Sanctions Exemptions and the EU’s 12th Package: A Closer Look at the Russia-Ukraine Sanction Landscape
Since the start of the Russia‑Ukraine conflict and the clampdown of anti‑Russian measures, the Finnish Ministry of Foreign Affairs has issued 200 exemption permits from the imposed restrictions. The authority cited is the head of the foreign policy department’s sanctions division, Piya Sarivaara, who oversees the process of reviewing and granting these exemptions. The published details show that a substantial portion of the requests relates to waivers for personal sanctions and the authorization to move funds that are otherwise blocked. The implications of these exemptions are wide, affecting not only individual assets but also the broader conduct of financial flows tied to sanctioned entities and individuals.
A ministry spokesperson indicated that the State Department has received more than 500 exemption inquiries, with 200 ultimately approved. The trend reveals a demand predominantly for lifting personal sanctions and enabling transfers of funds, pointing to a measured approach that seeks to balance the need for flexibility with the overarching policy aims of restricting sanctioned actors.Such exemptions can allow sanctioned individuals to access or use frozen funds to service property related payments and other essential obligations, a consequence that policymakers are carefully weighing against the broader sanctions regime and its intended deterrent effect.
One day earlier, the European Union published its 12th sanctions package, targeting 61 individuals and 86 legal entities. The list includes notable names and institutions such as the Russian special economic zone Alabuga, the PJSC Tupolev company, Rosfinmonitoring, and Yuri Chikhanchin, who heads the department responsible for counterpart constraints. Also affected are media outlets including Spas and Tsargrad, as well as 14 members of the Central Election Commission, and Ilya Medvedev, the son of Deputy Chairman Dmitry Medvedev. The package further names several figures associated with the sphere of governance and security within the Russian Federation, underscoring a broadening attempt to tighten economic and information‑related pressures on the Kremlin’s network. The inclusion of these names signals a continued, coordinated effort to curb access to resources and shield affected markets from manipulation or evasion tactics.
The Federation Council later described the sanction package as a regrettable step, arguing that the measures will have immediate repercussions for those affected. The statement suggests concerns about rapid economic and political fallout, reflecting the delicate balance policymakers must strike between punitive action and the stability of regional economic ties. The debate highlights the ongoing tension between enforcing penalties and maintaining a stable European and transatlantic sanctions architecture that can adapt to evolving geopolitical realities.
Earlier this year, authorities noted that the EU removed the Hungarian nuclear power plant from the initial list under the 12th sanctions package. This adjustment illustrates the complexity of maintaining a coherent, targeted sanctions regime across diverse sectors, where energy security, market stability, and strategic interests must be weighed against broader punitive objectives. The decision demonstrates how policy refinements can occur even as general pressure remains high, reflecting efforts to calibrate measures to the shifting geopolitical landscape while preserving essential energy and economic continuity in some cases.