Here are the updated FAQs on Russia sanctions and imports:

 

  • Insurance and reinsurance: The updated FAQs clarify that EU companies are prohibited from providing insurance or reinsurance to sanctioned Russian entities, even if the insurance or reinsurance is not provided directly to the sanctioned entity. This includes insurance or reinsurance for goods or services that are themselves subject to EU sanctions.

 

  • Central Securities Depositories (CSDs): The updated FAQs clarify that EU CSDs are prohibited from holding or administering securities issued by sanctioned Russian entities. This includes securities that are already held by the CSDs as well as new securities that are issued after the entry into force of the sanctions.

 

  • Oil imports: The updated FAQs clarify that the EU ban on imports of Russian oil does not apply to oil that is transported by pipeline. This means that EU companies can continue to import Russian oil that is transported through the Druzhba pipeline.

 

  • Circumvention and due diligence: The updated FAQs provide guidance on how EU companies can comply with the sanctions by taking steps to prevent circumvention. This includes conducting due diligence on their customers and suppliers to ensure that they are not doing business with sanctioned entities.

 

  • Provision of services: The updated FAQs clarify that the EU sanctions do not prohibit EU companies from providing certain services to sanctioned Russian entities. This includes services that are necessary for the provision of humanitarian aid or for the maintenance of critical infrastructure.

 

  • Road transport: The updated FAQs clarify that the EU ban on road transport of goods between the EU and Russia does not apply to goods that are in transit through the EU. This means that EU companies can continue to transport goods through the EU if the goods are not intended for consumption in the EU.

 

  • Sale of securities: The updated FAQs clarify that the EU ban on the sale of securities to sanctioned Russian entities does not apply to securities that are already held by EU investors. This means that EU investors can continue to hold securities that were issued by sanctioned Russian entities before the entry into force of the sanctions.

 

  • State-owned enterprises (SOEs): The updated FAQs clarify that the EU sanctions do not prohibit EU companies from doing business with SOEs that are not directly owned or controlled by the Russian government. However, EU companies should be aware that they may be exposed to reputational risks if they do business with SOEs that are involved in the Russian government's war in Ukraine.

 

  • Investment funds: The updated FAQs clarify that the EU sanctions do not prohibit EU investors from investing in investment funds that hold securities issued by sanctioned Russian entities. However, EU investors should be aware of the risks associated with investing in these funds, including the risk of losing their investment if the sanctions are tightened or if the sanctioned entities go bankrupt. 

 

  • Oil price cap: The updated FAQs provide guidance on how EU companies can comply with the proposed oil price cap by refusing to purchase Russian oil that is sold above a certain price. This could involve refusing to refine Russian oil or refusing to transport Russian oil.