Sanction Risk list regarding countries updated until: 24 Mar 2023
Country EU Sanctions US Sanctions Remarks
Afghanistan (AF)

measures against the Taliban:
- embargo on arms and related materiel
- ban on provision of certain services
- freezing of funds and economic resources
- restrictions on admission
- freezing of funds and economic resources
- ban on provision of certain services

Yes, for details what sanctions apply, see above mentioned links or contact us.

As of Feb 11, 2022, Executive Order Protecting Certain Property of Da Afghanistan Bank for the Benefit of the People of Afghanistan. 

High Risk

Balkans related (--)

see Bosnia and Herzegovina and/or Moldova and/or Serbia and Montenegro

Yes, for details what sanctions apply, see above mentioned links or contact us. New executive order - Blocking Property and Suspending Entry into the United States of Certain Persons Contributing to the Destabilizing Situation in the Western Balkans (June 8, 2021).

Medium Risk

Belarus (BY)

- embargo on arms and related materiel
- ban on exports of equipment for internal repression
- ban on provision of certain services
- restrictions on admission of listed natural persons
- freezing of funds and economic resources of listed persons, entities and bodies
- the member States deny permission to land in, take off from or overfly their territories to any aircraft operated by Belarusian air carriers, including as a marketing carrier.
- trade restrictions concerning petroleum products, potassium chloride ('potash') and goods used for the production or manufacturing of tobacco products
- restrictions on access to Union capital markets in relation to the Belarusian Government, as well as Belarusian state-owned financial institutions and entities
- ban on provision of insurance and re-insurance to the Belarusian Government and Belarusian public bodies and agencies

- valid until 28.02.2023
- 15.02.2016 Council conclusions on Belarus
- 02.10.2020 EU imposes sanctions for repression and election falsification

as of 02-March-2022 due to the involvement of Belarus in the invasion of Russia into the Ukraine:
- Introducing further restrictions related to the trade of goods used for the production or manufacturing of tobacco products, mineral fuels, bituminous substances and gaseous hydrocarbon products, potassium chloride (‘potash’) products, wood products, cement products, iron and steel products and rubber products.
- Introducing further restrictions on exports of dual-use goods and technology and on the provision of related services, as well as restrictions on exports of certain goods and technology which might contribute to Belarus's military, technological, defence and security development, together with restrictions on the provision of related services.

as of 09-March-2022 due to the involvement of Belarus in the invasion of Russia into the Ukraine:
- prohibiting the listing and provision of services in relation to shares of Belarusian state-owned entities on Union trading venues.
- limiting the financial inflows from Belarus to the Union.
- prohibiting transactions with the Central Bank of Belarus.
- restricting the provision of specialised financial messaging services to certain Belarusian credit institutions and their Belarusian subsidiaries.
- adding obligations on the Network Manager for air traffic management network functions of the single European sky regarding overflight prohibitions.

as of 08-April-2022 due to the involvement of Belarus in the invasion of Russia into the Ukraine:
- prohibiting the sale to Belarus of transferable securities denominated in any official currency of a Member State.
- prohibiting the sale, supply, transfer or export to Belarus of banknotes denominated in any official currency of a Member State.
- prohibiting any road transport undertaking established in Belarus from transporting goods by road within the territory of the Union, including in transit.

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

Bosnia and Herzegovina (BA)

- restrictions on admission
- freezing of funds and economic resources
- valid until 31.03.2024
- restrictions on admission of persons who committed certain acts of violence at Mostar

see Balkans related

Low Risk

Burma (MM)

see Myanmar

Yes, sanctions issued February 10th 2021 by Executive order 14014 (previous sanctions of the US were lifted in its entirety on October 7th, 2016).

Medium Risk

Burundi (BI)

- restrictions on admission of certain natural persons
- freezing of funds and economic resources
- valid until 31.10.2023
- prohibition to satisfy certain claims

No, sanctions of the US lifted in its entirety on November 18th, 2021.

Medium Risk

Central African Republic (CF)

- embargo on arms and related materiel
- ban on provision of certain services
- restrictions on admission of certain natural persons
- freezing of funds and economic resources
- commitment to dispose of arms and related materiel that are in breach of the embargo
- ban on provision of certain services
- prohibition to satisfy claims

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

China (CN)

- embargo on arms

Yes, for details what sanctions apply, see above mentioned links or contact us.
12-11-2020 issued Executive Order Addressing the Threat from Securities Investments that Finance Communist Chinese Military Companies.

Low Risk

Conakry (GN)

see Guinea (Republic of)

No

Medium Risk

Congo (Democratic Republic of) (CD)

- embargo on arms and related matériel
- ban on provision of certain services
- freezing of funds and economic resources
- restrictions on admission
- Article 3(2) shall apply until 12.12.2023

Yes, for details what sanctions apply, see above mentioned links or contact us

Medium Risk

Cote d'Ivoire (CI)

No, sanctions of the EU lifted in its entirety on June 9th, 2016, based on UNSCR 2283 (2016)

No, sanctions of the US lifted in its entirety on September 14th, 2016, based on UNSCR 2283 (2016)

Low Risk
see Ivory Coast

Crimea (--)

see Ukraine

Yes, for details what sanctions apply, see above mentioned links or contact us.

Extreme Risk

Cuba (CU)

No specific EU sanctions exist, mind the EU anti blocking statue.

Yes, for details what sanctions apply, see above mentioned links or contact us.

High Risk

Egypt (EG)

No, sanctions of the EU lifted in its entirety on March 12th, 2021.

No

Low Risk

Eritrea (ER)

No, sanctions of the EU lifted in its entirety on December 11th, 2018, based on UNSCR 2444 (2018).

No

Low Risk

Ethiopia (ET)

No

Yes, sanctions issued September 17th 2021 by Executive order 14046. For details what sanctions apply, see above mentioned links or contact us.

Medium Risk

Guinea (Republic of - Conakry) (GN)

- ban on provision of certain services
- restrictions on admission
- freezing of funds and economic resources
- valid until 27.10.2023

No

Medium Risk

Guinea-Bissau (Republic of) (GW)

- restrictions on admission
- freezing of funds and economic resources

No

Medium Risk

Haiti (HT)

- embargo on arms and related materiel
- restrictions on admission of listed natural persons
- freezing of funds and economic resources of listed persons, entities and bodies
- freezing of funds and economic resources of persons and entities engaged in or supporting gangs involved in violence, criminal activities or human rights abuses, which undermine the peace, stability and security of Haiti and the region.

- prohibition to satisfy certain claims in accordance with UN Security Council Resolution No 917(1994)
(NB. Common Position 94/681/CFSP has repealed the remainder of the restrictive measures)
- prohibition to satisfy claims with regard to contracts and transactions whose performance is affected by the measures taken in accordance with UN Security Council Resolutions 917(1994), 841 (1993), 873 (1993) and 875 (1993)

No

Medium Risk
Added per 25-11-2022 based on UN resolution 2653(2022)

Hong Kong (HK)

No

Yes, for details what sanctions apply, see above mentioned links or contact us.

Iran (IR)

- Joint Comprehensive Plan of Action (JCPOA) was implemented on 16 January 2016 (see *JCPOA*).
- restrictions on admission of certain persons
- *JCPOA* freezing of funds and economic resources
- valid until 13.4.2023
- embargo on telecommunications monitoring and interception equipment
- embargo on equipment which might be used for internal repression
- ban on provision of certain services
- embargo on arms and related materiel
- embargo on nearly all dual-use goods and technology
- embargo on certain goods and technology which could contribute to enrichment-related, reprocessing or heavy water-related activities, or to the development of nuclear weapon delivery systems or to the pursuit of activities related to other topics about which the IAEA has expressed concerns
- prohibition of procurement from Iran of arms and related material, nearly all dual-use goods and technology and certain other goods and technology
- (arms and other embargoes related) ban on provision of certain services
- (arms and other embargoes related) ban on certain investment
- controls on export of certain other sensitive goods and technology
- control on provision of certain services
- control on certain investment
- embargo on key equipment and technology for the oil and natural gas industries
- ban on provision of certain services (to the oil and natural gas industries)
- ban on certain investment (in the oil and natural gas industries)
- ban on certain Iranian investment (nuclear industry)
- ban on new commitments for grants, financial assistance and concessional loans to the Government of Iran
- *JCPOA* restrictions on transfers of funds to and from Iran
- restrictions on establishment of branches and subsidiaries of and cooperation with Iranian banks
- restrictions on provision of insurance and re-insurance
- restrictions on issuance of and trade in certain bonds
- vigilance over business with Iran
- inspection of and prior information requirement on cargoes to and from Iran
- restrictions on access to EU airports for certain cargo flights
- ban on provision of certain services to certain vessels and aircraft
- restrictions on admission of listed natural persons
- freezing of funds and economic resources of listed persons, entities and bodies
- measures to prevent certain specialised teaching or training
- prohibition to satisfy claims made by certain persons, entities or bodies
- import ban on crude oil and petroleum products- ban on provision of certain services, including transport (related to crude oil, and petroleum products from Iran)
- *JCPOA* import ban on petrochemical products
- *JCPOA* prohibition on transport of Iranian crude oil
- *JCPOA* ban on provision of certain services (related to Iranian crude oil)
- *JCPOA* ban on provision of certain services (related to prohibition on the provision of insurance and reinsurance and transport of Iranian crude oil)
- ban on provision of certain services (related to petroleum products)
- *JCPOA* ban on provision of certain services (related to petrochemical products)
- embargo on key equipment and technology for the petrochemical industry
- ban on provision of certain services (to the petrochemical industry)
- ban on certain investment (in the petrochemical industry)
- *JCPOA* ban on trade in gold and precious metals with the Government of Iran
- ban on trade in diamonds with the Government of Iran
- ban on provision of new Iranian banknotes and coins
- ban on provision of specialised financial messaging services to those subjected to the freezing of funds and economic resources
- import ban on natural gas
- ban on provision of certain related services (related to natural gas)
- embargo on graphite
- embargo on certain raw and semi-finished metals
- ban on provision of certain services (related to graphite and metals)
- embargo on key naval equipment and shipbuilding technology
- ban on provision of certain related services (related to key naval equipment and shipbuilding technology)
- prohibition of construction of new oil tankers for Iran
- embargo on certain software for integrating industrial processes
- ban on provision of certain related services
- ban on Member States' commitments for financial support for trade with Iran
- control of transactions of EU financial institutions with banks domiciled in Iran and their subsidiaries, branches and other financial entities outside Iran
- ban on provision of flagging and classification services to certain vessels
- *JCPOA* ban on 'supply' of certain vessels to Iran
- vigilance requirements for EU financial institutions in their activities with banks domiciled in Iran and their branches and subsidiaries
- ban on certain Iranian investment (nuclear industry)
- monitoring of activities of EU branches and subsidiaries of credit and financial institutions domiciled in Iran
- enhanced vigilance as regards transactions of EU financial institutions with credit and financial institutions domiciled in Iran and with the latter’s branches and subsidiaries

Yes, Since 4 November 2018, all US sanctions against Iran have been reinstated.
8 May 2019, "Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran"

The JCPOA was implemented on 16 January 2016, nevertheless, on May 8, 2018, the President announced his decision to cease the United States’ participation in the Joint Comprehensive Plan of Action (JCPOA), and to begin re-imposing, following a wind-down period, the U.S. nuclear-related sanctions that were lifted to effectuate the JCPOA sanctions relief. In conjunction with this announcement, the President issued a National Security Presidential Memorandum (NSPM) directing the Secretary of State and the Secretary of the Treasury to prepare immediately for the re-imposition of all of the U.S. sanctions lifted or waived in connection with the JCPOA, to be accomplished as expeditiously as possible and in no case later than 180 days from the date of the NSPM.
To implement the President’s direction, the Departments of State and of the Treasury will take steps necessary to establish a 90-day and a 180-day wind-down period for activities involving Iran that were consistent with the U.S. sanctions relief provided for under the JCPOA. OFAC expects that all the U.S. nuclear-related sanctions that had been lifted under the JCPOA will be re-imposed and in full effect.

After the 90-day wind down period ends on August 6, 2018, the U.S. government will re-impose certain sanctions that were lifted pursuant to the JCPOA, including sanctions on associated services related to the activities.

Following the 180-day wind-down period ending on November 4, 2018, the U.S. government will re-impose the remaining sanctions that were lifted pursuant to the JCPOA, including sanctions on associated services related to the activities.

Persons engaging in the activity listed above undertaken pursuant to the U.S. sanctions relief provided for in the JCPOA should take the steps necessary to wind down those activities by August 6, 2018 resp. November 4, 2018, to avoid exposure to sanctions or an enforcement action under U.S. law.

For details what sanctions apply, see above mentioned links or contact us.

Extreme Risk

Iraq (IQ)

- confirmation of embargo on arms and related materiel
- restrictions on trade in cultural goods
- freezing of funds and economic resources
- transfer of such funds and economic resources to Development Fund for Iraq
- *expired on 30 June 2011* immunities and restrictions concerning payment for petroleum and gas exported by Iraq
- prohibition to satisfy claims with regard to contracts and transactions whose performance is affected by the measures taken in accordance with UN Security Council Resolution 661(1990) and related resolutions

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

Israel (IL)

No

No

Low Risk
Arabic countries prohibit transactions involving Israel

Ivory Coast (CI)

No, sanctions of the EU lifted in its entirety on June 9th, 2016, based on UNSCR 2283 (2016)

No, sanctions of the US lifted in its entirety on September 14th, 2016, based on UNSCR 2283 (2016)

Low Risk

Korea (Democratic People's Republic of) (KP)

- embargo on arms and related materiel
- ban on exports of certain goods and technology
- prohibition of procurement from DPRK of arms, related materiel and other goods and technology
- ban on provision of certain services
- ban on provision of new DPRK banknotes and coins
- ban on trade in gold, precious metals and diamonds with the Government of DPRK
- ban on exports of luxury goods
- ban on public provided financial support for trade where such support could contribute to DPRK’s nuclear-related, ballistic missile-related or other weapons of mass destruction-related programmes
- ban on new commitments for grants, financial assistance and concessional loans to the DPRK
- enhanced monitoring of the activities of EU financial institutions with banks domiciled in DPRK and their subsidiaries, branches and other financial entities outside DPRK
- restrictions on establishment of branches and subsidiaries of and cooperation with DPRK banks
- restrictions on issuance of and trade in certain bonds
- inspection of and prior information requirement on cargoes to and from DPRK
- restrictions on access to EU airports for certain flights
- ban on provision of certain services to certain vessels and aircraft
- restrictions on admission for certain persons
- freezing of funds and economic resources
- measures to prevent certain specialised teaching or training
- enhanced vigilance over DPRK diplomatic personnel
- prohibition to satisfy certain claims made by certain persons, entities and bodies
- ban on import and purchase of goods and technology (which could contribute to North Korea's nuclear-related, other weapons of mass destruction-related or ballistic missile-related programmes)
- ban on provision of certain services (related to such goods and technology)
- ban on exports of luxury goods
- additional ban on exports and imports of certain goods and technology which could contribute to DPRK’s nuclear-related, ballistic missile-related or other weapons of mass destruction-related programmes
- prior information requirement on cargoes to and from DPRK
- measures to be applied by EU credit and financial institutions to exercise vigilance over their activities with banks domiciled in DPRK and their subsidiaries, branches and other financial entities outside DPRK
- restrictions on access to EU ports for certain vessels
- ban on provision to certain DPRK vessels of bunkering and ship supply services
- restrictions on certain flights (EU airports, overflight)

see North Korea

Extreme Risk

Lebanon (LB)

- embargo on arms and related material
- ban on provision of certain services
- restrictions on admission of persons suspected of involvement in the planning, sponsoring, organising or perpetrating of the murder of former Prime Minister of the Lebanon, Rafiq Hariri on 14 February 2005
- freezing of funds and economic resources of those persons
- commitment to cooperate with international investigation into that murder
- valid until 31-07-2023

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

Liberia (LR)

No, sanctions of the EU lifted in its entirety on June 20th, 2016, based on UNSCR 2288 (2016)

No, Emergency With Respect to the Actions and Policies of Former Liberian President Charles Taylor., terminated November 12, 2015

Low Risk

Libya (LY)

- embargo on arms and related materiel
- embargo on equipment which might be used for internal repression
- ban on provision of certain services
- prohibition of procurement from Libya of arms and related materiel and of equipment which might be used for internal repression
- commitment to inspect vessels and aircraft bound to or from Libya, if certain conditions are met
- commitment to deny permission to aircraft to land in, take off from or fly over a Member State's territory, if certain conditions are met
- inspection of and specific restrictions on certain vessels in order to stop illegal exports of crude oil from Libya
- restrictions on admission
- freezing of funds and economic resources
- confirmation of the freezing of certain funds and economic resources which were frozen as of 16.9.2011
- vigilance requirement when doing business with Libyan entities
- prohibition to grant certain claims to listed persons and entities and any other persons and entities in Libya, including the government of Libya
- prior information requirement on cargoes to and from Libya
- restrictive measures against three specific persons valid until 02.04.2021
- export restrictions on certain goods to Libya which may be used for smuggling migrants and trafficking in human beings

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

Mali, Republic of (ML)

- freezing of funds and economic resources
- Article 1a(1) and Article 2a(1) and (2) valid until 14-12-2023

Yes, UN sanctions against Mali of September 2017 were implemented as of 26 July 2019. For details what sanctions apply, see above mentioned links or contact us.

Medium Risk
Added per 28-9-2017

Moldova (MD)

- restrictions on admission for certain persons
- valid until 31.10.2023

see Balkans related

Low Risk

Myanmar (MM)

- Sanctions on Myanmar changed drastically on 2 April 2013
- embargo on arms and related materiel
- ban on exports of equipment for internal repression
- ban on provision of certain services
- valid until 30.04.2023

see Burma

Medium Risk

Nicaragua (NI)

- Freezing of funds and economic resources of certain natural or legal persons.
- This Decision shall apply until 15 October 2023

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

North Korea (KP)

see Korea (Democratic People's Republic of)

Yes, for details what sanctions apply, see above mentioned links or contact us.

Extreme Risk

Russian Federation (RU)

- see also Ukraine
- embargo on arms and related materiel
- embargo on dual-use goods and technology, if intended for military use or for a military end-user
- ban on imports of arms and related materiel
- (arms and related materiel related) ban on provision of certain services
- (dual-use goods and technology related) ban on provision of certain services
- (deep water, Arctic and shale oil related) controls on export of certain equipment/items for the oil industry
- controls on provision of certain related services
- prohibition of procurement from Russia of arms and related materiel
- restrictions on issuance of and trade in certain 'bonds, equity or similar financial instruments' (i.e. securities and money-markets instruments)
- prohibition to satisfy certain claims made by certain persons, entities and bodies
- valid until 31.7.2023
- ban on the supply of dual-use goods and technology to certain persons, entities and bodies

as of 23-February-2022 due to the invasion of Russia into Donetsk and Luhansk:
- restrictions on access to the capital market, in particular by prohibiting the financing of Russia, its Government and its Central Bank.

as of 25-February-2022 due to the invasion of Russia into Ukraine:
- Introducing further restrictive measures related to the finance, defence, energy, aviation, and space sectors.
- Expanding existing financial restrictions, in particular those on access by certain Russian entities to capital markets.
- Prohibiting the listing and provision of services in relation to shares of Russian state-owned entities on Union trading venues.
- Introducing new measures which significantly limit the financial inflows from Russia to the Union by prohibiting the acceptance of deposits exceeding certain values from Russian nationals or residents, the holding of accounts of Russian clients by Union central securities depositories, as well as the selling of euro-denominated securities to Russian clients.
- Imposing further restrictions on exports of dual-use goods and technology and on the provision of related services.
- Restrictions on exports of certain goods and technology which might contribute to Russia’s technological enhancement of its defence and security sector, together with restrictions on the provision of related services.
- Limited exemptions to such restrictions are envisioned for legitimate and pre-determined purposes only.
- Imposing restrictions on the sale, supply, transfer or export to Russia of specific goods and technologies for use in oil refining, together with restrictions on the provision of related services.
- Introducing an export ban covering goods and technology suited for use in aviation and the space industry.
- Prohibiting the provision of insurance and reinsurance and maintenance services in relation to those goods and technology.
- Prohibiting to provide technical assistance and other related services as well as financing and financial assistance in relation to the goods and technology subject to this prohibition.

as of 28-February-2022 due to the invasion of Russia into Ukraine:
- Prohibiting any transactions with the Central Bank of Russia.
- Member States should be required to deny permission to land in, take off from, or overfly, their territories to any aircraft operated by Russian air carriers, including as a marketing carrier, to any Russian-registered aircraft, and to non-Russian-registered aircraft which are owned or chartered, or otherwise controlled by a Russian legal or natural person.

as of 1-March-2022 due to the invasion of Russia into Ukraine:
- Introducing further restrictive measures with regard to the provision of specialised financial messaging services to certain Russian credit institutions and their Russian subsidiaries, which are relevant for the Russian financial system and which are already the subject of restrictive measures imposed by the Union or by partner countries and, subject to certain exceptions, with regard to engagement with the Russian Direct Investment Fund.
- Prohibiting, subject to certain exceptions, the supply of euro denominated banknotes to Russia.
- Introducing further restrictive measures to urgently suspend the broadcasting activities of media outlets in the Union, or directed at the Union which the Russian Federation has engaged in continuous and concerted propaganda actions, gravely distorting and manipulating facts.

as of 9-March-2022 due to the invasion of Russia into Ukraine:
- Introducing further restrictive measures with regard to the export of maritime navigation goods and technology.

as of 15-March-2022 due to the invasion of Russia into Ukraine:
- prohibiting all transactions with certain state-owned companies.
- prohibiting the provision of any credit rating services, as well as access to any subscription services in relation to credit rating activities, to any Russian person or entity.
- tightening the export restrictions regarding dual-use goods and technology as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector and to expand the list of persons connected to Russia’s defence and industrial base, which are subject to those restrictions.
- prohibiting new investments in the Russian energy sector.
- introducing a comprehensive export restriction on equipment, technology and services for the energy industry in Russia, with the exception of nuclear industry and the downstream sector of energy transport.
- introducing further trade restrictions concerning iron and steel, as well as luxury goods.

as of 08-April-2022 due to the invasion of Russia into Ukraine:
- extending the prohibition on deposits to crypto-wallets.
- extending the prohibitions on the export of euro-denominated banknotes and on the sale of euro-denominated transferrable securities to all official currencies of the Member States.
- prohibiting the award and continued execution of public contracts and concessions with Russian nationals and entities or bodies established in Russia.
- prohibiting the provision of support, including financing and financial assistance or any other benefit from a Union, Euratom or Member State programme to Russian publicly owned or controlled entities.
- prohibiting on being a beneficiary, acting as trustee or in similar capacities for Russian persons and entities.
- prohibiting providing certain services to trusts.
- prohibiting access to ports in the territory of the Union to vessels registered under the flag of Russia.
- restricting exports of jet fuel and other goods to Russia.
- additional import restrictions on certain goods exported by or originating from Russia, including coal and other solid fossil fuels.
- prohibiting any road transport undertaking established in Russia to transport goods by road within the territory of the Union, including in transit.

as of 3 June 2022 due to the invasion of Russia in to Ukraine:
- prohibiting the import, purchase or transfer into Member States of crude oil and certain petroleum products from Russia.
- prohibiting the insurance and reinsurance of maritime transport of crude oil and certain petroleum products from Russia to third countries.
- prohibiting the onward transfer, transport or re-sale of crude oil from Russia delivered into a Member State by pipeline to other Member States or to third countries.
- prohibiting, following a transitional period of eight months, the onward transfer, transport or re-sale to other Member States of petroleum products obtained from such crude oil.
- prohibiting the provision to Russia of accounting, auditing, including statutory audit, bookkeeping and tax consulting services, or business and management consulting and public relations services

as of 21 July 2022 due to the invasion of Russia in to Ukraine:
- prohibiting the direct or indirect import, purchase or transfer of gold, which constitutes Russia’s most significant export after energy. This prohibition applies to Russian-origin gold, exported from Russia after the entry into force of the Decision.
- extending the port access ban to locks in order to ensure full implementation of the measure and avoid circumvention.

as of 06 October 2022 due to the invasion of Russia in to Ukraine:
- extending the list of restricted items which might contribute to the Russian Federation’s military and technological enhancement or to the development of its defence and security sector, by including in that list certain chemical substances, nerve agents and goods which have no practical use other than for capital punishment, torture or other cruel, inhuman or degrading treatment or punishment, or which could be used for those purposes.
- prohibiting the sale, supply, transfer or export of firearms, their parts and essential components and ammunition.
- extending the import ban on steel products that either originate in the Russian Federation or have been exported from it.
- Imposing import restrictions on additional items that generate significant revenues for the Russian Federation. That prohibition applies to goods that originate in the Russian Federation or are exported from it and includes such items as wood pulp and paper, certain elements used in the jewellery industry such as stones and precious metals, certain machinery and chemical items, cigarettes, plastics and finished chemical products such as cosmetics.
- extending the export prohibition by adding new items to the list of goods which could contribute to the enhancement of Russian industrial capacities. It also imposes restrictions on the sale, supply, transfer or export of additional goods used in the aviation sector.
- in addition to the existing prohibitions related to the provision of services for the maritime transport of crude oil and certain petroleum products to third countries, further prohibiting the maritime transport of such goods to third countries.
- in the event that a vessel under the flag of a third country has transported Russian crude oil or petroleum products purchased at a price above the price cap, it should be prohibited to provide technical assistance, brokering services, financing or financial assistance, including insurance, related to any transport in the future by that vessel of crude oil or petroleum products.
- expanding the prohibition to engage in any transaction with certain Russian State-owned or controlled legal persons, entities or bodies by including a ban on Union nationals to hold any posts on the governing bodies of those legal persons, entities or bodies.
- requiring the withdrawal of authorisations granted by Member States to the Russian Maritime Register of Shipping.
- withdrawing the Union's recognition of the Russian Maritime Register of Shipping.
- extending the port access and lock ban in the territory of the Union to vessels certified by the Russian Maritime Register of Shipping.
- removing the threshold for the existing prohibition on the provision of crypto-asset wallet, account or custody services to Russian persons and residents, thereby banning the provision of such services regardless of the total value of such crypto-assets.
- extending the existing prohibition on the provision of certain services to the Russian Federation by banning the provision of architectural and engineering services as well as of IT consultancy services and legal advisory services.

as of 16 December 2022 due to the invasion of Russia in to Ukraine:
- Existing measures have been extended or amended.
- Implementation of the crude oil price cap.

as of 4 February 2023 due to the invasion of Russia in to Ukraine:
- Implementation of two additional Petroleum products price caps; one price cap for petroleum products traded at a discount to crude oil (‘discount to crude oil’) and another price cap for petroleum products traded at a premium to crude oil (‘premium to crude oil’).

as of 25 February 2023 due to the invasion of Russia in to Ukraine:
- Prohibiting the transit via the territory of Russia of dual-use goods and technology and of arms exported from the Union.
- Prohibiting on holding any posts in the governing bodies applies to European critical infrastructures and critical infrastructures identified or designated as such under national law.
- Prohibiting on providing gas storage capacity in the Union to Russian nationals, natural persons residing in Russia or legal persons or entities established in Russia.
- Introducing an obligation for aircraft operators to notify non-scheduled flights to their competent authorities.
- Requiring that natural and legal persons, entities and bodies supply to the competent authorities of the Member States and simultaneously to the Commission information on assets and reserves of the Central Bank of Russia which they hold or control or are a counterparty to.
- Providing for rules on the release by the customs authorities of the Member States of goods which are physically in the Union and which had already been presented to customs authorities when they became subject to such restrictions.

Yes, see Ukraine

Medium Risk

Saudi Arabia (SA)

No

No

Low Risk

Serbia and Montenegro (CS)

see Yugoslavia

see Balkans related

Low Risk

Sevastopol (--)

see Ukraine

see Crimea

Extreme Risk

Somalia (SO)

- confirmation of embargo on arms and related materiel
- ban on provision of certain services
- inspection of and prior information requirement on certain cargoes to and from Somalia
- embargo on supplying arms and related material
- ban on provision of certain services
- freezing of funds and economic resources
- restrictions on admission for certain persons
- import ban on charcoal
- ban on provision of certain related services (related to charcoal)
- ban on supplying arms and related material meant for the Security Forces of the Federal Government of Somalia to any person or entity not in the service of such forces
- vigilance requirement for EU Member States as regards certain goods related to military activities and the provision of certain services
- inspection of certain vessels in order to stop illegal trade in charcoal, arms and related materiel
- prior information requirement on cargoes to and from Somalia

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

South Sudan (SS)

- embargo on arms and related materiel
- ban on provision of certain services (related to arms and related materiel)
- restrictions on admission
- freezing of funds and economic resources
- prohibition to satisfy certain claims of certain persons, entities and bodies
- restrictions on admission for certain persons
- embargo on certain goods which might be used for the manufacture and maintenance of products which could be used for internal repression
- ban on provision of certain related services

Yes, the Executive Order does not target the country of South Sudan, but rather targets those responsible for the conflict there, which has been marked by widespread violence and atrocities, human rights abuses, recruitment and use of child soldiers, attacks on peacekeepers, and the obstruction of humanitarian operations (Sudan sanctions, exemption for South Sudan (31CFR212(g)(1)), for details what sanctions apply, see above mentioned links or contact us.

Medium Risk
South Sudan independent as of July 9th, 2011

Sudan (North) (SD)

- restrictions on admission
- freezing of funds and economic resources
- embargo on arms and related material
- ban on provision of certain services

Effective October 12, 2017, certain sanctions with respect to Sudan and the Government of Sudan – namely sections 1 and 2 of Executive Order (E.O.) 13067 of November 3, 1997 and all of E.O. 13412 of October 13, 2006 – will be revoked, pursuant to E.O. 13761 of January 13, 2017, as amended by E.O. 13804 of July 11, 2017. This revocation of certain sanctions:

- Does not affect OFAC sanctions related to the conflict in Darfur, which were imposed pursuant to E.O. 13400 of April 26, 2006 and pursuant to the national emergency declared in E.O. 13067, which will not be terminated; and
- Does not affect OFAC designations of any Sudanese persons pursuant to sanctions authorities other than E.O.s 13067 and 13412.

Medium Risk

Syria (SY)

- embargo on certain goods which might be used for the manufacture and maintenance of products which could be used for internal repression
- ban on provision of certain related services

- embargo on certain goods which might be used for the manufacture and maintenance of products which could be used for internal repression
- ban on provision of certain related services
- control of export of certain other goods which might be used for the manufacture and maintenance of equipment which might be used for internal repression
- control of provision of certain related services
- import ban on arms and related materiel
- ban on provision of certain related services
- embargo on telecommunications monitoring and interception equipment
- ban on provision of certain services (related to such equipment)
- import ban on crude oil and petroleum products
- ban on provision of certain services (related to crude oil and petroleum products)
- embargo on key equipment and technology for the oil and natural gas industries
- ban on provision of certain services (to the oil and natural gas industries)
- ban on provision of new Syrian banknotes and coins
- ban on trade in gold, precious metals and diamonds with the Government of Syria
- embargo on luxury goods
- ban on certain investment (in the oil and natural gas industries, in construction of power plants for electricity production)
- prohibition to participate in the construction of new power plants for electricity production
- restraint on commitments for public and private financial support for trade with Syria and ban on new long term commitments of Member States
- ban on new commitments for grants, financial assistance and concessional loans to the Government of Syria
- prohibition for the European Investment Bank to make certain payments
- restrictions on issuance of and trade in certain bonds
- restrictions on establishment of branches and subsidiaries of and cooperation with Syrian banks
- restrictions on provision of insurance and re-insurance
- restrictions on access to airports in the EU for certain flights
- inspection of certain cargoes to Syria and prior information requirement on cargoes to Syria
- restrictions on admission of certain persons
- freezing of funds and economic resources of certain persons, entities and bodies
- prohibition to satisfy claims made by certain persons, entities or bodies
- valid until 1.6.2023
- restrictions on trade in cultural goods (with list)
- embargo on jet fuel and certain additives
- ban on provision of certain services (related to jet fuel and certain additives)
- embargo on equipment used in the construction of new power plants for electricity production
- ban on provision of certain services (related to the construction of such power plants)
- specific exception for Central Bank of Syria (freezing of funds and economic resources)
- ban on exports of certain goods which might be used for the manufacture and maintenance of equipment which might be used for internal repression
- ban on provision of certain services
- ban on exports of luxury goods
- prior information requirement on cargoes to Syria
- information on competent authorities
- authorisation to apply an embargo on equipment which might be used for internal repression
- authorisation to ban the provision of certain services
- amendment of the exception to the ban on exports of certain goods which might be used for the manufacture and maintenance of equipment which might be used for internal repression
- amendment of the prohibition to satisfy claims made by certain persons, entities or bodies
- prohibition of circumvention of the restrictive measures
- restrictions on admission of persons suspected of involvement in the planning, sponsoring, organising or perpetrating of the murder of former Prime Minister of the Lebanon, Rafiq Hariri on 14 February 2005
- commitment to cooperate with international investigation into that murder

Yes, for details what sanctions apply, see above mentioned links or contact us.

High Risk

Tunisia (TN)

- freezing of funds and economic resources
- valid until 31.1.2024

No

Low Risk

Turkey (TR)

- freezing of funds and economic resources of certain persons, entities or bodies responsible for or involved in drilling activities infringing the sovereignty or sovereign rights and jurisdiction of the Republic of Cyprus in its territorial sea, exclusive economic zone and continental shelf.
- valid until 12.11.2023

No

EU added 11-11-2019

Ukraine (regarding US, see also Crimea) (UA)

as of 23-February-2022 Donetsk and Luhansk were added to these sanctions:
- ban on imports of goods from Crimea/Sevastopol, Donetsk, Luhansk
- ban on provision of certain services
- prohibition to satisfy certain claims made by certain persons, entities or bodies
- valid until 23.6.2023
- ban on investment in real estate in Crimea/Sevastopol, Donetsk, Luhansk
- ban on investment in entities in Crimea/Sevastopol, Donetsk, Luhansk
- embargo on certain goods and technology for use in certain sectors (transport, telecommunications, energy, oil, gas and mineral resources)
- ban on provision of certain services (related to such goods and technology)
- ban on provision of certain services related to infrastructure in certain sectors (transport, telecommunications, energy, oil, gas and mineral resources)
- ban on provision of certain services related to tourism
- prohibition for certain ships to enter ports in Crimea/Sevastopol
- restrictions on admission of (a) certain natural persons responsible for, actively supporting or implementing, actions or policies which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine, or stability or security in Ukraine, or which obstruct the work of international organisations in Ukraine, and certain natural persons associated with them; (b) certain natural persons actively supporting, materially or financially, or benefitting from, Russian decision-makers responsible for the annexation of Crimea or the destabilisation of Eastern Ukraine; (c) certain natural persons conducting transactions with the separatist groups in the Donbass region of Ukraine
- freezing of funds and economic resources of (a) certain natural persons responsible for, actively supporting or implementing, actions or policies which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine, or stability or security in Ukraine, or which obstruct the work of international organisations in Ukraine, and certain natural or legal persons, entities or bodies associated with them; (b) certain legal persons, entities or bodies supporting, materially or financially, actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine; (c) certain legal persons, entities or bodies in Crimea or Sevastopol whose ownership has been transferred contrary to Ukrainian law, or certain legal persons, entities or bodies which have benefitted from such a transfer; (d) certain natural or legal persons, entities or bodies actively supporting, materially or financially, or benefitting from, Russian decision-makers responsible for the annexation of Crimea or the destabilisation of Eastern Ukraine; (e) certain natural or legal persons, entities or bodies conducting transactions with the separatist groups in the Donbass region of Ukraine
- valid until 15.9.2023
- freezing of funds and economic resources of certain persons responsible for the misappropriation of Ukrainian State funds, of certain persons responsible for human rights violations in Ukraine and of natural or legal persons, entities or bodies associated with such persons
- valid until 6.3.2024 (with regard to entry 17 in the Annex, the measures in Article 1 shall apply until 6 September 2021, in respect of 4 persons valid until 6-9-2022).
- prohibition to satisfy certain claims made by certain persons, entities or bodies

as of 23-February-2022 due to the invasion of Russia into Donetsk and Luhansk:
- prohibiting the import into the European Union of goods originating in the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine, with the exception of goods having been granted a certificate of origin by the Government of Ukraine.
-Probibiting the trade in goods and technology for use in certain sectors in the non-government controlled areas of the Donetsk and Luhansk Oblasts of Ukraine.
- Prohibiting services in the sectors of transport, telecommunications, energy or the prospecting, exploration and production of oil, gas and mineral resources, as well as services related to tourism activities in the non-government controlled areas of the Donetsk and Luhansk oblasts of Ukraine

as of 25-February-2022 due to the invasion of Russia into Ukraine:
- Amending the criteria of designation including persons and entities supporting and benefitting from the Government of the Russian Federation as well as persons and entities providing a substantial source of revenue to it, and natural or legal persons associated with listed persons or entities.

as of 08-April-2022 due to the invasion of Russia into the Ukraine:
- Imposing restrictive measures on leading businesspersons involved in economic sectors providing a substantial source of revenue to, and on persons supporting or benefitting from, the Government of the Russian Federation and on natural persons associated with those persons, including family members unduly benefitting from them.
- Subjecting the Ministers and members of the ‘People’s Council’ of the so-called ‘Donetsk People’s Republic’ and ‘Luhansk People’s Republic’ to restrictive measures.
- Subjecting companies supporting, materially or financially, or benefitting from the Government of the Russian Federation and materially or financially supporting actions which undermine or threaten the territorial integrity, sovereignty and independence of Ukraine to restrictive measures.

Yes, sanctioned is the Crimea (incl. Sevastopol), Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine and individuals of the Russian Federation and Smart sanctions regarding the Russian Federation, for details what sanctions apply, see above mentioned links or contact us.
19-Dec-2018 OFAC submitted a notification to Congress of its intention to terminate the sanctions imposed on En+ Group plc ("En+"), UC Rusal plc ("Rusal"), and JSC EuroSibEnergo ("ESE") in 30 days.
21-Feb-2022 Added sanctions on the Donetsk People’s Republic (DNR) and Luhansk People’s Republic (LNR) regions of Ukraine

High Risk

United States of America (US)

- protection against certain effects of sanctions applied by the USA

No

Low Risk

Venezuela (VE)

- freezing of funds and economic resources
- embargo on arms and related materiel.
- (arms embargo related) ban on provision of certain services
- valid until 14.11.2023

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

Yemen (YE)

- restrictions on admission of certain persons
- freezing of funds and economic resources
- embargo on supplying arms and related matériel to certain persons, entities and bodies
- ban on provision of certain services to these persons, entities and bodies
- commitment to inspect vessels and aircraft bound to or from Yemen, if certain conditions are met
- prohibition to satisfy certain claims

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk

Yugoslavia (YU)

- withdrawn 29.10.2014
- prohibition to satisfy certain claims in accordance with UN Security Council Resolution No 757 (1992)
- prohibition to satisfy claims with regard to contracts and transactions the performance of which was affected by UN Security Council Resolution No 757 (1992) and related resolutions

see Balkans related

Low Risk

Zimbabwe (ZW)

- embargo on arms and related materiel
- ban on exports of equipment for internal repression
- ban on provision of certain services
- restrictions on admission (suspended for specific parties)
- freezing of funds and economic resources (suspended for specific parties)
- valid until 20.2.2024

Yes, for details what sanctions apply, see above mentioned links or contact us.

Medium Risk