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12th Sanctions Package: Ban on Services and Software for Business Now Also Applies to Subsidiaries from the European Union

On December 19, 2023, the 12th package of EU sanctions came into effect, and we would like to draw your attention to the following.
Ms. Olga Grigorieva
General Director

Starting from June 4, 2022, European sanctions have included a ban on various services. The Russian Government and Russian companies are no longer allowed to acquire services in the EU that fall under these sanctions. This list of prohibited services has been expanded several times. As of today, it is so extensive that virtually all standard business services fall under this ban.

With the 12th package, software for business, which cannot be exported, provided for use, or otherwise made available to Russian companies, was added to this prohibition. Abstractly speaking, Windows and Office might still be possible, but more complex business solutions have been under sanctions since December 19 of last year. And on March 20, 2024, the transitional period for contracts concluded before the 12th package came into force will end.

From the very beginning, this general prohibition contained a rule that these sanctions on services should not harm the subsidiaries of legal entities from the European Union. There was a general exemption from this prohibition for them.

But now this ban on services and software will also apply to all subsidiaries of the EU without exception, starting from June 20, 2024. The sanctions resolution included a clause allowing national sanctions control authorities to, at their discretion, grant exceptions to EU subsidiaries for the further use of these programs and services after June 20, 2024, based on applications from specific firms. However, there are no criteria for making decisions, and procedural issues for submitting and reviewing such applications have not yet been resolved.

Thus, there are 5 months left before the start of the ban. We and our partners offer you a review of what this specifically means for the operation of your company in Russia, what services of the parent company you can still use, in what volume and form these services can be provided, as well as what software commonly used by companies in your group can be used by you and under what conditions after June 20, 2024.

To apply for this service, you can now use the form on the website or send your request to, with the subject line – 12th package.