On 30 May 2023, the Council of the European Union (
“EU”) updated its list of persons subject to blocking sanctions (
“Designated Persons”).
The changes affected two regimes of restrictive measures (sanctions programmes) concerning
Russia and
Moldova.
The changes have been made in anticipation of the “eleventh package” of restrictive measures against Russia, but do not constitute the “eleventh package” itself.
Changes in the restrictive measures regime concerning Moldova
Previously
we wrote about the EU introducing a separate restrictive measures regime in connection with the political situation in Moldova.
A month later, the EU Council first introduced restrictive measures under the new regime against the following persons:
- Ilan Mironovich Shor;
- Gheorghe Petru Cavcaliuc;
- Marina Tauber;
- Igor Yuryevich Chaika; and
- Vladimir Gheorghe Plahotniuc.
As expected, these changes have broadened the grounds on which the EU can impose sanctions against Russian citizens and entities.
Changes in the Russian restrictive measures regime
The EU Council has listed Alexander Kalinin and Grigory Karamalak, who are both citizens of Russian and Moldova, as Designated Persons.
Importance and Effect of the News
Therefore, business figures and politicians from Moldova have begun to fall under the EU regime of restrictive measures against Russia, suggesting a potential convergence of the two sanctions programmes. As we wrote previously, this circumstance should be taken into account in any sanctions risk analysis.
