Gold restricted, and food deliberately left alone

The seventh package, adopted in July 2022, prohibited imports of russian gold — a significant export earner and a store of value that had been used to move wealth quietly.

The part I want to record, though, is the other half. The package wrote explicit exemptions for food, agricultural products and fertiliser, and clarified that banks and shipping companies could handle those trades without breaching the restrictions.

Why the carve-out mattered

Sanctions have a compliance chilling effect. A bank facing a complicated rulebook will often refuse a transaction it is legally allowed to process, simply because refusing is cheaper than checking. In the summer of 2022 that risk was real for grain and fertiliser cargoes bound for countries in Africa and Asia — places with no involvement in this war and no margin for a food price shock.

Writing the exemptions down explicitly, and saying so publicly, was a deliberate act of design. Anyone who works with trade compliance will recognise it as the difference between a rule that works and a rule that merely exists.