In order to impose and implement sanctions, pre-existing Regulations (EU) No 269/2014 and (EU) No 833/2014 have been amended numerous times in relation to Russia’s activities. The annex to Regulation (EU) No 269/2014 contains the details of persons and entities subject to financial sanctions and Regulation (EU) No 833/2014 contains sectoral economic sanctions, imposing restrictions on specific industries (e.g., restrictions on the import and export of certain goods and prohibitions on the provision of certain services).
In relation to the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, Council Regulation (EC) No 765/2006 has been amended numerous times. The annexes of the regulation contain the details of persons and entities subject to financial sanctions, as well as sectoral economic sanctions, imposing restrictions on specific industries.
The Government of the Republic has also adopted regulations for imposing sanctions in connection with the situation in Belarus (list of subjects) and in connection with the attack on the sovereignty and territorial integrity of Ukraine and the restriction of the provision of services in connection with the war in Ukraine and the imposition of a sanction of the Government of the Republic in connection with the aggression of the Russian Federation and the Republic of Belarus in Ukraine.
Frequently asked questions about the imposition of a sanction of the Government of the Republic in connection with the aggression of the Russian Federation and the Republic of Belarus in Ukraine
Russia has on several occasions violated Ukraine’s sovereignty and territorial integrity. The first restrictive measures were already imposed in 2014 to respond to the destabilising actions of Russia in Eastern Ukraine.
A second wave of restrictive measures was imposed following an unprovoked large-scale military invasion of Ukraine by the Russian armed forces on 24 February 2022, as well as the involvement of Belarus in the aggression against Ukraine.
Since the beginning of Russia’s military aggression, the European Union has adopted several packages of sanctions, which are increasingly being complemented and strengthened. A more detailed overview is provided on the website of the Council of the EU on restrictive measures imposed by the EU in response to the crisis in Ukraine.
In 2014, the Council of the EU adopted Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, and Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.
The annex to Regulation (EU) No 269/2014 contains the details of persons and entities subject to individual sanctions, meanwhile Regulation (EU) No 833/2014 and its annexes contain the relevant information on sectoral sanctions.
These basic legislative acts are constantly being amended and information about the latest changes and different sanctions regimes can be found most easily on the EU Sanctions Map. It includes, for example, restrictive measures against Belarus and Russia, restrictive measures following the illegal annexation of Crimea and Sevastopol, and restrictive measures against Donetsk and Luhansk. The European Commission’s website also provides an overview of restrictive measures and related frequently asked questions.
Pursuant to Section 4 of the International Sanctions Act, Estonia may also impose sanctions on its own. The Government of the Republic adopted regulations to impose sanctions in connection with the situation in Belarus and the attack on the sovereignty and territorial integrity of Ukraine.
Yes, they are. As EU regulations are directly applicable, EU sanctions are binding in all EU Member States from their entry into force, and both natural and legal persons are obliged to impose them. It is also mandatory to implement sanctions of the Government of the Republic from their entry into force and the sanctions imposed by a resolution of the United Nations Security Council before the Council of the European Union adopts a regulation concerning them.
Most frequent questions about financial sanctions
The website of the Financial Intelligence Unit has a search engine for subjects of financial sanctions to identify persons subject to the freezing of assets and the prohibition on making assets and resources available. The web search solution is linked to a database of financial sanctions managed by the European Commission, which contains data on all persons and entities subject to a financial sanction.
The prohibition on making resources and assets available applies to natural and legal persons directly or indirectly owned or controlled by a person subject to a sanction. Although in the latter case, they may not be a person on the list of sanctions, the sanctions also apply to them. Sanctions Guidelines of the European Union (pages 20–22) provide assistance in assessing compliance with the direct and indirect ownership and control criteria.
In most cases, any provision of services also means making resources available. Thus, the provision of services to the subject of a financial sanction is generally prohibited, unless the Financial Intelligence Unit has granted such an authorization.
Most frequent questions about goods
Goods not subject to sanctions can be exported and imported, but foreign trade companies must take into account that customs controls take longer than usual. It is best to monitor the restrictions imposed on goods from the EU Sanctions Map. Additional information can be found on the website of the Tax and Customs Board. In case of doubt, contact the Tax and Customs Board.
Transactions can only be concluded with those Russian and Belarusian banks, that are not under EU sanctions. However, as a result of the sanctions, other transactions involving Russia and Belarus may be subject to additional checks, delays, or rejections.
Last updated: 25.01.2024
