#32026R1336EU temporary sanctions derogations for supply-chain wind-downs and critical components
AI-generated summary for informational purposes only. Not legal advice. See the original source for the authoritative text.
This regulation creates temporary exceptions to EU asset-freeze rules for one sanctioned entity listed in the Ukraine sanctions regime. Member State authorities may allow frozen funds to be released, or funds to be made available, where this is strictly needed to end existing operations, contracts, or agreements concluded before 23 April 2026 by 31 December 2026. It also allows limited industry purchases of critical components made by that entity, subject to approval. Businesses using the entity’s components should treat this as a short transition window, prepare alternative suppliers, and document why any approved transactions are necessary.
AI-generated summary. May contain errors. Refer to official sources for legal decisions.
Key Changes
- Adds a temporary derogation from EU asset-freeze restrictions for one listed sanctioned entity
- Allows approved wind-down of pre-23 April 2026 operations, contracts, and agreements by 31 December 2026
- Permits authorised industry purchases of critical components made by the sanctioned entity during the transition period
Obligations
What this law requires
Union operators must obtain authorisation from the competent authority of a Member State before using the temporary derogation to release frozen funds or economic resources belonging to the entity listed as entry number 692 in Annex I, or before making funds or economic resources available to that entity.
Authorised releases of frozen funds or making available of funds or economic resources may be used only where strictly necessary to wind down operations, contracts, or other agreements concluded with the designated entity before 23 April 2026.
Union operators relying on the derogation for industry purchases of critical components manufactured by the designated entity must obtain competent authority approval before carrying out those purchases.
Operators using the temporary derogations are expected to adopt and implement appropriate diversification plans before the derogation expires, enabling transition to alternative sources of supply.