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Introduction

Export controls can be described as restrictions on international trade in certain sensitive goods, software and technology (hereinafter, Items). Generally, this involves licensing requirements or prohibitions on the cross-border movement of Items identified on specified control lists established at national or international level, or when sensitive end uses are involved, with potentially severe consequences for non-compliance.

In the European Union, export controls include both EU-wide restrictions provided for through EU legislation, as well as EU Member State-specific export controls set out at a national level. In each case, these controls are administered and enforced at national Member State level, resulting in certain variations in how export controls are applied across the EU.

This chapter gives an overview of export control rules under EU law, covering the key types of controls on Items subject to EU export controls; the circumstances in which export controls apply; export licensing requirements and practicalities; and the potential consequences of non-compliance.

EU export controls consist of a patchwork of EU-wide rules set out pursuant to EU legislation and local rules applied by individual Member States. These rules predominantly implement export controls on Items agreed pursuant to international frameworks to which the EU or its Member States are party (i.e., the Wassenaar Arrangement, the Australia Group (chemical weapons), the Nuclear Suppliers Group and the Missile Technology Control Regime).

In line with these international frameworks, EU export controls apply to both tangible and intangible exports of controlled Items (i.e., types of goods, software or technology specifically identified on relevant export control lists, such as the EU list of dual-use controlled Items as described below). Each of these controlled Items will be classified under a relevant export control regime, with a specific control entry (the EU equivalent of a US Export Control Classification Number); otherwise, the Item will be classified as NLR (no licence required). EU export control rules can also apply to exports of non-listed Items (i.e., those that do not specifically appear on export control lists) if there is knowledge, awareness or (in some cases) suspicion of a sensitive end use (known as catch all end-use controls). This includes certain end uses relating to the military sector or weapons of mass destruction.

The two main export control regimes in the EU are those concerning: (1) dual-use export controls (i.e., Items that can be used for commercial or civilian purposes but also for military purposes); and (2) military export controls, generally in relation to listed Items that are specially designed or modified for military use. As noted below, certain other regimes apply in the EU, including in relation to torture equipment.

When considering any transaction under EU export control rules, key questions to consider include the following.

In the EU, the key dual-use export control legislation is currently the EU Dual-Use Regulation. This sets out EU-wide controls that are directly applicable in all EU Member States, including controls on specifically listed dual-use Items and in respect of exports relating to controlled end uses.

Under the EU Dual-Use Regulation, dual-use Items are defined as items, including software and technology, which can be used for both civil and military purposes, and includes items that can be used for the design, development, production or use of nuclear, chemical or biological weapons or their means of delivery, including all items that can be used for both non-explosive uses and assisting in any way in the manufacture of nuclear weapons or other nuclear explosive devices.

The EU Dual-Use Regulation sets out lists of specific types of dual-use Items for which a licence (referred to within the Regulation as an authorisation) must be obtained in advance of export. Items covered by the EU Dual-Use Regulation include:

The main list of controlled Items can be found in Annex I, which, in summary, specifies Items for which a licence must be obtained before they are exported from within to outside the EU territory. Certain record-keeping and paperwork requirements also apply in respect of intra-EU transfers of Items listed in Annex I.

Annex I currently consists of 10 categories of controlled Items on more than 300 pages of the Regulation, with control entries including specific technical parameters (such as detailed definitions, exemptions and exceptions). The Items controlled in Annex I include various goods, software and technology used in a range of sectors, including marine, aerospace, chemicals, oil and gas, mining, pharmaceutical and nuclear. Statistical estimates published by the European Commission indicate that, in 2019, authorised dual-use trade amounted to 31.5 billion, representing 1.7 per cent of total extra-EU exports.

In line with international export control frameworks as noted above, the 10 categories in Annex I to the EU Dual-Use Regulation are as follows:

Each of these categories is further subdivided into sections, covering:

Each of these sections is then further subdivided into individual control entries for particular Items, often very technical and detailed in nature, with certain exceptions and exemptions. There are also a number of general exceptions from export control. These cover, for example, software and technology that is in the public domain.

By way of example of an Annex I dual-use Item, a server with controlled encryption functionality may be caught within Annex I control list entry 5A002a1, denoting that:

A much shorter list of more sensitive Items is set out at Annex IV to the EU Dual-Use Regulation. Annex IV is divided into two Parts. Items listed in Part I can be transferred within the EU on the basis of a National General Authorisation. In contrast, Part II contains Items for which a licence is also required for intra-EU transfers. These Items include highly sensitive Items, such as cryptanalytic Items, most nuclear-related Items, stealth-related technology, and Items relating to missiles and chemical warfare.

In addition to control lists set out under the EU Dual-Use Regulation, EU Member States may also set out their own lists of controlled dual-use Items. Germany, for instance, has done so by including some dual-use Items on the national export list that are not already covered by the EU Dual-Use Regulation, if they are to be exported to certain countries. One example is entry 6A908, which refers to radar-based navigation or surveillance systems for shipping or air traffic or components thereof that are not already covered under Annex I to the EU Dual-Use Regulation, if the destination of the Items is Iran.

As noted above, a licence may be required in respect of Items that are not controlled under a relevant list, when the transaction may involve a controlled end use. These are the catch all controls, as any Item could in theory be subject to a licensing requirement depending on the end use.

Key end-use controls under the EU Dual-Use Regulation include the following:

In addition, under Article 9 of the EU Dual-Use Regulation, EU Member States may decide to prohibit or impose an authorisation requirement on the export of non-listed Items for reasons of public security, including the prevention of acts of terrorism, or human rights considerations.

A licence will be required for any export of Annex I-listed Items or of any non-listed Items in respect of a controlled end use. The concept of an export captures both (1) shipments of tangible (physical) goods from within to outside the territory of the EU (including hand carries of Items), and (2) intangible transfers of controlled software or technology from within the EU to legal and natural persons and partnerships outside the EU. These exports can occur intra-group and need not involve any sale, consideration or transfer of ownership.

The concept of an intangible transfer under EU export controls is particularly broad and is a common area in which companies can fall foul of the rules. Examples include:

Licences are also required in certain circumstances when a person or entity in the EU is involved in brokering (e.g., negotiating or arranging) the sale or supply of Items between two third (i.e., non-EU) countries. Provided they carry out brokering services from the EU into the territory of a non-EU country, this also applies to non-EU persons or entities. These controls typically apply when the relevant EU broker has been informed or is aware of a controlled WMD or military end use in respect of a listed Annex I Item. However, Member States are also permitted to extend brokering controls to capture:

Likewise, while Items in transit through the EU (i.e., passing through the EU from and to a non-EU destination) are not subject to EU dual-use export controls, Member States may prohibit Items in transit if they are or may be intended for a controlled WMD or military end use.

As the EU is a single customs territory allowing for free movement of goods, export controls principally apply to exports of dual-use goods from the EU to a destination outside the EU. Intra-EU movements of most dual-use Items do not normally require a licence. However, there are a few important points to note:

As noted below, military controlled Items generally require a licence for transfers between EU Member States, as these controls are set at national level.

As noted above, certain sensitive dual-use Items as listed under Annex IV to the EU Dual-Use Regulation require an authorisation to be transferred between EU Member States. Those Items listed in Part 1 of Annex IV can be transferred on the basis of a National General Authorisation while Items listed in Part 2 of Annex IV cannot.

Licences may be required for intra-EU movements of dual-use Items when the Items will be re-exported from the EU without being further processed, and a licence would be required to export them from the EU. This is an optional control that only certain EU Member States have implemented.

All intra-EU transfers of Items listed in Annex I to the EU Dual-Use Regulation must be accompanied by a statement that the Items are subject to control if exported from the EU. The statement should appear in the relevant commercial documents (e.g., contracts, order confirmations, invoices and dispatch notes). Additionally, records of intra-EU transfers must be kept for at least three years from the end of the calendar year in which the transfer took place and shall be produced, on request, to the competent authority.

Licences are also required in certain instances where an entity provides technical assistance related to Items listed in Annex I from the territory of the EU into the territory of a third country; or an EU entity provides technical assistance within the territory of a third country or to a resident of a third country temporarily present in the EU. These controls typically apply when the relevant supplier has been informed or is aware of a controlled WMD or military end use in respect of the Items in question.

Technical assistance is any technical support related to repairs, development, manufacture, assembly, testing, maintenance or any other technical service, and may take forms such as instruction, advice, training, transmission of working knowledge or skills or consulting services, including by electronic means as well as by telephone or any other verbal forms of assistance.

Export controls in relation to military Items are controlled by each EU Member State. The EU does maintain a common military list, setting out a list of military Items subject to export controls. This list is adopted annually by the Council, pursuant to Council Common Position 2008/944/CFSP defining common rules governing control of exports of military technology and equipment. However, this list is non-binding, and it is up to each Member State to legislate for and implement its own, national military export controls.

Generally, controls on military Items as adopted by individual Member States and pursuant to the EU common military list capture Items that are either specially designed or modified for military use. These terms are not currently defined on a pan-EU basis but are generally very broadly interpreted. This can apply (for example) to Items that are simply developed or customised for a military customer even if they have civilian applications.

The EU common military list currently captures 22 categories of military-controlled Items, again capturing goods, software and technology. Items caught by this list are set out in entries ML1 to ML22, inclusive, covering a range of Items, such as:

Germany, for example, distinguishes between military Items and war weapons. All military Items are subject to a licence requirement for exports. However, some of these Items are also war weapons, which are subject to further restrictions under the German War Weapons Control Act.

In addition to dual-use and military Items, a number of other Items may be controlled under separate export control lists either at EU or Member State level.

By way of example, the EUs Anti-torture Regulation is a reflection of the EUs commitment to eradicate torture and the death penalty. The measures seek to prevent the trade in certain goods that could be used for capital punishment, torture or other cruel, inhuman or degrading treatment. The Regulation:

As a specific example of the dynamic nature of export controls, during 2020 we also saw the introduction and subsequent removal of controls in relation to personal protective equipment, in response to the covid-19 pandemic. In 2021, export control restrictions in relation to the covid-19 vaccine were implemented and were in force until the end of 2021.

Within the EU, individual Member States are each responsible for licensing in respect of exports (whether in respect of EU-wide controls on dual-use Items, or national controls). There is no EU-wide export licensing body.

For example, in Germany, the central authority responsible for issuing licences is the Federal Office for Economic Affairs and Export Controls (BAFA). BAFA offers an online tool through which licences can be obtained and can assist in classifying goods. There are a number of very useful general export authorisations available in Germany, in addition to the EU-wide general export authorisations explained below.

Different types of licences may be available depending on the Item and transaction in question (including, in particular, the relevant destination). The EU Dual-Use Regulation sets out certain common forms for licences as follows:

Each licence covers exports of certain Items, to certain destinations, in some cases only to certain end users or consignees. In addition, each licence will have specific conditions, exclusions and requirements. These include obligations to obtain written undertakings from consignees or end users prior to export. For example, these undertakings can include certifications from the end user that they are the intended end user of the goods to be supplied by the licensee, and that the goods will not be used for any purpose connected with chemical, biological or nuclear weapons, or missiles capable of delivering those types of weapons. It is critical for exporters to ensure full compliance with the terms of any export licence. This is a typical area of non-compliance, with authorities in the EU commonly conducting audits in which they scrutinise exports for compliance with all licence conditions.

Certain licences may only be granted when the EU exporter can demonstrate that it has implemented an internal compliance programme (i.e., sufficient export compliance policies and procedures). Again, export authorities may audit exporters to determine whether appropriate policies and procedures are in place. In 2019, the European Commission made specific recommendations in respect of the key elements it would expect to see in an internal compliance programme, which include the following:

Under the EU Dual-Use Regulation, the relevant export licence must be obtained by the exporter from the Member State authority in which it is established (e.g., where it is incorporated) or, if the exporter is established outside the EU, by the competent authority of the Member State where the Items are located. A licence granted in one EU Member State should be valid for exports from any other Member State (although certain local restrictions can apply in practice). The exporter is currently defined to include (in summary):

Determining which entity is the exporter, and in which EU Member State it is established (and thus from which Member States competent authority the relevant export licence must be obtained), is a key matter that is not always straightforward in more complex supply chains. Different Member States can also take different approaches to the concept of establishment.

The EU has in place an enforcement coordination mechanism with a view to establish direct cooperation and exchange of information between competent authorities and enforcement agencies. However, the implementation and enforcement of export controls in the EU is also the responsibility of individual EU Member States. The EU Dual-Use Regulation states that each Member State shall take appropriate measures to ensure proper enforcement, including penalties that are effective, proportionate and dissuasive.

Penalties for breaches of export controls can include civil or criminal penalties, or broader legal and practical consequences, varying by jurisdiction. Typical penalties may involve:

More broadly, export violations may damage an exporters relationships with relevant licensing authorities, potentially hampering the ability to obtain export licences in the future (which can significantly affect business activities). Export violations may also damage relationships with banks and other counterparties and key stakeholders, as well as a companys reputation.

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The Guide to Sanctions - Third Edition - Global Investigations Review

UNHCR, the UN Refugee Agency, is issuing the following recommendations ahead of the 1 July meeting hosted by the European Commission. The meeting brings together Member States and key actors to discuss and launch the 2023-2025 pledging exercise for resettlement and humanitarian admission. The recommendations set out UNHCRs key asks to EU Members States and relevant European Union (EU) institutions as they consider their commitments to resettling and admitting refugees through complementary pathways in 2023.

UNHCRs recommendations are in line with the Three-Year Strategy (2019-2021) on Resettlement and Complementary Pathways(the Strategy), the Third Country Solutions for Refugees: Roadmap 2030 (Roadmap 2030),1 and the objective set out in the Global Compact on Refugees (GCR) to increase the number of resettlement and complementary pathways admissions globally. The Strategy foresees the resettlement of one million refugees and admission of two million refugees through complementary pathways by 2028.

In the last two years, EU Member States have shown their capacity to respond to a series of challenges by working together and demonstrating solidarity. Despite the important impact of the COVID-19 pandemic on resettlement and complementary pathway admissions of refugees, EU Member States have remained engaged with UNHCR and other partners to find ways to ensure admissions. The EU stepped up following the events in Afghanistan in August 2021 and received tens of thousands of Afghan nationals evacuated from their country in addition to commitments for resettlement and other admission programmes to receive Afghan refugees from neighbouring countries.Since February 2022, the war in Ukraine has forced millions of people to flee, becoming the largest refugee emergency since the end of World War II. From the onset of the emergency, EU Member States demonstrated remarkable solidarity with an unanimous decision to activate the Temporary Protection Directive providing protection, access to rights and assistance to millions of people. The EU has demonstrated its capacity to work together, providing emergency assistance in a very short period of time, and with an unprecedented mobilization of receiving authorities and host communities.The Projected Global Resettlement Needs increased from 1,47 million in 2022 to more than 2 million for 2023. In this context, UNHCR urges Member States to maintain their commitments to refugees and provide solutions to those most at risk, and calls on the EU to:

MAINTAIN AMBITIOUS TARGETS FOR SUFFICIENT RESETTLEMENT ADMISSIONS OF REFUGEES IN NEED

Maintain ambitious targets: while UNHCR acknowledges the great pressure in the past few months with the Ukraine emergency, it is essential to pursue the solidarity efforts and commitments to refugees worldwide. UNHCR recommends that the 27 EU Member States maintain ambitious resettlement targets, and resettle at least 40,000 refugees in 2023, in addition to a minimum of 8,500 places for Afghan refugees to keep pace with a five-year target of 42,500 resettlement departures.

Ensure the incremental growth of resettlement as envisaged in the Strategy with EU targets increasing to a minimum of 44,000 in 2024 and 48,000 in 2025, in addition to an average of 8,500 places per year over the next five years in order to respond to the needs of Afghan refugees.

Adopt flexible case processing modalities to increase the agility and resilience of resettlement and admissions under other legal pathways.

Increase the number of EU Member States participating in resettlement: UNHCR is ready to support capacity building initiatives and work together with partners such as the EU Agency for Asylum (EUAA), the International Organization for Migration (IOM) and NGOs to meet this objective.

Increase EU funding for capacity building initiatives, including through the CRISP2 initiative to build solid and quality resettlement programmes and to advance complementary pathways.

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Summary of UNHCR Recommendations to the European Union: UNHCR resettlement needs, complementary pathways, and key priorities for 2023 (June 2022) -...

Delivery Hero and Glovo have been targeted for antitrust inspections in the European Union.

The European Commission announced today that it has carried out unannounced inspections of a number of online food, grocery and consumer goods delivery businesses in two Member States citing concerns over potential breaches of EU competition laws against forming cartels and other restrictive business practices.

The Commission has concerns that the companies concerned may have violatedArticle 101 of the Treaty on the Functioning of the European Union, which prohibits cartels and restrictive business practices, it writes in a press release.

The investigation concerns an alleged agreement or concerted practice to share national markets for the online ordering and delivery of food, groceries and other consumer goods in the European Union, it added.

The Commission did not name any of the companies that have been inspected and declined to provide more details when asked but Reuters reported that Berlin-based Delivery Hero was one of the inspected companies.

Delivery Hero confirmed this to us when reached for comment, sending this statement:

Delivery Hero confirms that the European Commission conducted an inspection at its offices in Berlin. The fact that the Commission carries out such an inspection does not mean that the Commission has concluded that there has been an actual infringement of competition law nor does it prejudge the outcome of the investigation itself. Delivery Hero is committed to cooperating fully with the Commission.

We have also confirmed that Barcelona-based Glovo, which since the end of 2021 has been majority owned by Delivery Hero was also approached by the Commission.

As part of its investigation, we can confirm that the European Commission has approached Glovo, a Glovo spokewoman told us. We are confident that Glovo meets all antitrust and compliance requirements, as defined by the law and the initial investigation does not prejudge the outcome of the investigation itself. We are always collaborating with authorities and are actively cooperating with the European Commission authorities to aid their investigation.

The Commission PR about the raids specifies that companies in two Member States were inspected presumably a reference to Germany and Spain, given those are the home markets of Delivery Hero and Glovo respectively.

Wereached out to a number of other delivery players in those markets to ask if they were also paid a visit.

At the time of writing, Berlin-based Gorillas had confirmed it was not targeted. Regarding this issue, we can confirm that Gorillas has not been targeted by the raids organized by the European Commission, a spokesperson told us.

We also understand that UberEats was not involved in the Commission action.

Berlin-based Flink also told us it was not raided nor sent any requests related to the investigation.

The timing of the inspection is interesting given that the on-demand delivery space is facing particularly challenging operational conditions.

The global economic downturn has made it harder for startups to raise, generally, but the high losses/burn rates of some of these delivery/q-commerce platforms which tend to prioritize growth over profitability in a bid to dominate markets and squeeze out competition over the longer run make them look particularly vulnerable to the end of fundraising good times.

So while quick commerce exploded rapidly in the wake of a pandemic-triggered surge in demand for app-based shopping and delivery, theres likely been a similarly rapid cooling from investors on the sector in recent months as rising interest rates and soaring inflation cause funds to reconsider pouring yet more capital into a scramble for convenience that may turn out to be more flash in the pan than paradigm shopping shift.

Delivery Hero and Glovo are particularly interesting cases here, too given that Glovo had already abandoned its solo run and thrown its lot in with the German rival. (The acquisition was announced on December 31 after 11 p.m. CET which doesnt exactly suggest they were keen to trumpet the news.)

Delivery Heros shares, meanwhile, have taken a battering in recent months plunging almost 60% in Q1, per Bloomberg, whose April news report quoted HSBC analyst, Andrew Porteous, writing: The Glovo deal continues to baffle us and pointing out that Delivery Hero expected Glovo to post a loss of 330 million in 2022, which suggests the acquisition has beefed up its operational challenges, raising questions about wheres the upside?

As well as lots of consolidation, the on-demand delivery space has been characterized by rapid revisions to operational footprints with players typically firing up ops across multiple markets as they scramble for scale, before often, equally quickly pulling out again if they judge the level of expenditure has got too high vs. potential gain.

Startups in the space often talk about wanting to be either the number one or two player in a given market which has led to a patchwork of brands operating piecemeal across Europe, rather than uniform competition between all operators. But in such a high-cash-burn environment dominating the market is not really a nice to have rather its a necessity. And the relative footprints of on-demand delivery players can, at times, appear like coordinated agreements to carve up different markets even if its the burn rate ultimately dictating where they each operate.

Given all these pressures and the wider downturn turning the screw on the sector, the Commission sniffing around Delivery Hero and Glovo now looks interesting.

Although the EU is emphasizing that the inspections it has carried out so far are a preliminary step into suspected anticompetitive practices and the two companies are not facing any formal objections at this stage.

The fact that the Commission carries out such inspections does not mean that the companies are guilty of anti-competitive behaviour nor does it prejudge the outcome of the investigation itself, the Commission adds.

There is no deadline for the EU to complete the inquiries. And it remains to be seen whether any formal charges get delivered.

Its PR points out that the Commission offers a leniency program under which it may offer companies that have been involved in a secret cartel immunity from fines or significant reductions in fines in return for reporting the conduct and cooperating with an investigation. While individuals are also encouraged to report cartel or other anti-competitive behaviour on an anonymous basis via its whistleblower tool.

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Delivery Hero and Glovo targeted for EU antitrust inspection - TechCrunch

As part of the regular political dialogue between the Kingdom of Morocco and the EU, the Commissioner with responsibility for Home Affairs, YlvaJohansson, and the Spanish Home Affairs Minister, Fernando Grande-Marlaska, met with the Moroccan Minister of the Interior, Abdelouafi Laftit, in Rabat on 8 July 2022.

They highlighted the solid results of their cooperation based on shared responsibility in matters of migration, and agreed to renew their partnership in order to work together to tackle human smuggling networks, in particular following the emergence of new, extremely violent, methods adopted by such criminal networks.

The Commissioner and the two Ministers regretted every death of people attempting unlawful entry, including those that occurred during the recent distressing events on 24 June 2022. They also regretted the injuries, including to members of the Moroccan and Spanish border forces. These events put traditional methods of combatting human smuggling under strain.

Besides the human tragedy, they showed how very dangerous and violent human smuggling networks were, and the extent to which they were prepared to take any risk.

Investigations were under way to clarify the circumstances surrounding these events. At the same time, the Commissioner and the two Ministers welcomed the fact-finding commission set up by the Moroccan National Human Rights Council. The protection of fundamental rights is a value shared by Morocco and the European Union.

The new operational anti-smuggling partnership between the Commission and Morocco to tackle human trafficking will cover, in particular, support for border management, enhanced police cooperation (including joint investigations), awareness-raising on the dangers of unlawful migration and enhanced cooperation with EU agencies responsible for home affairs.

Morocco is a strategic and committed partner of the European Union, with which the EU has been cooperating on migration issues for a number of years. Its National Immigration and Asylum Strategy (SNIA) is one of the most well-developed migration management systems today, in both legislative and institutional terms, and has enabled the legalisation of the administrative status of thousands of migrants, and their integration into Moroccan society. Morocco was also one of the founding States of the Rabat process and his Majesty King Mohammed VI was appointed leader for Africa on the issue of migration by African Heads of State.

Morocco's practical efforts have resulted, in the first half of this year, in preventing more than 26,000 irregular departures one tenth of them saved at sea. In the same period, Morocco has dismantled around a hundred criminal trafficking networks.

In connection with the New Pact on Migration and Asylum, the Commission is establishing migration partnerships with the countries of origin, transit and destination, to combat human smuggling networks, but also to address the root causes of migration and improve legal migration routes so that people do not feel the need to risk their lives on dangerous journeys.

See the article here:
European Commission and Morocco launch renewed partnership on migration and tackling human smuggling networks - European Commission

By Sophia WangJul. 7, 2022

President Joe Biden was pressed about his administrations plans to temper rapidly rising oil prices during the U.S. NATO press conference at the Madrid NATO Summit June 30.

Oil prices have risen due to the war in Ukraine, with some analysts believing that prices may reach $200 a barrel.

When asked how long drivers in the U.S. could expect to face the rising prices, Biden answered As long as it takes so Russia cannot, in fact, defeat Ukraine and move beyond Ukraine. This is a critical, critical position for the world.

The European Union (EU) and the U.S. have already taken decisive steps to weaken Russias financial institutions, foremost among them sanctions against the country: for example, the U.S. and United Kingdom have announced total bans on Russian fossil fuels.

More conservative in its measures, the EU plans to cut oil imports from Russia by two-thirds, planning to ban all Russian oil imports arriving by sea by the end of the year. The EU also announced plans to halt Russian coal imports by August.

Russia is a critical supplier to European nations, supplying over 40% of the EUs natural gas. EU negotiations for appropriate sanctions came to a compromise after significant deliberation. The EU continues to import over 800,000 barrels per day of Russian oil imports through pipeline, a temporary measure since countries like Hungary and Slovakia depend heavily on this resource.

Notably, Germany and Poland voluntarily halted pipeline imports, despite significant reliance on Russian gas. According to International Energy Agency Reports, in 2020, Germany made up 42.6% of Russias gas exports; in 2021, 58% of Polands total oil imports came from Russia.

Shipping insurance is critical to the sanctions the EU plans to implement. Following a phase in six month period, EU companies cannot provide technical assistance, brokering services or financing or financial assistance, related to the transport, including through ship-to-ship transfers, to third countries of crude oil or petroleum products from Russia, as dictated by a EU Council Regulation published June 3.

At the Madrid Summit, Biden said that the West would not insure Russian ships carrying oil. We would not provide insurance for them, so they would have great difficulty getting customers.

Taken together, the sanctions would reduce the amount of oil the EU buys from Russia by 90%.

Despite Western sanctions on Russian oil exports, Russias revenue from oil exports has risen as a function of increasing fuel prices felt across the world. U.S. Treasury Secretary Janet Yellen has been a key proponent of imposing a price cap on Russian oil sales to Europe; such a cap would allow Russian oil sales in the market, but at a lower revenue stream, especially as several of the EUs sanctions are being phased in by the end of the year.

Supporters of the price cap include Sloan professor Simon Johnson PhD 89, who serves as adviser to the Russian Tanker Tracking Group. Johnson said Theres no other active idea that would impact Putins revenues from fossil fuels over the next five months and that the Russians have been quite cynically manipulating gas markets, so this would be a chance to turn the tables, according to a New York Times article on June 26.

Critics of the approach worry that Russia could refuse to sell at too low of a price cap and utilize its market in India and China for a higher revenue stream.

Biden commented June 30 that we should consider putting a cap on the amount of money that we would pay for Russian oil. Were going to allow you to have a profit on what you make but not the exorbitant prices that youre charging for the oil now. We think it can be done, and it would drive down the price of oil, and it would drive down the price of gasoline as well.

Following the recent G-7 Summit a meeting of the leaders of Canada, France, Germany, Italy, Japan, Britain, and the U.S. the seven countries agreed on sanctions extending beyond oil regulations. All G-7 members announced a ban on imports of Russian gold.

Altogether, the sanctions imposed from resources like natural gas to U.S. bans on debt payments using money held in U.S. banks have dealt notable blows to Russia. For the first time since 1998, Russia defaulted on a debt, a $100 million payment, which sanctions made impossible to pay.

As Ukraine enters its fifth month of war, financial sanctions implemented by alliances in the EU and abroad seek to highlight solidarity with Ukraine and isolate Russia from the global market.

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European Union to reduce purchasing of Russian oil by 90% - The Tech