On 20 December 2014 the EU issued Council Regulation 1351/2014 introducing various new sanctions in response to the region’s continued illegal annexation. The most notable are;

• A prohibition on the sale, supply, transfer or export of certain goods and technology “suited for use” in the targeted sectors of: (i) transport; (ii) telecommunications; (iii) energy; and (iv) the prospection, exploration and production of oil, gas and mineral resources. The expanded list of prohibited goods and technology is very wide in scope, and includes items as diverse as refrigerators; forestry machinery; air-conditioning machines; electric motors; and calculating machines and cash registers.
• A prohibition of “services directly related to tourism activities in Crimea or Sevastopol”. European cruise ships are prohibited from calling at (i) Sevastopol; (ii) Kerch; (iii) Yalta; (iv) Theodosia (v) Evpatoria; (vi) Chernomorsk; and (vii) Kamysh-Burun, except in the case of an emergency. This applies to all ships owned and under the operational control of an EU ship owner or any ship flying the flag of an EU member state.

The goods or technology listed cannot be provided to anyone in Crimea or Sevastopol or for use in Crimea or Sevastopol. As is common under EU sanctions, it is also prohibited to provide technical assistance or brokering services or provide financing or financial assistance in respect of any of the listed goods or technology.

In addition to enhanced trade restrictions in Crimea and Sevastopol, investment in Crimea and Sevastopol is prohibited. EU nationals and EU-based companies are prohibited from providing investment services, purchasing or extending ownership in real estate, investing in or providing finance to, entities based in Crimea or Sevastopol, and creating any joint venture in Crimea or Sevastopol or with any entity based in Crimea or Sevastopol.

There are certain exemptions for existing contracts entered into prior 20 December 2014. There are also exemptions for medical use, hospitals, human health and safety and the environment. 

Members with business activities connected to Crimea and Sevastopol are recommended to take appropriate legal advice.

For further information about sanctions in place in respect of Ukranie and other countries please see the Club’s website.

Member Alert is published by The Swedish Club as a service to members. While the information is believed correct, the Club cannot assume responsibility for completeness or accuracy.