SANCTIONS UPDATE – EU Amends and Clarifies Russia Sanctions
On 5 December 2014, the Council of the EU published amendments to its sanctions regime against Russia in order to clarify certain provisions in its previous measures.
The Council has clarified the geographical scope of the restrictions regarding oil exploration and production projects in Russia by specifically referring to the “Exclusive Economic Zone and Continental Shelf”. The types of projects that are covered by the restrictions have been specified (e.g. oil exploration and production in waters deeper than 150 metres). An amendment to the exceptions for required authorisation has also been made. The amendment concerns duly justified emergency cases. Additionally the scope for the enforcement of operative contracts has been revised to allow for performance under ancillary contracts.
Amendments have also been made to the prohibitions on, and exceptions to the prohibition on, making new loans or credit with a maturity exceeding 30 days. The prohibitions do not apply to drawdowns or disbursements made under a contract concluded before 12 September 2014 provided that certain conditions are met.