Insights | December 18, 2023

Roschier Insights Seminars: The Christmassy Sanctions Review

As we approach the end of another year overshadowed by Russia's invasion of Ukraine, the landscape of EU sanctions remains a topic that requires constant attention from businesses across Europe.

On Wednesday, 13 December 2023, our Dispute Resolution team experts Paula Airas, Laila Sivonen and Lauri Säilä from our Helsinki office and Annika Pynnä Lindskog from our Stockholm office hosted a hybrid client event in Helsinki on the latest EU sanctions.

The panelists discussed their experiences over the past few years on, for example, the appropriate level of due diligence, sanctions circumvention and how to be compliant in practice. In addition, the upcoming 12th sanctions package was touched upon.

Here are the key takeaways from the discussion:

• EU sanctions continue to evolve despite the challenging political climate. The 12th sanctions package has been a long time in the making, and reaching political agreement on its scope has been difficult. Nonetheless, soon after the event, EU agreed on the 12th package of sanctions against Russia, including a phased ban on imports of Russian diamonds, a tightening practice relating to the cap on Russian oil prices and measures to prevent Russia from obtaining dual-use goods by requiring EU companies to have their counterparties for certain products sign contracts prohibiting re-export to Russia. The 12th package is reported to become effective as of 1 January 2024.
• Compliance with EU sanctions requires a company-wide commitment. The current media interest should act as a motivator for everyone. There has been a lot of media interest lately in the activities of European companies in Russia, and especially in the European goods that either knowingly or through circumvention still end up in the country despite sanctions and public announcements that all Russian operations have ended. To mitigate risks, companies should work to ensure that their compliance practices cover all the necessary aspects of the business and are adhered to at all levels of the organization. Circumvention is best prevented through cooperation.
• Do what you can, don’t be naive. What is sufficient for companies? Both the sanctions regulations and the Russian attempts to limit their practical impact are constantly evolving, and it may seem difficult for companies to keep up with the rules in their day-to-day operations. The most important thing is to remain vigilant and understand the risks relevant for your business, as well as to have well-documented compliance practices based on such risk assessment.
• The arsenal of analytical methods and compliance tools is growing, and our team is ready to help you with any challenge, big or small. In considering what level of compliance is possible, companies are advised to keep up to date with sanctions compliance services, which are naturally evolving as the practical importance of the issue increases. We are constantly adopting new tools to help our clients be as effective as possible and are happy to assist you in obtaining background information and making sure that relevant databases are sufficiently vetted.

We would like to thank everyone who attended the event. Our experts are available to discuss any sanctions-related issues you may have.