[Update] Recent key sanctions imposed against Russia by the EU and the UK: EU FAQs related to the Infrastructure Transaction Ban (Article 5ae of Council Regulation EU no. 833/2014) We refer to our Circular No.24-023 dated 12 March 2025 on the 16th package of sanctions against Russia adopted by the EU. We noted in the Circular that the package included Article 5ae of Council Regulation 833/2014 introducing a ban to engage in any transaction with ports listed in Part A of Annex XLVII, namely: Ust-Luga, Primorsk, Novorossiysk, Astrakhan and Makhachkala. Paragraph 3 of the Article 5ae provided an exhaustive list of exemptions from this ban. We also noted that the International Group was seeking clarification on whether the transport of certain cargoes, that can still be exported from Russia, e.g. coal, is still permitted as there was no specific exemption for such cargoes.   On 20 March 2025 the EU published FAQs on infrastructure transaction ban introduced in Article 5ae.   The FAQs clarify that - unless specifically exempt under paragraph 3 of Article 5ae - goods cannot be exported from the listed ports:   “4. Can the listed ports and locks in Russia be used for the transit of goods originating in Russia and not subject to an import ban? Last update: 20 March 2025   Article 5ae provides for a broad transaction ban. In principle, EU operators cannot engage in transactions if this concerns products not explicitly exempted in Art. 5ae paragraph 3. This also covers goods that are not subject to an import ban . Other Russian ports that are not listed in Annex XLVII can be used for the transit to a third country or for the import into the Union (if the good in questions is not subject to an import restriction)”.   And the same position is confirmed specifically in relation to coal:   “5. Can the listed ports and locks in Russia be used for the transit of Russian-origin coal to third countries? Last update: 20 March 2025   The Union is comm