BELGIUM Law and Practice Contributed by: Valerijus Ostrovskis, Bogdan Evtimov, Michael De Boeck and Coline Cauvin, ACQUIS
thing that is relevant for sanctions against Russia and Belarus. This may extend to several years in cases where the individual’s/entity’s listing is renewed at regular reviews and/or is challenged in the EU’s Gen - eral Court. 5. Trade and Export Restrictions 5.1 Services Council Regulation (EU) No 833/2014 imposes sev - eral service-related bans aimed at restricting trade and economic interactions with Russia. These bans, alongside legal and other professional services pro - hibitions, include the following. • Technical Assistance and Brokering Service: There is a prohibition on the provision of technical assistance, brokering services, or other services related to goods and technology covered by export bans. This includes services associated with the use of dual-use goods and technologies that might contribute to Russia’s military or technological enhancement. • Financial Services: There is a ban on providing financial assistance for trade involving prohibited goods and technologies. This extends to credit-rat - ing services and other financial activities that could support Russian sanctioned sectors. • Business and Industrial Software Services: The Russia sanctions include a prohibition on providing software for business management and industrial design and production. This covers systems such as Enterprise Resource Planning (ERP) software, which is used for managing supply chains and customer relationships. • Transport and Logistics Services: The regula - tion bans services related to the transportation of goods covered by the sanctions. This includes restrictions on Russian transport undertakings operating within the EU and the use of EU ports and locks for certain Russian vessels. • Prohibition on Media Services: Certain Russian media outlets are subject to a broadcasting sus - pension within the EU. Additionally, advertising on these banned media outlets by any means is prohibited.
• Cryptocurrency Services: The regulation extends to services involving crypto wallets, crypto accounts, or crypto custody services for Russian nationals and residents. These measures aim to prevent the use of cryptocurrencies to circumvent other sanc - tions. 5.2 Goods Council Regulation (EU) No 833/2014 imposes restric - tions on the export and import of several goods to and from Russia. These bans include the following. • Dual-use goods and technology, which can be used for both civilian and military purposes, are restricted. Military goods, specifically designed for military applications, are also prohibited. Maritime navigation equipment for maritime use is restricted, as are advanced electronics and components – particularly those intended for military applications. Industrial machinery used in various production processes is also included in the sanctions. • The energy sector faces sanctions on equipment and technology related to oil exploration, produc - tion, and refining. • Aviation and space industry goods, including air - craft and spacecraft, are restricted as well. Motor vehicles – including trucks, buses, and special vehicles, as well as high-end luxury vehicles – are prohibited. • High-value luxury goods (eg, luxury cars, jewel - lery, and high-end fashion items) are banned if they exceed certain value thresholds. Precious metals and stones (eg, gold, silver, platinum and dia - monds) are banned. • Iron and steel products – both finished and semi- finished – are sanctioned, alongside coal and other solid fossil fuels. • Banknotes and securities, which include currency and financial instruments, are restricted under the sanctions. 6. Civil Litigation and Arbitration 6.1 Force Majeure Belgian courts may consider compliance with sanc - tions as a case of force majeure. This means that com - panies may be able to invoke force majeure clauses in
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