12.12.22 / Embargo / Campaign Updates

Open letter on the urgency of enforcement of energy sanctions against Russia

Letter to European Council, Ministers of foreign affairs of EU member states, Members of European Parliament.


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European Council

Ministers of foreign affairs of EU member states

Members of European Parliament

We address you at a time when millions of Ukrainians are being deprived of power supply, heating and critical services due to massive attacks on our energy infrastructure by Russia. The country now officially recognized as terrorist state is willfully targeting our civillian population of Ukraine and  attempts to create humanitarian catastrophe in Europe.

Since March over 850 organizations from more than 60 countries have expressed solidarity with Ukraine and joined a collective call for effective global sanctions on the Russian fossil fuel trade, and for an immediate end for any investments in Russian oil, gas and coal production. We reiterate this call with extreme urgency.

Despite all the restrictions and sanctions imposed by the EU in previous 8 packages, Russia continued to receive billions of euros from the export of oil and gas. These funds are enough to continue financing the war in Ukraine. The income from the export of fossil fuels during the first 100 days of the war amounted to about €100 billion. And according to the words of the Minister of Finance of Russia Anton Siluanov, these surplus profits were used to finance the war in Ukraine. Effective enforcement of the EU oil embargo and G7 price cap is of utmost importance today as these measures have the potential to undercut the key revenue stream of the aggressor country.

According to CREA latest findings, in November most of the Russian oil and oil products were still shipped using tankers with European ownership or insurance, showing that Russia so far had little success in finding alternative shipping and insurance providers so far. This illustrates how strong a set of tools the price cap coalition has to force down Russia’s oil revenues by lowering the price cap in the coming months. Experts recommend setting the price cap lower than the market price and closer to production cost, which is estimated at $30.

Strong penalties are necessary to deter shipping companies from violation of sanctions and create incentives for compliance. It is essential to set tough penalties for vessels that don’t comply with the price cap, banning them from eligibility for insurance or entry into ports of EU member states forever. The same should be applied to all vessels, that will be identified as carriers of illegally transhipped Russian oil.

Involvement of any European entities in trade of unsanctioned Russian oil or circumvention of related sanctions should be disincentivized by strong penalties, while sanctions breaches should be investigated and prosecuted as crimes by all governments that express good will to end Russian aggression and invasion in Ukraine. We trust in your resolve to deliver strong and comprehensive enforcement of the EU embargo and G7 price cap on Russian oil that entered into force on 5th December.

On December 2 the European Commission put forward a proposal to harmonise criminal offences and penalties for the violation of EU sanctions and restrictive measures against Russia. This proposed directive among other things lists as criminal offenses “trading in goods or services whose import, export, sale, purchase, transfer, transit or transport is prohibited or restricted” which clearly applies to Russian oil in case of non-compliance with the G7 price cap and EU oil embargo.

We, as a Ukrainian grassroots organization focused on climate justice and human rights, call on all EU Member States to support this legal initiative and streamline its swift implementation by national law enforcement systems.

United and strong European response against Putin’s aggression is long overdue and we urge for it now. You have the power to stop the war in Ukraine by depriving Russia’s economy and federal budget of a key source of income. Please use this power.

With highest gratitude for your ongoing support, and faith in your strong response.


Svitlana Romanko, Director and Founder of Razom We Stand

Oleh Savytskyi, Campaign Manager of Razom We Stand