#32026D1333EU Allows Temporary Sanctions Derogations for Critical Component Purchases
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
This decision creates limited exceptions to EU asset-freeze sanctions for one listed entity connected to Russia related measures over Ukraine. Member State authorities may allow frozen funds to be released, or funds to be made available, only where the money is strictly needed for specific permitted purposes. EU businesses affected by supply chain exposure to this listed entity get time to wind down existing contracts by 31 December 2026. They may also buy critical components from the entity until 16 March 2027, but the purpose must be to support a move to alternative suppliers. Companies should document the need, seek national authorization, and prepare a diversification plan before the exception ends.
AI-generated summary. May contain errors. Refer to official sources for legal decisions.
Key Changes
- Adds a temporary exception to the asset freeze for winding down operations and contracts with the listed entity by 31 December 2026
- Allows authorized industry purchases of critical components from the listed entity until 16 March 2027
- Requires the exception to support a transition toward alternative sources of supply
Obligations
What this law requires
Do not release frozen funds or economic resources of the entity listed under entry number 692, or make funds or economic resources available to that entity, unless the competent Member State authority has authorised the transaction under the specified derogation.
For wind-down transactions with the listed entity, ensure the operation, contract, or agreement was concluded before 23 April 2026 and is terminated by 31 December 2026 under national competent authority authorisation.
Complete any authorised release or making available of funds or economic resources for wind-down purposes no later than 31 December 2026.
Only purchase critical components from the listed entity under the derogation where the purchase is for industry needs and is intended to enable transition toward alternative sources of supply.
Obtain competent Member State authority authorisation before making corresponding payments to the listed entity for critical components manufactured by that entity.