goods and any payment related thereto comply with the provisions and objectives of eu restrictive measures. similarly, any decision not to release such goods should comply with those objectives and ensure, among others, that the goods are not returned to russia. makes certain technical corrections in the operative text of decision 512. council implementing regulation (eu) 2023/429 (regulation 429) 25 february 2023 regulation 269 on publication date adds a further 87 individuals and 34 entities to the asset freeze list under regulation 269, including most significantly rosbank, tinkoff bank and alfa bank. council implementing regulation (eu) 2023/430 (regulation 430) 25 february 2023 regulation (eu) 2020/1998 on publication date designates the wagner group and three of its members involved in serious human rights violations in different parts of the world. adds 8 individuals and 7 entities in the list of natural persons, legal persons, entities and bodies subject to restrictive measures under regulation (eu) 2020/1998. council decision (cfsp) 2023/432 25 february 2023 decision 145 on publication date equivalent to those listed under regulation 426 above. council decision (cfsp) 2023/433 25 february 2023 decision 1999 on publication date equivalent to those listed under regulation 430 above. council decision (cfsp) 2023/434 25 february 2023 decision 512 on publication date equivalent to those listed under regulation 427 above. council implementing regulation (eu) 2023/419 (regulation 419) 27 february 2023 regulation 765 on publication date renews the restrictive measures imposed on belarus until 28 february 2024. amends the entries relating to 21 individuals and 2 entities included in the list of natural and legal persons, entities and bodies subject to restrictive measures under regulation 765. council decision (cfsp) 2023/421 27 february 2023 decision 642 on publication date equivalent to those listed under regulation 419 above. council regulation (eu) 2023/1214 (regulation 1214) 23 june 2023 regulation 833 on publication date prohibits the transit of goods and technology suited for use in aviation or space industry and jet fuel and fuel additives, exported from the eu to third countries via russia. allows for appropriate individual measures such as designations or trade restrictions, to be adopted to address the involvement of third-country operators facilitating circumvention. introduces the possibility of last-resort measures restricting the sale, supply, transfer or export of sensitive dual-use goods and technology, or goods and technology that might contribute to the enhancement of russia’s military, technological or industrial capacities or to the development of russia’s defence and security sector to third countries used for circumvention. adds 87 new entities to the list of entities directly supporting russia’s military and industrial complex in its war of aggression against ukraine, certain entities from third countries involved in the circumvention of trade restrictions, and certain entities involved in the development, production and supply of electronic components for russia’s military and industrial complex. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which contribute to the development or production of russia’s military systems, including electronic components, semiconductor materials, manufacturing and testing equipment for electronic integrated circuits and printed circuit boards, precursors to energetic materials and precursors to chemical weapons, optical components, navigational instruments, metals used in the defence sector and marine equipment. extends the list of restricted firearms, their parts, essential components and ammunition, and adds other types of arms. imposes further restrictions on exports of goods which could contribute to the enhancement of russian industrial capacities. prohibits the sale, licence or transfer in any other way of intellectual property rights or trade secrets used in connection with restricted goods. extends the suspension of the broadcasting licences in the eu of five russian media outlets under the permanent control of the russian leadership, and the prohibition against broadcasting their content. extends the prohibition on the transport of goods by road in the eu by trailers and semi-trailers. prohibits access to ports and locks in the territory of the eu by vessels engaged in ship-to-ship transfers where the competent authorities have reasonable cause to suspect that a vessel is in breach of the ban on importing seaborne russian crude oil and petroleum products into the eu or is transporting russian crude oil or petroleum products purchased above the price cap agreed by the price cap coalition. prohibits access to ports and locks in the territory of the eu by vessels which competent authorities have reasonable cause to suspect of illegally interfering with, switching off or otherwise disabling their shipborne automatic identification systems (ais) when transporting russian crude oil and petroleum products. that prohibition does not apply in circumstances where the shipborne ais can be legitimately turned off in accordance with international agreements, rules or standards that provide for the protection of navigational information, such as navigation through high-security-risk waters. ends the temporary derogation granted to germany and poland for the supply of crude oil by pipeline from russia through the northern section of the druzhba oil pipeline. the import of oil which originates in kazakhstan or another third country and is transiting through russia via the druzhba oil pipeline is not prohibited. introduces derogations from the prohibitions on the sale, supply, transfer or export directly or indirectly to any natural or legal person, entity or body in russia or for use in russia of certain goods or technology, on the provision of related financing or financial assistance, technical assistance, brokering services or other services, or on the provision of auditing services, engineering services, legal advisory services, technical testing and analysis services which are strictly necessary for that purpose, subject to strict conditions to avoid the risk of circumvention. extends prohibition on providing transferable securities to financial instruments denominated in any currency. introduces a derogation from the prohibition to provide certain services to russian entities required for the setting-up, certification or evaluation of a firewall removing the control exercised by a listed person over the assets of a non-listed eu entity which the listed person owns or controls. clarifies the evidence required for importation of iron and steel products processed in a third country incorporating iron and steel products originating in russia. introduces clarifications regarding the competent authorities which receive notifications of non-scheduled flights between russia and the eu. extends the deadline for the application of a temporary derogation from the prohibition on providing certain services, with the aim of further facilitating divestment from the russian market by union operators. introduces a temporary derogation from the prohibition on providing legal advisory services to legal persons, entities or bodies established in russia. the competent authorities of the member states may authorise the provision, until 31 march 2024, of legal services which are mandatory, under the national legislation of the member state, for such divestments to be completed. adds switzerland to the list of partner countries which are applying a set of export control measures substantially equivalent to those set out in regulation 833. council regulation (eu) 2023/1215 (regulation 1215) 23 june 2023 regulation 269 on publication date introduces a further criterion for the asset freeze listing to allow the designation of legal persons, entities or bodies operating in the russian it sector with a licence from federal security service of the russian federation (fsb) or the russian ministry of industry and trade. amends an existing listing criterion regarding the circumvention of eu sanctions, or significant frustration of eu sanctions by third country operators, including instances where the main activity of a third country operator consists of purchasing restricted goods in the eu that reach russia, the involvement of russian individuals or entities, the recent creation of a company for purposes related to restricted goods reaching russia, or a drastic increase in the turnover of a third country operator involved in such activities. introduces further derogations from the asset freeze to allow for divestment from russian companies and the disposal of certain types of securities held with vtb bank and national settlement depository (nsd). introduces a derogation allowing the provision of services required for the establishment of a firewall removing the control by a listed person over the assets of an eu entity. allows for the provision of pilot services in specific circumstances to safeguard maritime safety. insertion of certain clarifications in the provision on information sharing between competent authorities and regarding the respect of the confidentiality of the communications between lawyers and their clients in the context of reporting obligations. introduces a derogation allowing the release of frozen funds belonging to alexey alexandrovits mordashov after having determined that such funds are necessary for the completion of transactions of a joint venture. introduces a derogation allowing the release of frozen funds for certain banks when such funds are necessary for the purchase, import or transport of agricultural and food products, namely the following entities, bank rossiya, promsvyazbank, veb.rf, otkritie fc bank, novikombank, sovcombank, vtb bank, sberbank, credit bank of moscow, jsc ‘dalnevostochniy bank’, jsc ural civil aviation factory, alfa-bank js, public joint-stock company rosbank, mrb bank and cmr bank. council implementing regulation (eu) 2023/1216 (regulation 1216) 23 june 2023 regulation 269 on publication date adds a further 71 individuals and 33 entities to the asset freeze list under regulation 269, including most significantly mrb bank and cmr bank. council decision (cfsp) 2023/1217 23 june 2023 decision 512 on publication date equivalent to those listed under regulation 1214 above. council decision (cfsp) 2023/1218 23 june 2023 decision 145 on publication date equivalent to those listed under regulation 1215 above. council implementing regulation (eu) 2023/1591 (regulation 1591) 3 august 2023 regulation 765 on publication date adds a further 38 individuals and 3 entities from belarus to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765. council implementing decision (cfsp) 2023/1592 3 august 2023 decision 642 on publication date equivalent to those listed under regulation 1591 above. council regulation (eu) 2023/2873 (regulation 2873) 18 december 2023 regulation 269 on the day following that of its publication date extends the listing criteria to cover natural or legal persons, entities or bodies benefitting from the compulsory transfer of ownership of, or control over, entities established in russia that were previously owned or controlled by eu entities. sets out the conditions on which the council is able to retain the name of a deceased person on the asset freeze list under particular circumstances. introduces a derogation to allow for the release of frozen funds or economic resources, in cases where a member state deprives a listed person of funds or economic resources belonging to, or owned by or controlled by, it, and for making funds and economic resources available to such person for compensation to be paid. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the sale or use of shares in, or assets of, an entity established in russia where the ownership or control by an eu legal person of that entity has been compulsorily transferred by the russian government. that derogation would enable, among others, the payment of agreed adequate compensation to eu legal persons. extends the deadline applicable to the existing derogation allowing the processing of payments by the jewish claims conference until 31 december 2024 through alfa-bank jsc and introduces a derogation to allow for certain payments as an indemnity or benefit for the materialisation of a risk involving a newly listed entity. introduces a temporary derogation from the asset freeze and the prohibition on making funds and economic resources available to allow the sale and transfer of proprietary rights directly or indirectly owned by certain listed persons (namely petr aven, mikhail fridman, gennady timchenko, german khan, alexey kuzmichev, igor kesaev, boris rotenberg, arkady rotenberg, as well as certain legal entities) in a legal person, entity or body established in the eu. introduces a derogation from the asset freeze and the prohibition on making funds and economic resources available to allow for the termination of contracts concluded with a newly listed entity. extends to a newly listed alfastrakhovanie, an insurance company, the existing derogation currently applicable to certain listed banks under certain circumstances. makes technical amendments in the operative text, defines the scope of certain reporting obligations and introduces an obligation for national competent authorities of member states to designate in accordance with national legislation the national authorities competent to identify and trace, where appropriate, funds and economic resources belonging to, or owned, held or controlled by, listed natural or legal persons, entities or bodies, with a view to preventing or detecting instances of a breach or circumvention, or attempts at a breach or circumvention, of regulation 269. council regulation (eu) 2023/2878 (regulation 2878) 18 december 2023 regulation 833 on the day following that of its publication date adds 29 new entities to the list of legal persons, entities and bodies supporting russia’s military and industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemicals, lithium batteries, thermostats, dc motors and servomotors for unmanned aerial vehicles, machine tools and machinery parts. introduces a list of partner countries, being swtizerland and norway, which apply a set of restrictive measures on imports of iron and steel and a set of import control measures. it also extends certain wind-down periods for the import of specific steel products. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. prohibits the transit via the territory of russia of certain goods and technology which could contribute in particular to the enhancement of russian industrial capacities, exported from the eu. introduces further restrictions on imports of goods which generate significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. provides for an exemption for the entry of cars into the eu for specific circumstances. introduces a derogation enabling the granting of loans or credits to entities operating in the russian energy sector which are subject to the transaction ban provided for in regulation 833, under the conditions provided for therein. imposes a prohibition on the direct or indirect import, purchase or transfer of diamonds from russia. that prohibition applies to diamonds originating in russia, diamonds exported from russia, diamonds transiting russia and russian diamonds when processed in third countries other than russia. the prohibition applies to non-industrial natural and synthetic diamonds, as well as diamond jewellery, as of 1 january 2024, and includes a progressive phasing-in, from 1 march 2024 until 1 september 2024, of an indirect import ban on russian diamonds when processed in third countries other than russia, including jewellery incorporating diamonds originating in russia. prolongs by an additional year specific derogations from the prohibition on imports from russia of crude oil and petroleum products in order to ensure the security of supply of certain member states. introduces a requirement that itemised price information for ancillary costs, such as insurance and freight, be shared upon request throughout the supply chain of russian oil trade. competent authorities can request that information from any actor, regardless of their place in the supply chain, at any time, in order to verify compliance with the price cap mechanism. provides for a notification obligation for the sale of tankers to any third country and a derogation from the prohibition on the sale of tankers to russian persons and entities, or for use in russia. this obligation applies to the owner of a tanker who is a national of a member state, to a natural person residing in a member state, and to a legal person, entity or body which is established in the eu. the owner, or anyone acting on his or her behalf, should notify the competent authorities of any such sale concluded since 5 december 2022 and provide all the necessary details. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2024 to ensure japan’s energy security needs. includes a ban on russian nationals or natural persons residing in russia from owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing crypto-asset wallet, account or custody services to russian persons. extends the existing prohibition on the provision of services to also include the provision of software for the management of enterprises and software for industrial design and manufacture, subject to appropriate exemptions and derogations. imposes certain reporting requirements for the transfer of funds out of the eu made by entities established in the eu, including special purpose entities, whose proprietary rights are owned by entities established in russia, by russian nationals or by natural persons residing in russia. requires that exporters contractually prohibit re-exportation to russia and re-exportation for use in russia of certain specific sensitive goods and technology. council implementing regulation (eu) 2023/2875 18 december 2023 regulation 269 on publication date adds a further 61 individuals and 86 entities to the asset freeze list under regulation 269, most notably including alfastrakhovanie group, the insurance arm of alfa bank. council decision (cfsp) 2023/2871 18 december 2023 decision 145 on publication date equivalent to those listed under regulation 2873 above. council decision (cfsp) 2023/2874 18 december 2023 decision 512 on publication date equivalent to those listed under regulation 2878 above. council decision (cfsp) 2024/195 3 january 2024 decision 145 on publication date adds pjsc alrosa and its ceo, pavel alekseevich marinychev, to the asset freeze list under decision 145. council regulation (eu) 2024/745 (regulation 745) 23 february 2024 regulation 833 on the day following that of its publication date adds 27 russian and third country entities to the list of legal persons, entities and bodies associated to russia’s military-industrial complex set out in annex iv of regulation 833. expands the list of controlled items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding components for the development and production of unmanned aerial vehicles. imposes further restrictions on exports of goods which contribute in particular to the enhancement of russian industrial capabilities. adds the united kingdom to the list of partner countries for the iron and steel imports. these partner countries apply a set of restrictive measures on imports of iron and steel and a set of import control measures that are substantially equivalent to those regulation 833. council implementing regulation (eu) 2024/753 (regulation 753) 23 february 2024 regulation 269 on publication date adds a further 106 individuals and 88 entities to the asset freeze list under regulation 269. council decision (cfsp) 2024/746 23 february 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 745 above. council decision (cfsp) 2024/747 23 february 2024 decision 145 on publication date equivalent to those listed under regulation 753 above. council regulation (eu) 2024/1428 (regulation 1428) 17 may 2024 regulation 833 on the day following that of its publication date introduces measures to suspend broadcasting activities within the union or directed at the union by certain media outlets listed in the annex to regulation (eu) 2024/1428. council regulation (eu) 2024/1485 (regulation 1485) 27 may 2024 n/a. new measure on publication date provides for the freezing of funds and economic resources of, and the prohibition to make funds and economic resources available to, natural or legal persons, entities or bodies, certain designated natural or legal persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. these restrictions largely mirror those of regulation 269 in substance. provides for certain sectoral restrictions on exporting equipment, technology or software, which might be used for internal repression, as well as items intended primarily for use in the monitoring or interception of information security and telecommunication and the provision of related technical assistance, brokering services, financing or financial assistance. council decision (cfsp) 2024/1484 27 may 2024 n/a. new measure on publication date provides for a travel ban on certain designated natural persons in connection with serious violations or abuses of human rights or the repression of civil society and democratic opposition, or the undermining of democracy or the rule of law in russia. contains other measures equivalent to those listed under regulation 1485. council implementing regulation (eu) 2024/1488 (regulation 1488) 27 may 2024 regulation 1485 on publication date adds 19 individuals and 1 entity to the asset freeze list under regulation 1485. council implementing regulation (eu) 2024/1493 (regulation 1493) 27 may 2024 regulation 269 on publication date adds a further 2 individuals and 1 entity to the asset freeze list under regulation 269. council decision (cfsp) 2024/1508 27 may 2024 decision 145 on publication date equivalent to those listed under regulation 1493 above. council regulation (eu) 2024/1739 24 june 2024 regulation 269 on publication date introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. clarifies that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. introduces a provision to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them, provided that the member state national or company concerned does not have effective access to remedies under the relevant jurisdiction. introduces a new reporting obligation on member states to report penalties imposed for violations of the restrictive measures provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties. ensures that any document held by the council, the commission or the high representative of the union for foreign affairs and security policy for the purpose of ensuring the enforcement of the measures set out regulation 269, or of preventing the violation or circumvention thereof, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. that protection also applies to the joint proposals from the high representative of the union for foreign affairs and security policy and the commission for the amendment of regulation 269 and to any preparatory documents related to them. council regulation (eu) 2024/1745 24 june 2024 regulation 833 on the day following that of its publication date amends the prohibition to land in, take off from or overfly the territory of the eu so that it also applies to any aircraft which is used for a non-scheduled flight and with regard to which a russian natural or legal person, entity or body is in a position to effectively determine the place or time of its take-off or landing. also amends the same prohibition to introduce an exemption for certain aircraft when used for private, non-corporate flights carried out within eu territory and airspace for recreational or training purposes. introduces an obligation for operators to provide, for non-scheduled flights, upon request of the competent authorities of the member state of departure, destination or overflying, information needed for the purpose of verifying compliance with the flight ban, including information about ownership of the aircraft and, where reasonable grounds to suspect circumvention of the flight ban exist, about passengers. amends the prohibition on the transport of goods by road within the territory of the eu, including in transit. eu operators which are owned for 25 % or more by a russian natural or legal person should be prohibited from becoming a road transport undertaking or from transporting goods by road in the eu, including in transit. clarifies that rough diamonds imported from russia prior to 1 january 2024 and polished diamonds imported from russia or manufactured before 1 march 2024 or 1 september 2024, depending upon the weight of the diamond, are not covered by the diamond ban. also amends the ban on russian diamonds in order to enable the temporary import or export of jewellery for repairs, auctions and trade fairs and amends the scope of application and the date of entry into force of the requirement to provide traceability-based evidence. provides that the indirect import ban on russian diamonds processed in third countries other than russia, is temporarily not to apply to jewellery incorporating such diamond. prohibits reloading services in the territory of the eu for the purposes of transshipment operations where such services are used to transship russian lng, except in the case of such transshipments to member states. prohibits new investment and the provisions of goods, technology and services for the completion of lng projects. introduces import restrictions on russian lng through union lng terminals that are not connected to the interconnected natural gas system. introduces a sectoral ban prohibiting access to member states’ ports and locks as well as certain services related to maritime transport for vessels which contribute to russia’s ability to wage war against ukraine. clarifies the scope of the port access ban for russian-flagged vessels and adds a derogation. introduces a prohibition on purchasing, importing, transferring or exporting ukrainian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance, where there are reasonable grounds to suspect that the goods have been unlawfully removed from ukraine, along with a prohibition on related services. enables the possibility to subject companies which make use of russian law provisions, which force the satisfaction of claims against assets of eu companies in a foreign jurisdiction, claims which they would otherwise be prohibited from satisfying pursuant to regulation 833 or regulation 269, to a transaction ban. prohibits eu entities which operate outside of russia from directly connecting to the ‘system for transfer of financial messages’ (spfs) or equivalent specialised financial messaging services set up by the central bank of russia, and adds a transaction ban on eu operators with specifically listed entities using that system outside russia. eu entities however are not prohibited from dealing with russian entities which use the spfs, provided that those eu entities do not connect to the spfs themselves. establishes a transaction ban on eu operators with credit and financial institutions as well as crypto assets providers, established outside of the eu, when the council has determined that those entities facilitate transactions that support russia’s defence-industrial base through the export, supply, sale, transfer or transport towards russia of dual-use goods and technology, common high priority items or firearms and ammunition. broadens the existing prohibition on the provision of support, including financing and financial assistance or any other benefit, from an eu, euratom or member state programme to any legal person, entity or body established in russia or to any legal person, entity or body majority owned by them. creates an exemption to the prohibition to provide certain services to the government of russia or to legal persons, entities or bodies established in russia, for eu nationals who resided in russia before february 2022 and who are employed by subsidiaries of eu and partner countries’ entities. imposes restrictions on accepting applications for registrations in the eu of certain intellectual property rights by russian nationals, natural persons resident in russia and russian companies. in particular, and without prejudice to their procedural rules, intellectual property offices and other competent institutions should not allow the filing of such applications. introduces a prohibition on the acceptance, by political parties, foundations, alliances, non-governmental organisations, including think tanks, and media service providers in the eu, of financing, donations or any other economic benefits or support from russia, whether directly or indirectly. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. provides for member states to report about penalties imposed for violations of restrictive measures. ensures that the documents held by the council, the commission and the high representative of the union for foreign affairs and security policy concerning the enforcement of the restrictive measures set out in regulation 833, or concerning the prevention of the violation or circumvention of those measures, are subject to professional secrecy and enjoy the protection afforded by the rules applicable to the eu institutions. introduces a derogation to allow the satisfaction of certain claims brought by russian persons, entities and bodies if that is strictly necessary for the divestment from russia or the wind-down of business activities in russia. introduces provisions to enable member state nationals and companies to obtain compensation from russian individuals and entities that caused damages to them. provides that where a natural or legal person voluntarily, completely and in due time discloses a violation of the restrictive measures, it should be possible for national competent authorities to take that self-disclosure into account when applying penalties, as appropriate, in accordance with national administrative law or with other relevant national law or rules requires eu operators to undertake their best efforts to ensure that legal persons, entities and bodies established outside the eu that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 833. requires eu operators to contractually prohibit their commercial counterparts in third countries from using, or allowing the use of, the intellectual property rights, trade secrets or material or information protected by intellectual property rights or protected as trade secret transferred to them in connection with common high priority items to be sold, supplied or exported to russia or for use in russia. requires eu operators that are selling, supplying, transferring or exporting common high priority items to third countries, other than the partner countries listed in annex viii regulation 833, to implement due diligence mechanisms capable of identifying and assessing risks of exportation to russia and mitigating such risks. eu operators must also ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. this adopts the position taken by the court of justice in case c-72/11 case c-72/11 afrasiabi and others. adds 61 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512. also includes on that list certain entities in third countries other than russia that are involved in the circumvention of trade restrictions and that engage in the procurement of sensitive items used for. expands the list of items which contribute to russia’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems. imposes further restrictions on exports of goods which could contribute in particular to the enhancement of russian industrial capacities. adds five common high priority items to the restrictions on exports of goods. introduces further restrictions on the import of helium. extends the exemption provided for in relation to the sakhalin-2 (сахалин-2) project, located in russia, until 28 june 2025 to ensure japan’s energy security needs. makes certain technical amendments in the operative text and annexes, deleting references to transitional periods which have expired introduces a horizontal exemption from the prohibitions in this regulation for the paks ii nuclear project, with a notification obligation for such activities. expands the lists of partner countries that apply a set of export control measures or a set of restrictive measures on imports of iron and steel and a set of import control measures which are substantially equivalent to those set out in regulation 833. council implementing regulation (eu) 2024/1746 24 june 2024 regulation 269 on publication date adds a further 69 persons and 47 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/1776 24 june 2024 regulation 833/regulation 1428 on the day following that of its publication date provides that the measures in relation to broadcasting in regulation 833 apply from 25 june 2024 in respect of all entities referred to in the annex to regulation 1428 and can be found here. council decision (cfsp) 2024/1738 24 june 2024 decision 145 on publication date equivalent to those listed under regulations 1739 and 1746 above. council decision (cfsp) 2024/1744 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1745 above. council decision (cfsp) 2024/1770 24 june 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1776 above. council regulation (eu) 2024/3189 (regulation 3189) 16 december 2024 regulation 269 on publication date introduces a derogation allowing the release of cash balances that are held by central securities depositories and attributable to the nsd. introduces a derogation allowing the release of frozen funds to arkady rotenberg, boris rotenberg and gennady timchenko. council regulation (eu) 2024/3192 (regulation 3192) 16 december 2024 regulation 833 on the day following that of its publication date adds 32 new entities to the list of persons, entities and bodies supporting russia’s military-industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles or missiles. adds further vessels to the list of vessels on which a ban from member states’ ports and locks, as well as a ban on the provision of a broad range of services related to maritime transport, are imposed. adds that certain actions by a central securities depository carried out in good faith do not give rise to liability of any kind on the part of that depository, or of its directors or employees, unless it is proved that the action was a result of negligence. introduces a prohibition on the recognition or enforcement in the union of injunctions, orders, judgments or other court decisions pursuant to or in relation to article 248 of the arbitration procedure code of the russian federation or equivalent russian legislation. makes certain technical amendments to regulation 833, including to extend the deadlines applicable to certain derogations needed for divestments from russia or for member states’ security of supply of certain petroleum products. council implementing regulation (eu) 2024/3177 (regulation 3177) 16 december 2024 article 8a(1) of regulation (ec) no 765/2006 on publication date adds 26 individuals and 2 entities in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 in view of the situations in belarus. council implementing regulation (eu) 2024/3183 (regulation 3183) 16 december 2024 regulation 269 on publication date adds a further 54 individuals and 30 entities to the asset freeze list under regulation 269. council implementing regulation (eu) 2024/3188 (regulation 3188) 16 december 2024 regulation 2642 on publication date adds 16 individuals and 3 entities to the list of natural and legal persons, entities and bodies set out in annex i to regulation (eu) 2024/2642. council decision (cfsp) 2024/3174 16 december 2024 decision 2643 on publication date equivalent to those listed under regulation 3188 above. council decision (cfsp) 2024/3182 16 december 2024 decision 145 on publication date equivalent to those listed under regulation 3189 and regulation 3183 above. council decision (cfsp) 2024/3187 16 december 2024 decision 512 on the day following that of its publication date equivalent to those listed under regulation 3192 above. council implementing decision (cfsp) 2024/3175 16 december 2024 decision 642 on publication date equivalent to those listed under regulation 3177 above. council regulation (eu) 2025/390 (regulation 390) 24 february 2025 regulation 269 on publication date introduces two further criteria for the listing of natural or legal persons, entities or bodies in relation vessels involved in certain activities or who form part of, supporting, materially or financially, or benefitting from russia’s military and industrial complex. extends an existing divestment derogation to three additional listed individuals. extends the scope of two existing derogations regarding certain transfers of funds and payments. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries as referred to in annex viii of regulation 833 that apply similar restrictive measures. enables the commission to process personal data in relation to the due diligence required from union operators in respect of potential business partners. allows union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages. introduces a best-efforts obligation to union operators undertake such best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation 269. further expands on the scope of the best efforts obligation. makes a number of technical amendments in order to ensure the clarity of certain provisions of regulation 269 including those concerning documents held by the union institutions and the processing of personal data. council regulation (eu) 2025/392 (regulation 392) 24 february 2025 regulation 765 on publication date strengthens the prohibition on the export of dual-use goods and technology and of goods and technology which might contribute to the technological enhancement of belarus’s defence and security sector. expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including chemical precursors to riot control agents, software related to computer numerical control machines, chromium ores and compounds and controllers used to guide unmanned aerial vehicles. imposes further restrictions on exports of goods which could contribute to the enhancement of belarusian industrial capacities, such as chemical elements, pyrotechnic articles and combustible materials. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus of machinery and of goods which could contribute, in particular, to the enhancement of belarusian industrial capacities. establishes derogations for the provision of certain goods and machinery necessary for civilian non-publicly available electronic communications networks. introduces further restrictions on the import of primary aluminium, which allows belarus to diversify its sources of revenue, thereby enabling its involvement in the russian aggression against ukraine. imposes a restriction on the sale, supply, transfer, export or provision of software related to oil and gas exploration in order to further restrict the oil and gas exploration and production capacities of belarus and minimise the risk of circumvention of restrictive measures via the territory of belarus. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, licence or transfer in any other way of intellectual property rights or trade secrets related to a software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of belarus located in a member state. expands the scope of the prohibition on accepting deposits to include those from legal persons, entities or bodies established in third countries and majority-owned by belarusian nationals or natural persons residing in belarus. subjects the acceptance of deposits for non-prohibited cross-border trade to a prior authorisation by the national competent authorities. prohibits the provision of crypto-asset wallet, account or custody services to belarusian persons and residents and includes a prohibition on belarusian nationals or natural persons residing in belarus owning or controlling, or holding any posts on the governing bodies of, the legal persons, entities or bodies providing such services. introduces an exemption from the prohibition on the sale, supply, transfer or export of banknotes denominated in any official currency of a member state to or for use in belarus, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in belarus, under certain conditions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a belarusian natural or legal person. provides for the freezing of funds and economic resources of, and prohibits making funds or economic resources available to, designated persons, entities and bodies. introduces an additional designation criterion which applies to those forming part of, supporting, materially or financially, or benefiting from the military and industrial complex of belarus. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed intermediary bank in their transfer, under the conditions that the transfer is between two non-listed natural or legal persons, entities or bodies and is carried out using accounts at non-listed credit institutions. introduces a derogation allowing the release of funds that were frozen due to the involvement of a listed issuing bank in their transfer under the condition that the transfer is between two non-listed natural or legal persons, entities or bodies. union operators can seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as result of claims lodged by the entities or persons. union operators can seek damages from certain persons, entities or bodies that own or control the entities or bodies. introduces provisions in relation to the exchange of information and reporting requirements. union operators that are selling, supplying, transferring or exporting such goods to third countries are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to belarus and mitigating such risks. union operators are required to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions. includes technical amendments. council regulation (eu) 2025/395 (regulation 395) 24 february 2025 regulation 833 on publication date extends the suspension of the broadcasting licences in the union of russian media outlets under the permanent control of the russian leadership, and the prohibition on broadcasting their content. introduces further restrictive measures to suspend the broadcasting activities of certain media outlets in the union, or directed at the union. adds 53 new entities to the list of natural or legal persons, entities and bodies set out in annex iv to decision 512 on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. also includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles (uavs) or missiles. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemical precursors to riot control agents, software related to computer numerical control (cnc) machines, chromium compounds and controllers used to guide uavs. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as chemicals, some plastics and rubber. further extends the list of goods and technology subject to the prohibition on transit via the territory of russia. empowers competent authorities to authorise the sale and export, and related technical assistance, of information security systems, equipment and components, for non-military use and for a non-military end user, after having determined that such goods or technology or the related technical assistance are intended for a civilian non-publicly available electronic communications network, and provided that that network is not the property of an entity that is publicly controlled or with over 50 % public ownership, such authorisations can be granted in particular to providers of specialised financial messaging services. introduces further restrictions on the import of primary aluminium, which generates significant revenues for russia, thereby enabling the continuation of its war of aggression against ukraine. introduces a new targeted derogation from the prohibition on importing certain items that are strictly necessary for the operation of the druzhba pipeline. limits the application of an exemption to the flight ban on manned aircraft by introducing the need for an authorisation by the competent authorities. extends the flight ban to listed air carriers operating domestic flights within russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to a russian air carrier or for flights within russia, as well as to any entity owned or controlled by such air carrier. imposes further restriction on exports of goods and technology, in particular software related to oil and gas exploration, in order to further restrict russia’s oil and gas exploration and production capacities. provides for a derogation for the sale, supply, transfer or export from slovakia to hungary or from hungary to slovakia of certain petroleum products as listed in annex xxxi to regulation 833 which are obtained from crude oil imported by pipeline. introduces a prohibition on the provision of temporary storage for russian crude oil and petroleum products within the union, irrespective of the purchase price of the oil and of the final destination of those products. clarifies that reloading services for the purposes of transshipment operations of russian lng are allowed if necessary for its transport between ports of the same member state, including from the mainland of a member state to its outermost regions. amends the prohibition on the transport of goods by road within the territory of the union, including in transit, by operators that are owned for 25 % or more by a russian natural or legal person. entities established in the union before 8 april 2022 and already operating as road transport undertakings should be prohibited from making any changes to their capital structure that would increase the percentage share owned by a russian natural or legal person, entity or body, unless that percentage share remains below 25 % following such a change. extends prohibitions to the completion of crude oil projects in russia, such as the vostok oil project. introduces a derogation from the prohibition that can be granted by a member state that is not connected to the interconnected natural gas system when the lng is purchased, imported or transferred from a terminal located in another member state that is connected to the interconnected natural gas system in order to ensure its energy supply. requires imports of rough diamonds to be accompanied by a certificate in which the country of mining origin or the countries of mining origin are clearly stated. postpones the date of entry into force of the requirement to provide traceability-based evidence for imports of polished diamonds. furthermore, addressing governance issues associated with the traceability system will require ongoing cooperation with the g7 and third countries. introduces a prohibition on the provision of construction services, including civil engineering works. clarifies that the sale, license or transfer in any other way of intellectual property rights or trade secrets related to that software is prohibited. introduces a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and it consultancy services where those services are strictly necessary for the functioning of a consular or diplomatic representation of russia located in a member state. introduces a prohibition on any transaction with ports and locks and airports in russia that are used for the transfer of uavs or missiles or related technology or components thereof to russia, or for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices or of other restrictive measures. imposes restrictions on legal persons, entities or bodies established outside russia that use the system for transfer of financial messages of the central bank of russia. introduces a derogation allowing the execution of transactions with a specific entity included in annex xliv to regulation 833 that are necessary for the repayment of guarantees granted by a member state, divestment from russia or the wind-down of business activities in russia, or execution of certain contracts. further extends the transaction ban on credit institutions, financial institutions and entities providing crypto assets services that support transactions in relation to any listed vessel, thus frustrating the prohibition set out in article 3s of regulation 833. imposes restrictions on legal persons, entities and bodies, as listed in annex xlv to regulation 833, established outside of the union that are credit or financial institutions or entities providing crypto assets services involved in transactions that facilitate, directly or indirectly, the circumvention of the prohibitions set out in article 3n of regulation 833. extends the restrictive measures in relation to the provision of specialised financial messaging services to certain russian credit institutions or entities subscribing to financial messaging services or russian subsidiaries of third-country credit institutions, which are relevant for the russian financial and banking system, and are either large and important regional banks, which consequently facilitate regional and federal finances and business, or banks which facilitate significant cross-border payments or banks which are already the subject of restrictive measures imposed by the union or by partner countries. adds a derogation for the acceptance of deposits otherwise restricted for operations necessary for the restructuring or liquidation of a legal person associated with an entity listed in annex i to regulation 269. introduces an exemption from the prohibition on the sale, supply, transfer or export to russia of banknotes denominated in any official currency of a member state, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in russia under certain conditions. enables the commission to exchange information concerning third-country trade, transactions and operators with the competent authorities of partner countries that apply similar restrictive measures. extends the provision in regulation 833 on recognition of a claim for damages suffered by union operators as a consequence of a decision pursuant to specific russian legislation to those persons who are responsible for issuing that decision. adds to this provision a reference to russian legislation that allows for the corporate rights of foreign holding structures in economically significant russian organisations to be restricted, as well as for the direct foreign ownership in such organisations to be acquired by russian beneficiaries and for them to receive dividends directly. entitles union operators to seek, in judicial proceedings before the competent courts of a member state, compensation in respect of certain direct or indirect damages incurred as a result of claims lodged by certain entities or person. enables the commission to assist union operators facilitate their due diligence in respect of potential business partners and enables the commission to process personal data for this purpose. union operators that are selling, supplying, transferring or exporting such goods to third countries, other than the partner countries listed in annex viii to regulation 833, are required to implement due diligence mechanisms capable of identifying and assessing the risks of such re-exportation to russia and mitigating such risks. requires union operators to ensure that legal persons, entities and bodies established outside the union that they own or control also implement those requirements. makes certain amendments to the exemptions and derogations from the prohibition on the export of dual-use goods and advanced technologies, and replaces exemptions from certain prohibitions by derogations. deletes references to transition periods which have expired and other references that are not necessary for compliance with certain provisions of regulation 833. adds specific references to the applicable russian legislation in order to update some provisions concerning the protection of union operators. includes technical amendments to improve the accuracy of certain provisions of regulation 833 concerning personal data and documents held by the institutions of the union and to improve the linguistic clarity of certain other provisions. council regulation (eu) 2025/398 (regulation 398) 24 february 2025 regulation 263 on publication date prohibits, subject to certain exceptions, the supply to the non-government controlled areas of ukraine in the oblasts of donetsk, kherson, luhansk and zaporizhzhia of banknotes denominated in any official currency of a member state. introduces restrictions on the export to the non-government controlled areas of certain goods and technology that are also restricted by regulation 833. prohibits the provision to the non-government controlled areas of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. it also prohibits the provision to the non-government controlled areas of certain software for the management of enterprises and software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and amends the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. requires that union operators undertake their best efforts to ensure that legal persons, entities and bodies established outside the union that they own or control do not participate in activities that undermine the restrictive measures provided for in regulation (eu) 2022/263. member states report about penalties imposed for violations of the restrictive measures. clarifies that the protection against liability that is granted to union operators if they did not know, and had no reasonable cause to suspect, that their actions would infringe union restrictive measures cannot be invoked where union operators have failed to carry out appropriate due diligence. council regulation (eu) 2025/401 (regulation 401) 24 february 2025 regulation 692 on publication date prohibits, subject to certain exceptions, the supply to crimea and sevastopol of banknotes denominated in any official currency of a member state. restricts the export to crimea and sevastopol of certain goods and technology that are also restricted by regulation 833. prohibits the provision to crimea and sevastopol of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, it consultancy, market research and public opinion polling, technical testing and analysis and advertising services. prohibits the provision to crimea and sevastopol of certain software for the management of enterprises and of software for industrial design and manufacture, and of related intellectual property rights or trade secrets. introduces a number of horizontal provisions and to amend the wording of certain existing provisions. amends the provision prohibiting circumvention to clarify that the requirements of knowledge and intent are met not only where a person deliberately seeks the object or effect of circumventing restrictive measures but also where a person participating in an activity having the object or effect of circumventing restrictive measures is aware that such participation may have that object or that effect, and accepts that possibility. introduces a best-efforts obligation to union operators. introduces reporting obligations for member states in relation to penalties imposed for violations of restrictive measures. council implementing regulation (eu) 2025/389 (regulation 389) 24 february 2025 regulation 269 on publication date adds a further 48 individuals and 35 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/388 24 february 2025 decision 145 on publication date equivalent to those listed under regulation 389 and 390 above. council decision (cfsp) 2025/391 24 february 2025 decision 642 on publication date equivalent to those listed under regulation 392 above. council decision (cfsp) 2025/394 24 february 2025 decision 512 on publication date equivalent to those listed under regulation 395 above. council decision (cfsp) 2025/396 24 february 2025 decision 266 on publication date equivalent to those listed under regulation 398 above. council decision (cfsp) 2025/397 24 february 2025 decision 386 on publication date equivalent to those listed under regulation 401 above. council implementing regulation (eu) 2025/527 (regulation 527) 14 march 2025 regulation 269 on the day following that of its publication date adds further 126 individuals and 36 entities to the asset freeze list under regulation 269. deletes 3 deceased persons, 4 other persons and 3 duplicate entries from the asset freeze list under regulation 269. council decision (cfsp) 2025/528 14 march 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 527 above. council implementing regulation (eu) 2025/631 (regulation 631) 27 march 2025 article 8a(1) of regulation (ec) no 765/2006 on publication date adds further 25 individuals and 7 legal persons in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in annex i to regulation 765 in view of the situations in belarus. council implementing decision (cfsp) 2025/632 27 march 2025 decision 642 on publication date equivalent to those listed under regulation 631 above. council implementing regulation (eu) 2025/701 (regulation 701) 8 april 2025 regulation 833 on the day following that of its publication date provides that the restrictive measures to suspend the broadcasting activities in the eu, or directed at the eu, of certain media outlets listed in annex v to regulation 395 should apply as of 9 april 2025. council decision (cfsp) 2025/700 8 april 2025 article 4g of decision 2014/512/cfsp on the day following that of its publication date equivalent to those listed under regulation 701 above. council regulation (eu) 2025/903 (regulation 903) 14 may 2025 regulation 269 on the day following that of its publication date introduces a new listing criterion to include natural or legal persons, entities or bodies that have participated in or enabled transfers of ownership, control or economic benefit of the business interests of leading businesspersons operating in russia. sets outs the burden of proof required for the council to maintain the inclusion of leading businesspersons on the list of natural or legal persons, entities or bodies subject to restrictive measures. council decision (cfsp) 2025/904 14 may 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 903 above. council regulation (eu) 2025/932 (regulation 932) 20 may 2025 regulation 833 on the day following that of its publication date adds 31 new entities to the list of natural or legal persons, entities or bodies set out in annex iv to regulation 833, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. also includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on unmanned aerial vehicles or computer numerical control machine tools. expands the list in annex vii of regulation 833 of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including chemical precursors to energetic materials and spare parts for machine tools. extends the duration of an exemption from the oil price cap which allows, in view of energy security concerns, the transport, by vessel, of crude oil originating in the sakhalin-2 project in russia to japan. adds 189 vessels to the list of vessels set out in annex xlii to regulation 833, which are banned from accessing member states’ ports and locks, as well as from receiving a broad range of services related to maritime transport. council regulation (eu) 2025/964 (regulation 964) 20 may 2025 regulation 2642 on the day following that of its publication date amends the criteria guiding individual designations in the listings freezing assets and the prohibition from making funds and economic resources available to listed persons bodies and entities. introduces additional measures prohibiting transactions with tangible assets supporting russia-driven destabilising activities, such as vessels, aircraft, real estate, ports, airports, physical elements of digital and communication networks. prohibits broadcasting in the eu by specifically-designated media outlets. suspends the broadcasting licences in the eu of the specifically-designated media outlets, and prohibits the broadcasting of their content in the eu directing it to the eu. council implementing regulation (eu) 2025/933 (regulation 933) 20 may 2025 regulation 269 on publication date adds a further 17 individuals and 58 entities to the asset freeze list under regulation 269 council implementing regulation (eu) 2025/958 (regulation 958) 20 may 2025 regulation 1485 on publication date adds 28 individuals to the asset freeze list under regulation 1485. council implementing regulation (eu) 2025/965 (regulation 965) 20 may 2025 regulation 2642 on publication date adds 21 individuals and 6 entities to the asset freeze list under regulation 2642. council implementing regulation (eu) 2025/959 (regulation 959) 20 may 2025 regulation 1542 on publication date adds 3 entities to the asset freeze list under regulation 1542. council decision (cfsp) 2025/931 20 may 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 932 above. council decision (cfsp) 2025/936 20 may 2025 decision 145 on publication date equivalent to those listed under regulation 933 above. council decision (cfsp) 2025/957 20 may 2025 decision 1484 on publication date equivalent to those listed under regulation 958 above. council decision (cfsp) 2025/963 20 may 2025 decision 2643 on the day following that of its publication date equivalent to those listed under regulation 964 above. council decision (cfsp) 2025/966 20 may 2025 decision 2643 on publication date equivalent to those listed under regulation 965 above. council decision (cfsp) 2025/960 20 may 2025 decision 1544 on publication date equivalent to those listed under regulation 959 above. council implementing regulation (eu) 2025/1438 (regulation 1438) 15 july 2025 regulation 1485 on publication date adds 5 individuals to the list of natural and legal persons, entities and bodies set out in annex iv to regulation 1485. council implementing regulation (eu) 2025/1444 (regulation 1444) 15 july 2025 regulation 2642 on publication date adds 9 individuals and 6 entities to the list of natural and legal persons, entities and bodies set out in annex i to regulation 2642. council decision (cfsp) 2025/1425 15 july 2025 decision 1484 on publication date equivalent to those listed under regulation 1438 above. council decision (cfsp) 2025/1443 15 july 2025 decision 2643 on publication date equivalent to those listed under regulation 1444 above. council regulation (eu) 2025/1472 (regulation 1472) 18 july 2025 regulation 765 on the day following that of its publication date prohibits the sale, supply, transfer or export to belarus of arms and related materiel of all types. further prohibits the procurement from belarus of arms and related materiel of all types. provides member states with an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in annex va to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in belarus or that the end-use of the items may be for belarusian entities. expands into a transaction ban the existing prohibition to provide specialised financial messaging services to certain belarusian credit institutions and their belarusian subsidiaries, which are relevant for the belarusian financial system, and which are already the subject of restrictive measures imposed by the eu. adds exemptions related to the functioning of diplomatic and consular representations of the eu and of the member states or of partner countries in belarus, and, to transactions made by nationals of a member state who are residents in belarus. adds a derogation for transactions which are strictly necessary for the divestment from belarus or for the wind-down of business activities in belarus. prohibits member states from recognising or enforcing any injunction, order, relief, judgment of a court other than a court of a member state or other court, arbitral or administrative decision issued in proceedings other than those in the member states pursuant to or derived from investor-state dispute settlement proceedings in connection with measures imposed under regulation 765. enables competent authorities or the eu, where applicable, to recover in proceedings before a court of a member state any damages caused, including legal costs and costs incurred in the event of non-compliance with the arbitral award by the other party, from those persons, entities or bodies and from persons, entities or bodies that own or control those persons, entities or bodies, as a consequence of an investor-state dispute settlement in connection with measures imposed under regulation 765, provided that all available legal remedies in the relevant jurisdiction have been exercised. enables member states to invoke any objection available to them in domestic or foreign proceedings for the recognition and enforcement of such awards when member states are confronted with arbitral awards rendered against them in investor-state dispute settlement proceedings in connection with measures imposed under regulation 765. extends the application of the forum necessitatis provision to article 8l. adds a new entity to the list of natural and legal persons, entities and bodies set out in annex ii to decision 2012/642/cfsp. expands the list of items which might contribute to belarus’s military and technological enhancement or to the development of its defence and security sector by adding items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of belarus’s military systems, including chemical precursors to energetic materials, spare parts for machine tools, additional computer numerical control (cnc) machines and constituent chemicals for propellants. expands the list of goods subject to export restrictions which might contribute to the enhancement of belarusian industrial capacities, such as machinery, chemicals, some metals and plastics. extends the list of goods and technology subject to the prohibition on transit via the territory of belarus. council regulation (eu) 2025/1494 (regulation 1494) 18 july 2025 regulation 833 on the day following that of its publication date prohibits the sale, supply, transfer or export to russia of arms and related materiel of all types, and the procurement from russia of arms and related materiel of all types. adds 26 to the list of persons, entities and bodies supporting russia’s military and industrial complex in its war of aggression against ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of russia’s defence and security sector, are imposed. includes on that list certain entities in third countries other than russia that indirectly contribute to russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on unmanned aerial vehicles. expands the list of items which might contribute to russia’s military and technological enhancement or to the development of its defence and security sector, by listing items which have been used by russia in its war of aggression against ukraine and items which contribute to the development or production of its military systems, including additional computer numerical control machines and constituent chemicals for propellants. introduces an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in annex vii to regulation 833 to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in russia or that the end-use of the items may be for russian entities. imposes further restrictions on exports of goods which might contribute to the enhancement of russian industrial capacities, such as machinery, chemicals, some metals and plastics. further extends the list of goods and technology subject to the prohibition on transit via the territory of russia. ends the temporary derogation granted to czechia for the supply of crude oil by pipeline from russia. imposes a prohibition on the purchase, import, or transfer, directly or indirectly into the eu, of petroleum products obtained in a third country from russian crude oil, as well as on the provision of related technical or financial assistance. introduces a list of partner countries which have a set of restrictive measures that are substantially equivalent to those imposed by the eu on imports of russian oil and petroleum products. introduces a derogation from the prohibition that can be granted by a member state that is not directly connected to the interconnected natural gas system of any other member state and that receives the first commercial supply of its first long-term natural gas supply contract after 20 july 2025 in order to ensure its energy supply. introduces an exemption from the transaction ban, provided that a competent authority has imposed a public trusteeship or similar public firewall measure or the competent authority has authorised a similar firewall measure. amends the conditions for imposing a transaction ban on persons, entities or bodies established outside russia that use the system for transfer of financial messages (spfs) of the central bank of russia or equivalent specialised financial messaging services set up by the central bank of russia. provides for an exemption from the transaction ban on certain ports for kazakh coal based on the eu’s commitment to prevent negative impacts on energy security of third countries around the globe. provides for an exemption from the transaction ban on certain airports with regard to civil nuclear capabilities and facilities. introduces restrictive measures banning any transaction that is directly or indirectly connected to the natural gas pipelines nord stream and nord stream 2 and that concerns the completion, operation, maintenance or use of the pipelines or parts of the pipelines. expands the transaction ban on third-country credit and financial institutions and crypto assets services providers to include entities that are significantly frustrating the purpose of the prohibitions in regulations 833 and 269 adds 2 entities to the list of third country financial institutions subject to that ban. expands into a transaction ban the existing prohibition on the provision of specialised financial messaging services to certain russian credit or financial institutions or other entities subscribing to financial messaging services or to russian subsidiaries of third-country credit or financial institutions. adds 22 credit or financial institutions and other entities to the list of legal persons, entities or bodies subject to that transaction ban. adds exemptions related to the functioning of diplomatic and consular representations of the eu and of the member states or of partner countries in russia and to transactions made by nationals of a member state who are residents in russia. adds a derogation for transactions which are strictly necessary for divestment from russia or for the wind-down of business activities in russia. provides for a dynamic automatic procedure to modify the price cap for russian crude oil depending on the average market price of russian crude oil. introduces a transaction ban targeting the rdif, its subsidiaries, its significant investments and anyone providing those entities with investment services or other financial services. adds 4 entities to the list of legal persons, entities and bodies, in which rdif has made significant investments, that are subject to the transaction ban. adds 105 vessels to the list of vessels set out in annex xvi to decision 512 which are banned from member states’ ports and locks, as well as from receiving a broad range of services related to maritime transport. imposes a prohibition on the provision of software with certain uses in the banking and financial sector. prohibits member states from recognising or enforcing any injunction, order, relief, judgment of a court other than a court of a member state or other court, arbitral or administrative decision issued in proceedings other than those in the member states pursuant to or derived from investor-state dispute settlement proceedings in connection with measures imposed under regulations 833 or 269. enables enable competent authorities or the eu, where applicable, to recover in proceedings before a court of a member state any damages caused, including legal costs and costs incurred in the event of non-compliance with the arbitral award by the other party, from those persons, entities or bodies and from persons, entities or bodies that own or control those persons, entities or bodies, as a consequence of an investor-state dispute settlement in connection with measures imposed under regulations 833 or 269, provided that all available legal remedies in the relevant jurisdiction have been exercised. enables member states to invoke any objection available to them in domestic or foreign proceedings for the recognition and enforcement of such awards when they are confronted with arbitral awards rendered against them in investor-state dispute settlement proceedings in connection with measures imposed under regulation 269 or 833. extends the application of the forum necessitatis provision to article 11e. council implementing regulation (eu) 2025/1469 (regulation 1469) 18 july 2025 article 8a(1) of regulation 765 on publication date adds 8 entities to the asset freeze list under regulation 765. council implementing regulation (eu) 2025/1476 (regulation 1476) 18 july 2025 regulation 269 on publication date adds 14 individuals and 41 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/1471 18 july 2025 decision 642 on the day following that of its publication date equivalent to those listed under regulation 1472 above. council decision (cfsp) 2025/1478 18 july 2025 decision 145 on publication date equivalent to those listed under regulation 1476 above. council decision (cfsp) 2025/1495 18 july 2025 decision 512 on the day following that of its publication date equivalent to those listed under regulation 1494 above. council implementing decision (cfsp) 2025/1461 18 july 2025 decision 642 on publication date equivalent to those listed under regulation 1469 above. council implementing regulation (eu) 2025/1894 (regulation 1894) 12 september 2025 regulation 269 on the day following that of its publication date adds 142 individuals and 134 entities to the asset freeze list under regulation 269. council decision (cfsp) 2025/1895 12 september 2025 decision 145 on the day following that of its publication date equivalent to those listed under regulation 1894 above.

published in june 2025, the q2 2025 statistical bulletin from the bvi financial services commission highlights key updates in the financial services sector: corporate affairs: 7,037 new incorporations were recorded, a 2.52% increase from q2 2024. total business companies on the register reached 355,024. limited partnerships: new formations rose by 10.75% year-on-year, with a 37.33% increase from q1 2025. trade marks: applications decreased by 17.98% compared to q2 2024. banking: total assets slightly decreased to $3.26 billion, while loans and advances grew by 0.99%. net income rose by 81.94% from q1 2025. investment business: 60 new funds were registered, maintaining the same level as q2 2024. virtual assets: 5 licences were issued as of june 2025 under the virtual assets service providers act. inspections: six onsite inspections were conducted, including trust companies and investment businesses. this bulletin reflects steady growth and regulatory activity across sectors. for more information, bvi’s statistical bulletin for q2 2025 can be accessed here

on 13 june 2025, the cyprus securities and exchange commission (cysec) issued directive di 73-2009-05 to regulate distributed ledger technology (dlt) market infrastructures. this directive aligns with eu regulation 2022/858, establishing a pilot framework for dlt-based market infrastructures (the dlt market infrastructures regime). the cysec directive was accompanied by a policy statement issued by cysec (ps-02-2025). in a nutshell, the dlt market infrastructures regime allows investment firms, market operators and central securities depositories to operate multilateral trading facilities (mtf) and settlement systems which rely on dlt. key provisions: licensing process: entities which apply for specific licences to operate dlt-based trading, settlement, or combined systems, must follow the procedure in the cysec directive. applications must follow cysec's prescribed format and include required documentation in greek or english. notifications: operators must notify cysec of specific issues under article 11 of eu regulation 2022/858. fees and subscriptions: application fees range from €8,000 to €15,000, depending on the licence type. annual subscriptions for dlt operators are set at €15,000 for trading or settlement systems and €30,000 for combined systems. additional fees apply for exemptions and modifications. the cysec directive (in greek) can be found here the policy statement can be found here

the european union is advancing critical legislative measures to bolster financial stability and boost cross-border cooperation within its financial markets. the european parliament provided updates to the procedure files for several legislative proposals tied to the review of the eu's bank crisis management and deposit insurance (cmdi) framework. these initiatives, focussed on early intervention measures, deposit protection and resolution funding, aim to amend existing regulations and directives, ensuring a more resilient and transparent financial system across member states. a summary of the three legislative procedures: 2023/0111(cod): this regulation focusses on early intervention measures, conditions for resolution and funding of resolution actions. it amends regulation 2014/806 and is part of the eu's financial supervision framework. it aims to: expand the scope of resolutions: by reviewing public interest assessments. strengthen the funding of resolution actions: without imposing losses on depositors through deposit guarantee scheme (dgs) funds. clarify the early intervention framework: by removing overlaps and foster cooperation between competent and resolution authorities. the procedure is currently awaiting the council's first reading position. the draft regulation can be found here. 2023/0115(cod): this directive addresses deposit protection, the use of dgs funds, cross-border cooperation and transparency. it amends directive 2014/49. it aims to: enhance regional and cross-border financial stability: by harmonising depositor protection in the eu. ensure that preventative measures achieve their objective: by requiring additional reporting obligations from credit institutions. protect individuals: by mandating that alternative funding arrangements of dgss are not financed through public funds. the council's first reading position is pending. the draft directive can be found here. 2023/0112(cod): this directive also deals with early intervention measures, resolution conditions and financing of resolution actions, amending directive 2014/59 it aims to: safeguard taxpayers’ money: by reducing the overall costs associated with bank failures. empower authorities: to effectively handle potential failures of banks or a group of banks. it is also part of the eu's broader financial market and supervision reforms, awaiting the council's first reading position. the draft directive can be found here. procedure files released by the european parliament indicate that plenary sitting dates for the first readings of all three procedures are expected to commence on 15 december 2025.

on 25 september 2025, the uk and bermuda issued a joint statement reinforcing their commitment to sanctions enforcement. during a meeting in hamilton, uk minister for overseas territories stephen doughty and bermuda premier david burt highlighted bermuda’s leadership in freezing over $200m in sanctioned assets and ensuring robust compliance with uk sanctions. both leaders signed a memorandum of understanding, with the uk committing £300,000 to enhance bermuda's sanctions capabilities. discussions also covered bermuda’s progress on a beneficial ownership register and broader collaboration on security, trade, and the environment. this partnership highlights a united effort to prevent sanctions evasion and maintain strong enforcement across the uk and its territories. the joint statement can be found here

on 5 september 2025, cyprus securities and exchange commission (cysec) amended its directive di-87-09 for the restriction on the marketing, distribution or sale of contracts for differences (cfds). the amended directive now expressly provides that a 10% initial margin requirement applies for cfds where the underlying is a commodity or any stock index, not expressly listed in the directive. this effectively means that cyprus investment firms (cifs) may offer such cfds at a maximum 10:1 leverage. cfds with gold as the underlying continue to be subject to a 5% initial margin requirement. this amendment aims to further enhance protections of offering cfds to retail clients and to eliminate uncertainty in the industry’s interpretation of the directive. the amending directive (only available in greek) can be found here the consolidated version of the directive (only available in greek) can be found here

on 4 july 2025, the bvi financial services commission (fsc) published its newsletter for q2 of 2025, highlighting its efforts in advancing regulatory frameworks and promoting financial literacy. here are the key updates: meet the regulator (mtr) series: the 2025 mtr series kicked off in the bvi, focussing on beneficial ownership access to align with international standards. sessions in hong kong, london, and panama followed, fostering global stakeholder engagement. legislative updates: amendments to the proliferation financing act now enforce stricter liability for financial dealings with designated entities and mandate reporting of all transactions, regardless of value. corporate registry evolution: the registry of corporate affairs has undergone significant digital transformation, with the virrgin system enabling seamless operations (even prepared to deal with post-hurricane disruptions). beneficial ownership filing extension: companies and partnerships now have until 1 january 2026, to comply with beneficial ownership filing requirements, with no additional fees. public warnings: the bvi fsc issued advisories against fraudulent entities, urging caution in financial dealings. for more information, the bvi fsc’s newsletter can be found here