EU launches new sanctions framework targeting Russia regarding human rights violations
3 min read
On May 27, 2024, the EU adopted a new sanctions regime in relation to deemed human rights violations and internal repression in Russia. The new sanctions measures include asset freezes and export restrictions targeting equipment used for internal repression and information security.
New sanctions regime
The new sanctions regime targeting Russia was established due to EU concerns about the deteriorating human rights situation in Russia, including in relation to the death of Alexei Navalny.1
This regime is separate from the EU's Russia-related sanctions in response to the invasion of Ukraine and supplements the EU's Global Human Rights sanctions regime, allowing for the EU to implement further Russia-specific measures, such as trade restrictions based on findings of human rights violations and internal repression in Russia.
The new regime adds a further layer to the EU's sanctions against Russia. In situations where these rules overlap with existing EU sanctions under EU Regulation 833/2014, the stricter rules will prevail.
Asset freeze and travel bans
Under the new sanctions regime, the EU has designated 19 individuals linked to the Russian judicial system, and one entity, the Federal Penitentiary Service in Russia.2 The newly listed individuals are subject to a travel ban and all listed parties are subject to asset freeze restrictions, meaning their assets in the EU must be frozen and EU persons are prohibited from making new funds or economic resources available to them, directly or indirectly, unless authorized or exempt.
A couple of months ago, the EU – also as a reaction to the death of Alexei Navalny – designated 33 individuals and two entities (i.e., the penal colonies that held Navalny) under its Global Human Rights sanctions regime.3
Export restrictions on key items
The new sanctions regime also introduced export restrictions on internal repression and information security items in relation to Russia.
Internal repression equipment
The new export restrictions prohibit the sale, supply, transfer or export, directly or indirectly, of specified internal repression items to any person in Russia, or for use in Russia. In line with internal repression item restrictions under other EU sanctions regimes, such restricted items include firearms, ammunition, bombs and explosives, military knives and related production equipment. The export restrictions also apply to related financing, technical or financial assistance and brokering services.
Certain limited exceptions and grounds for authorizations apply.
Information security items
Certain other new export restrictions prohibit the sale, supply, transfer or export, directly or indirectly, of specified information security and telecommunications equipment, technology and software that could be used for internal repression to any person in Russia or for use in Russia. Similar to restrictions under other EU sanctions regimes, these items include equipment, technology and software that may be used for applications such as code breaking or radio frequency monitoring, speaker recognition/processing and network interception, but exempts certain mass-market and public domain software.
Ruth Benbow (Knowledge Manager, London) contributed to the development of this publication
1 See Council Regulation (EU) 2024/1485 of May 27, 2024 concerning restrictive measures in view of the situation in Russia.
2 See Council Implementing Regulation (EU) 2024/1488 of May 27, 2024 implementing Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia.
3 See Council Implementing Regulation (EU) 2024/952 of March 22, 2024 implementing Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses.
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