On May 9, 2023, in a press statement with Ukrainian President Volodymyr Zelenskyy, President of the European Commission, Ursula von der Leyen, announced further information regarding the EU’s pending 11th package of sanctions against Russia.

According to Ursula von der Leyen, the focus of this sanctions package is to further crack down on the circumvention of sanctions, which she noted will be done in close coordination with the G7 countries (i.e., the U.S., UK, Germany, France, Italy, Canada, and Japan). In particular, Ursula von der Leyen noted that the 11th package of sanctions will include the following three key elements:

  • Transit ban on additional products such as advanced technology products and aircraft parts that are exported to third countries via Russia;
  • A new tool to combat sanctions circumvention where, if the Commission recognises that goods are being exported from the EU to Russia via third countries, the Commission can propose to the EU Member States to sanction the export of those goods; and
  • A ban on ‘shadow’ entities from Russia and third countries that are deliberately evading EU sanctions.

The precise details regarding the scope and application of these new measures and tools remain to be seen and also remains subject to further discussion and approval by all 27 EU Member States. We will follow up with a client alert once the legislation introducing the EU’s 11th package of sanctions against Russia is agreed and published.