Update on sanctions developments in connection with the invasion of Ukraine - Norway has implemented the EU's sixth and latest sanctions package

The prohibition on import, purchase or transfer of crude oil and other petroleum products listed in Annex XXV from Russia entered into force immediately (17 June 2022). The prohibition also covers technical assistance, brokering services, financing and financial assistance in respect of the same. The regulations contains certain exemptions, as well as the following transitional periods:

• Until 5 December 2022 for crude oil (provided the delivery is a spot cargo, or the contract concerns CN 2709 00^[1] and was entered into prior to 18 June 2022); and


• Until 5 February 2023 for petroleum products (provided the delivery is a spot cargo, or the contract concern CN 2710^[2] and was entered into prior to 18 June 2022).

Until further notice, the prohibition does not apply to CN 2709 00 products that are shipped via pipeline to the EU or to Norway. Certain special restrictions apply to such oil products.

The regulation prohibits providing technical assistance, brokering services, financing or financial services relating to the transport of crude oil/petroleum products that have originated in Russia to third countries, meaning other countries than Norway and EU member states. The prohibition does not concern contracts entered into before 18 June 2022 and which are fulfilled by 5 December 2022.

It should be noted that the above mentioned prohibitions apply irrespective of whether such oil products originate in Russia. However, the prohibitions do not apply to such oil products that are transported by sea and are merely loaded in, in transit through or shipped from Russia, provided that the oil products originate outside Russia and do not have a Russian owner,

An additional three Russian banks are excluded from the SWIFT payment system, Russia's largest bank Sberbank, Credit Bank of Moscow and Russian Agricultural Bank.

The new regulation further prohibits providing accounting, auditing, bookkeeping or tax consulting services, or business and management consulting or public relations services to the Government of Russia or legal persons, entities or bodies established in Russia with exceptions for services which are necessary for the termination by 19 July 2022 of prohibited contracts concluded before 18 June 2022. The prohibition does not apply to necessary legal services relating to the right of defence in judicial proceedings and the right to an effective legal remedy. The prohibition does furthermore not apply to services provided to Russian entities which are owned or controlled, solely or jointly, by a person/entity incorporated in Norway or the EU.

The ministry of foreign affairs may provide exemptions for services necessary for humanitarian/human rights/civil society purposes.

The regulation also expands the list of goods/technology in Annex IX – Advanced Technologies to include export restrictions/prohibitions on several several chemicals.

Additional goods are added to the list of import restricted goods in Annex XXI.

In addition, another 65 individuals including military personnel, government personnel, businesspeople, and family members and 18 entities including military suppliers and contractors, vehicle manufacturers, other suppliers to the Russian Government in have been listed. New entities listed include Pella Shipyard OJSC, Optron JSC and United Shipbuilding Corporation ‘5th Shipyard. These listings entered into force on 3 June 2022. In total, 1,158 Russian individuals and 98 entities have been listed.

Please note that these updates do not provide an exhaustive description of all sanctions in place. Any person or entity involved in business activities in any way related to Russia, Belarus or Ukraine should carefully assess how they are affected by the sanctions.

Our sanctions team offers guidance on the increasingly complex and frequently changing sanctions regulations, including how to ensure compliance with the same.   

^{[1] CN 2709 00 - Petroleum oils and oils obtained from bituminous minerals, crude}

^{[2] CN 2710 - Petroleum oils and oils obtained from bituminous minerals, other than crude; preparations not elsewhere specified or included, containing by weight 70 % or more of petroleum oils or of oils obtained from bituminous minerals, these oils being the basic constituents of the preparations; waste oils}