Military goods cover military technology and equipment which may be used for internal repression or international aggression or contribute to regional instability.
Dual-use goods are items, including software and technology, which can be used for both civil and military purposes, and include all goods which can be used for the manufacture of arms and military equipment, weapons of mass destruction or their delivery, etc.
Usually when arms embargoes/ restrictions on dual-use items are imposed, the related technical, financial assistance as well as other services are also prohibited. Although the primary responsibility for the classification of goods and technologies lies with the customers sending or receiving such items, the prohibition to provide financial assistance is also mandatory for the Bank.
The prohibition on military goods/ dual-use items means that Swedbank cannot participate in any financial transactions, provide business support or any financial support to customers that sell, supply, transfer, mediate or export such goods to restricted countries (e.g., the Russian Federation), if they are intended for military purposes, or sell, supply, transfer or export such goods to the certain EU-listed entities. Therefore, Swedbank may conduct additional checks on related payments. As a result, the execution of the payment order may be delayed or cancelled.
There are EU-listed items related to the energy sector listed by the EU which are restricted for export to Russia. The U.S. has imposed restrictions on all goods/ non-financial services or technology in support of energy projects. Therefore, the Swedbank must be aware if the customer has an authorization from competent or sanctions-issuing authorities in order to not be involved in prohibited transactions.
Sectoral sanctions against Russia
In response to the military aggression, the EU has significantly expanded sanctions against Russia, adding unprecedented restrictive measures to the list of sanctions, supplementing the existing measures applied to Russia since 2014 in connection with the annexation of Crimea and the violation of the Minsk agreements. The newly introduced sanctions against Russia include not only an embargo on goods, but also a ban on the provision of services. Goods that may not be exported to Russia are, for example: goods and technology suited for use in aviation or space industry, luxury goods, maritime navigation goods and technology, goods and/or technology suited for use in oil refining, goods which could contribute in particular to the enhancement of the Russian industrial capacities. Goods that may not be imported from Russia include: crude oil and refined petroleum products, coal and other solid fossil fuels, steel, gold including jewellery, cement, wood, paper and plastic, seafood and alcoholic beverages. The EU has prohibited the provision of certain business-related services to the Russian government, or any legal entity established in Russia: accounting services, IT consulting, legal consulting, architectural and engineering services, advertising, market research and public opinion research services. Any EU-registered legal person, entity or body of which 25% or more is owned by a Russian natural or legal person, entity or body is prohibited from becoming a road transport company engaged in the carriage of cargo by road within the territory of the EU, including in transit.
Sectoral sanctions against Belarus
In response to human rights violations in Belarus and the violent repression of civil society, democratic opposition and journalists, the EU has imposed new sanctions against Belarus since 2020.
In light of the falsified results of the presidential elections in Belarus on 9 August 2020 and the violence committed by Belarusian security forces against peaceful protesters, the democratic opposition and journalists, the EU has imposed sanctions against a number of natural and legal persons. On 4 June 2021, the Council also banned all Belarusian airlines from taking off from, landing in or overflying EU territory.
In view of Belarus' involvement in Russia's unprovoked and unjustified war against Ukraine, on 29 June 2024 the EU adopted additional restrictive measures targeting the Belarusian economy. These restrictive measures are aimed at imposing sanctions already in place against Russia, thereby limiting the circumvention of sanctions imposed against Russia as a result of the high degree of integration between the Russian and Belarusian economies. The new sanctions include trade restrictions, a ban on the supply of certain services, transport and logistics restrictions and anti-circumvention measures that will affect various sectors of the Belarusian economy.
Please note that the above lists are not complete. The full list of prohibited goods and services, as well as other restrictions can be found in the link below.
EU Common Military List
EU Dual use controls
EU Council Regulation related to Russia sectoral sanctions
EU Council Regulation related to Belorussian sectoral sanctions