EU sanctions against Russia: what changes the 20th business package

In general, the European Union is no longer simply blocking direct trade. The aim is now to prevent circumvention via third countries or intermediaries. In fact, this changes the way compliance is approached: it is no longer enough to verify the end customer, it is necessary to understand the entire chain of the operation.

At the sectoral level, the energy sector remains a priority, with stronger measures against Russian oil and the "phantom fleet", used to maintain certain parallel trade flows. Several hundred ships are now being targeted, making these circuits more difficult to use.

In addition, the financial rules are also tightening, with further bank exclusions and a strengthened framework for certain transactions involving crypto-assets when they can contribute to circumvention schemes.

In a more operational approach, certain product categories are now subject to increased vigilance. These include industrial and technological equipment which, although apparently classic, can become sensitive according to their use and destination.

More broadly, the measures cover a wide range of industrial products, including raw materials, machinery and electronics. The customs code remains the basis of reference here, but it must now be analysed with context, use and final destination.

At the same time, sanctions are not limited to property. They also cover associated services such as technical assistance, brokering, financing or transfers of know-how and intellectual property.

Thus, an operation may be involved even if the product itself does not seem sensitive, simply because of the accompanying service.

Finally, compliance is no longer limited to an isolated verification of a customs code. It requires a global analysis of the operation, product, intermediaries, associated services and actual destination.