On 4 May, the EU Sanctions blog advised of guidance on ‘firewalls’ which allow non-designated EU entities controlled by EU-designated persons to continue their business operations in the trade in agricultural and food products, including wheat and fertilisers. The EU Commission says that several cases concerning the trade in agricultural and food products, including wheat and fertilisers, have been brought to its attention in the past months, and it is necessary to ensure that those cases may not lead to food insecurity around the globe.
https://finance.ec.europa.eu/system/files/2023-05/230503-guidance-firewalls_en.pdf