B4Ukraine: Civil Society Recommendations on Strengthening the Existing Sanctions Regime on Russia Ahead of the Eu’s 12th Sanctions Package

In the past 18 months the EU and its allies have imposed unprecedented sanctions to curb Russia’s ability to pursue its war in Ukraine. Broad EU sanctions imposed across key sectors has constrained the Russian economy, as has the decision of more than 780 multinational companies to divest.

Unfortunately, as these measures begin to bite, Russia has continued to adapt to and evade sanctions, reducing the overall impact. With Russian oil now on average selling significantly above the price cap, and Russia maintaining and even increasing pipeline and LNG gas sales to Europe, Russia’s energy revenues look set to continue rising. As of September 2023, Russia’s total fossil fuel export revenues have risen in the most recent two consecutive months. Despite an initial drop-off following the full-scale invasion of Ukraine in February 2022, Russian imports of sensitive technology have largely returned to pre-war levels. To prevent a resurgence of the key energy and dual use sectors of the economy, additional action is clearly needed.

With this in mind, we – a coalition of leading experts and civil society organizations – welcome the development of a 12th Package of EU sanctions against Russia. In support of its development, this paper outlines new sanctions that can and should be imposed on Russia, as well as other measures to promote and define EU expectations around responsible business conduct. Combined, these would accelerate an end to its war against Ukraine and further pressure the Kremlin’s economic base. Priority areas include: