Restridions on fidde-

reloted
findncing
in the
technologies/goods
The possibility
for Russia to substitute such products
and technologies
originating from the EU or US is low in view of the likely unavailability of
similar products (of
similar degree of sophistication and quality)
elsewhere.
For these key, high tech, high value added technologies, which are not
dual use goods,
restrictions would take the form of a authorization
regime based on a Council decision and implementing Regulation with a
prohibition
to export the identified items when they are destined to
specific projects.
There would be a system of prior
authorization for the sale, supply,
transfer or export, directly or indirectly, of the technologies listed in the
Council Regulation, whether or not originating in the-onion, for use in
Russia. Public authorities would deny export authorization of pre-
identified technologies when there are
grounds
to determine that the
products
are destined for proiects
in deep sea drilling, arctic exploration
and shale oil. Gas related projects
would not be affected. An indicative
list of possible
concerned items is annexed. The licensing system is to
ensure that the ban is selecilve, limiting the impact for exporilng
companies.
Coordination with international partners (US
considering same type of
restrictions) as well as other non EU countries (Norway)
would be
required to make the EU measure effective.
To note, that US only sanctions would still affect EU
producers
via the de
minimis rule according to which products
with at least 25% of US content
would fall underthe export prohibition.
This restriction would cover the provision
of technical and financial
assistance like export credi! re-insurance or other financial services
associated with trades in commodities which are themselves subject to
restrictions. lt is therefore a standard ancillary measure aimed at
assisting the enforcement of sanctions.
The measure would negatively impact on Russia by increasing the cost of
accessing to those services in alternative markets (cost increase
estimated to around 1-2%). There could be negative impacts for service
providers,
although a loss of revenue would occur anyway due to the
restriction of the related trades. The US are ready to take a similar
measure. lf sanctions only apply to some categories of dual use
technologies, it would have a very modest impact.
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