EU: Council Regulation (EU) 2024/745 — 13th Russia sanctions package (extended export bans, anti-circumvention entity listings)

Mechanism

Twelfth consecutive amendment to the core Regulation (EU) No 833/2014 Russia regime. Two mechanisms: (1) an expanded CN-code export-ban annex covering further dual-use and advanced-technology goods; (2) 27 entities added to the Annex IV "no-exception" list — firms located outside Russia (China, Hong Kong, India, Sri Lanka, Serbia, Kazakhstan, Thailand, Turkiye) assessed as channels for sanctioned-goods transshipment or direct military-industrial support to Russia. This is the anti-circumvention enforcement track the 11th package's Article 12g tool set up, now exercised against named third-country firms rather than countries generically.

Severity basis

Mixed: the export-ban CN-code expansion is a qualitative scope judgment, but the entity-listing component is quantified and verifiable — 27 entities added to the no-exception export-ban list, alongside 106 individuals and 88 entities newly asset-frozen under the parallel Council Decision.

Downstream implications

• First package to name specific third-country (non-Russia, non-Belarus)

firms for circumvention rather than sanctioning a country's trade generically — a template the later 14th+ packages extend.

• Chinese, Hong Kong and Indian entity exposure here is a direct input to

any company-dossier flagging a counterparty on this list.

Open questions

• The 27 named entities were not individually re-verified against the

Annex IV text for this filing; company_refs is left empty pending a pass that extracts and confirms each legal name from the regulation's own annex rather than secondary summaries.