Large EU sanctions data gap since more than THREE WEEKS!

Status: Jan 10 2024, 09:46 CET.

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1.) Background
On December 18 2023, the 12th EU Russia Sanctions Package was published in the EU Journal. On the same day, Council Implementing Regulation (EU) 2023/2875 entered into force, which includes 147 newly sanctioned parties. Their names were published in the EU Journal and they are subject to an asset freeze.

2.) Sanctions Data Gap
❗Although published in the official organ (EU Journal) and effective Dec 18 2023, these parties are still NOT included in the downloadable EU sanctions list files, which are widely used in the industry for screening purposes.
❗This means a huge screening gap for all who rely on these EU data formats – or on commercial providers who use this source only instead of the EU Journal.
❗Please note that the EU is very clear on this matter: The EU Journal content is binding! Not the content of their downloadable list format!

Do you want to know if you are affected?
Please check the following names in your system (examples only):
➡ LLC MirTelecom (ООО МирТелеком)
➡ JSC Spetsmash
➡ Federal State Enterprise ANOSIT

EU Journal 18 December 2023:
Council Implementing Regulation (EU) 2023/2875:
EU Consolidated Sanctions List:

3.) Why is this dramatic?
Newly sanctioned parties, which are subject to an asset freeze, have plenty of time to move their assets silently out of reach.
I am pretty sure that there are enough helpers from legal and advisory services who read the EU Journal and warn their Russian clients.
And of course there is a huge risk of sanctions violation for all companies who rely on patchy screening data. Potential consequence: A remediation of all transactions since Monday Dec 18 2023.

4.) What are possible reasons for the delay on EU side?
In theory, there are several explanations:
➡ Systemic reasons (holiday season, weekends, processes etc.)
➡ Legal or political reasons
➡ Technical reasons
➡ Man-made/human error
➡ Sabotage

Sanctions-intelligence[.]com has observed and reported this phenomenon a couple of times already. This time, the delay is extreme.
And NONE of the explanations above is acceptable!

5.) What is the outcome?
In the end, Russia sanctions do not bite as they could. For reasons that cannot be tolerated.
Particularly in times of war, where the future development depends on the success of these measures.

Sanctions-intelligence[.]com monitors the EU Journal on a regular basis, and the respective EU Consolidated Sanctions List even every five minutes for changes: