Update on the Ninth Sanctions Package
Amendments to the existing EU sanctions regime were introduced in the ninth package of sanctions against Russia.


On 16 December 2022, amendments to the existing EU sanctions regime were introduced in the ninth package of sanctions against Russia.

EU Council Regulation (EU) 2022/2475 of 16 December 2022 amends Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. It introduces an extended deadline for the derogation allowing divestments by listed entities. Specifically, it amends Article 6(b)(3) of EU Regulation 269/2014 by updating the deadline from 31 December 2022 until 28 February 2023.

Article 6(b)(3) permits the release of economic assets and facilitates the unfreezing of assets so they can be the subject of a sale and transfer. National competent authorities are entrusted with authorising such operations.  One general aim of the authorisation process is to assist entities which find themselves prohibited from dealing with an asset, to which they have a contractual right of use to seek the release of, in a manner that is compatible with the sanctions goals.   

William Fry has successfully acted for a number of non-sanctioned parties in court applications seeking orders for specific performance of leases and purchase options under various charterparty contracts. Following the successful court applications, William Fry advised the parties on their applications for derogations to the competent authorities under Article 5 of EU Regulation 269/2014. Article 5 allows for the release of funds or economic resources by the competent authorities of Member States where a judicial decision has been made, provided the funds or economic resources are being used to satisfy the orders made by the relevant Court. William Fry also advises non-sanctioned parties seeking derogations under Article 6(b)(3) of EU Regulation 269/2014. 

Contributed by Niamh McCabe

Key Contacts

Paul Convery Partner

Laura Murdock Partner

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