The next round of sanctions have been adopted and we are now waiting for their publication. The suggestions are that more individuals, companies active in dual use products and companies in the financial services sector will be affected. This then would mark a further development of the SMART sanctions adopted at the end of July.

As we cannot yet see the new measures it is worth just noting the three key issues that should be taken into account when we finally do review the text:

The EU adopted further sanctions against Russia on Friday.  Leaving to one side the political aspects, from a purely commercial level, for companies subject only to EU jurisdiction (as compared to those subject to EU and US measures) the current EU sanctions are unlikely to have any direct commercial impact.