The European Union (EU) adopted additional measures on 18 December 2014 widening the scope of existing restrictions in relation to goods originating in Crimea or Sevastopol, on the provision of financing or financial assistance related to the import of such goods as well as on trade and investment in infrastructure projects in the transport, telecommunications and energy sector and concerning the exploitation of oil, gas and minerals.

In particular, Council Regulation (EU) No 1351/2014 (the EU Regulation) provides for:

  • a ban on all foreign investments in Crimea or Sevastopol, as well as a prohibition on services directly related to the investment ban; 
  • a prohibition on services related to tourism activities, including in the maritime sector, and in the sectors of transport, telecommunications, energy and exploitation of oil, gas and minerals in Crimea and Sevastopol; and 
  • the implementation of a prohibition on the sale, supply, transfer, or export to Crimea or Sevastopol or for use in Crimea or Sevastopol of certain goods and technology suited for use in the above sectors as listed in Annex II to the EU Regulation.

Furthermore, the EU Regulation imposes a prohibition on the provision of services directly related to tourism activities in Crimea and Sevastopol and in particular, a prohibition on any ship providing cruise services and flying the flag of an EU Member State, or owned, under the operational control or responsibility of an EU ship owner or operator, from entering into or calling at any port situated in the Crimean Peninsula, as listed in Annex III to the EU Regulation.

In order to minimise the impact of these measures on economic operators and on the civilian population in Crimea or Sevastopol, the EU Regulation provides for an exception (in most case limited until 21 March 2015) to the prohibitions for the execution of obligations arising from contracts concluded prior to 20 December 2014, or ancillary contracts necessary for the execution of such contracts, provided that relevant competent authorities have been informed at least five working days in advance. In addition, the EU Regulation provides for certain licensing exceptions in relation to goods and technology and associated services necessary for health and safety, including the safety of existing infrastructure, or the environment.