On 25 February 2022, the Council adopted new trade sanctions (regulation 2022/328) in response to Russia’s invasion of Ukraine.

The sanctions involve a prohibition against export of dual-use products and certain products and services within the energy and aviation sector and measures restricting Russian individuals' and companies' access to financial markets.

Prohibition against export of dual-use products and technology

The regulation generally prohibits export of products on the EU’s dual-use list and certain forms of advanced technology to Russia. It also introduces an absolute prohibition against exports to specified Russian companies and other entities to which an export licence cannot be issued.

Prohibition against export within the energy and aviation sector

The new sanctions ban exports of certain products and technologies suitable for use in the processing of crude oil (oil refinery) or aviation or the space industry to natural or legal persons in Russia or for use in Russia. The prohibition also includes export of ancillary services, e.g. technical assistance and delivery of components. The sanctions will not apply to contracts entered into before 26 February 2022 if they are performed within a certain date.

Restrictions on access to the financial markets

The new sanction package also introduces measures restricting financial transactions with the EU. This includes i.a. a prohibition against selling negotiable securities in Euro which have been issued after 26 February 2022 to Russian citizens or natural persons residing in Russia and legal persons established in Russia.

The sanctions also include a prohibition against issuing and trading in negotiable securities issued by certain legal persons, e.g. large Russian banks which are subject to Russian control or ownership and related investment services. From 12 April 2022, it will also be prohibited for European stock exchanges to carry out listings and provide services regarding negotiable securities owned by legal persons established in Russia and being subject to more than 50 % public ownership.

The regulation came into force on 26 February 2022.

Horten follows the development of the sanctions against Russia, and you are welcome to contact us for specific advice on export control and trade sanctions.


Christian Gregersen

Managing Partner

Søren Toft Bjerreskov


Sofie Lindholm


Lasse Dreiøe Jansen

Assistant Attorney