EU Amends Russia Sanctions FAQs Over Asset Freezes and Oil Imports
The European Commission last week amended two frequently asked questions under its Russia sanctions regime guidance. Under its asset freeze FAQs, the commission added FAQ 15, which says voting rights by shareholders with qualifying holdings in an EU ban should be viewed as an intangible economic resource given that they can be used to obtain funds, goods or services. Under the oil imports FAQ section, the commission added FAQ 2, which includes information on imports into the EU or the purchase or transfer of goods that originate in a third country but are mixed during transport with goods that originate in Russia.
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“Russian oil transported together with oil of other origin in mixed fashion is subject to the prohibition," the FAQ said. "However, as a consequence of transportation through a pipeline that serves both non-Russian and Russian origin productions, oil originating in a third country can be mixed for technical reasons with Russian originating oil, due to infrastructural constraints. Such mixing should not increase or facilitate the production and or marketing of Russian-origin oil, nor generate any avoidable financial flows or indirect benefits in favour of Russian actors for the Russian-origin oil transported via the pipeline, excluding the necessary transportation costs."