Introduction
On 24 June 2024, the European Union (“EU”) issued its 14th package of sanctions against Russia. At close to 600 pages, the 14th package is also one of the most comprehensive to date. There are over 30 new measures, [These include: new ban on LNG, extension to existing bans (e.g., further restrictions on flights, 29 additional pages of goods prohibited for export, further restriction on vessels seeking to dock in EU, tighter reporting requirements on diamonds, and extension of ban on Russian transport undertaking to those also with minority (25%) Russian ownership), new bans (e.g., on import of Ukrainian cultural goods, helium, Russian SWIFT (called SPFS)), new licensing ground (e.g., for humanitarian aid and medical devices), extension of various wind-downs (e.g., for intragroup services), extension of the no re-export clauses (e.g., for dual-use goods and high risk goods).] though four are truly ground-breaking innovations by the European Commission (“EC”). These
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