Recital 18

(18) Since restrictive measures imposed by the Union and partner counties significantly limit the ability of Russia to access international markets and procure military equipment, as well as the possibility for listed persons to carry out financial transactions, new circumvention mechanisms have emerged. Such mechanisms include the offering by operators outside the financial sector of access to payments from third countries through legal persons under their control or through complicit intermediaries, as well as the activities of operators who offer services to enable access to schemes that make it possible to carry out international transactions without cross-border payments, instead using alternatives such as netting, set-off, reconciliation or settlement. With a view to ensuring that such circumvention practices are not effective, it should be prohibited to carry out any transaction with operators that are identified as offering services to enable international transactions that circumvent restrictive measures. It is appropriate to clarify that, by their nature, derogations granted in Regulation (EU) No 833/2014 or in Regulation (EU) No 269/2014 cannot constitute a circumvention of the prohibitions contained in those legal acts. Therefore, transactions carried out in compliance with those exceptions and derogations do not constitute international transactions that circumvent restrictive measures.

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Source: EUR-Lex (Cellar) · retrieved 2026-10-09 · Text as adopted (Official Journal); later amendments are not incorporated in this text.