Official letters to 16 EU countries regarding the implementation of IT consultancy sanctions

On January 8, 2023, a complete ban on European legal persons, entities or bodies to provide software development and implementation services, as well as services for installing physical computer equipment and computer networks to Russia entered into force. Thus, every European company that after January 8 continues to provide or distribute any access to its software, technical systems, computer equipment or technical specialists to Russian companies or government, violates the EU sanctions regime.

These sanctions are of great importance at the moment, as some sectors of the Russian economy, such as the banking sector, industrial production, mechanical engineering, industrial equipment, and logistics, are still being sensitive to the use of European IT products. Depriving the Russian market of European intellectual resources will significantly weaken the ability of Russian businesses that finance terrorist activities in their country.

Control over compliance with sanctions, including IT sanctions, is entrusted to the authorized bodies of the EU member states. The EU member states determine the available penalty framework for the violation of the EU sanctions.

We have contacted the competent authorities in 16 EU Member States with a request to provide information on how IT sanctions are applied at the national level. In particular: How is the control over the implementation of sanctions in the field of IT consultancy ensured? How do national authorities ensure the identification of clients from Russia who are provided with IT services by European companies? How do national authorities control that IT services are not provided to the Russian market by persons who, although they are not EU citizens, carry out business activities on the territory of the EU?

This information will help our Foundation to organize assistance to national authorities in monitoring alleged violations of IT sanctions by European companies and to prevent the outflow of intellectual resources from the territory of the EU to Russia, which illegally initiated a bloody war on the territories of sovereign Ukraine and daily commits genocide, atrocities and massacres, causing significant damage to all Ukrainian people, including those represented by our Foundation.

Together we will stop the aggressor country and ensure the peaceful existence of Ukrainians!

A more detailed analysis of IT consultancy sanctions can be found in the MEMORANDUM on EU sanctions against Russia in IT consultancy prepared by Ukrainian Victims of War Foundation.