On 16 December 2014, the European Commission (the “Commission”) published guidance on the EU’s sanctions (of 31 July 2014) against Russia. This follows guidance published by the UK Department for Business, Innovation & Skills (“BIS”) on 5 December 2014.
The EU guidance covers frequently asked questions relating to restrictive measures on financial assistance and financial services measures (trade finance, emergency funding, loans and capital markets). The UK guidance also includes a number of frequently asked questions and covers: the restrictions on energy-related goods, technologies and associated services; the arms embargo; restrictions on dual use items; and licence applications. BIS commented that the average time for processing a licence application for Russia is 21 working days with 49% of applications completed within 20 working days.
Whilst both guidance documents are non-binding they are a useful tool for interpreting the scope of the EU’s sanctions against Russia.