On June 23, 2023, the EU adopted its latest round of Russia sanctions. The new regulations have a focus on combatting circumvention and evasion, following suit with similar measures adopted by the United States last month.

The EU added 87 new entities to its export controls covering dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defense and security sector. For the first time, the EU is covering entities that are not just registered Russia or Iran, but also other jurisdictions, i.e., Armenia, Hong Kong, Syria, the United Arab Emirates, and Uzbekistan.

The EU also intends to deploy a new anti-circumvention tool to restrict the sale, supply, transfer, or export of specified sanctioned goods and technology to third countries that pose a high risk of circumvention. This tool would be employed as a “last resort” where other measures and outreach have proven insufficient. Moreover, the EU enhanced its anti-circumvention measures related to transportation, including denying access to vessels which manipulate or turn off their tracking system when transporting Russian oil subject to the oil import ban or G7 price cap.

This package contains a number of other new and notable measures, including:

• A requirement that all EU importers prove that their imports of iron and steel from third countries do not have any Russian inputs;
• An expansion of the luxury goods ban to include yachts and exports of all new and second-hand luxury cars above a certain engine size; and
• A full ban on certain types of machinery components.

Finally, the EU identified a list of economically critical goods (chemicals, machinery, electronics, maritime, and optics/related instruments) that businesses and third countries should be especially vigilant about in transactions.

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