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Update on Russia Sanctions FAQs: Clarifications on Approval Procedures and Cross-Border Services under Art. 5n EU Regulation

  • The European Commission has updated the consolidated FAQ on sanctions against Russia and Belarus
  • Clarifications on approval procedures and cross-border services related to Article 5n of Regulation (EU) No. 822/2014
  • Article 5n prohibits certain services for the Russian government and entities, with exceptions for EU subsidiaries and companies from partner countries
  • A new approval possibility for national authorities of EU Member States has been created
  • BAFA has issued General Approval No. 42 for transactions and services under Article 5n
  • The updated FAQs address the implementation of Article 5n and national approval procedures
  • National authorities can issue collective approvals for similar services to the same Russian customer
  • The Commission clarifies that Regulation (EU) No. 833/2014 does not allow bundled approvals or approvals for multiple Member States for the same service

Source: awb-international.de

Note that this post was (partially) written with the help of AI. It is always useful to review the original source material, and where needed to obtain (local) advice from a specialist.

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