“This round of sanctions on Russia is the most wide-sweeping since the start of the war, together with new hybrid, human rights, and chemical weapons-related sanctions. In this 17th package, we include Surgutneftegas - a Russian oil giant - as well as almost 200 vessels in Russia’s shadow fleet. While Putin feigns interest in peace, more sanctions are in the works. Russia’s actions and those who enable Russia face severe consequences. The longer Russia persists with its illegal and brutal war, the tougher our response will be.” - Kaja Kallas, High Representative for Foreign Affairs and Security Policy and chair of the Foreign Affairs Council.

These measures were adopted through:

• 6 Common Foreign and Security Policy (“CFSP”) decisions; 
• 2 Council regulations; and 
• 4 Council implementing regulations. 

Takeaways

• Alongside the traditional 2014 frameworks used to sanction Russia, the Council is now making use of the full range of tools available to it. It adopted restrictive measures based on regimes concerning Russia’s destabilising activities, domestic violations of human rights and the use of chemical weapons, in addition to those driven by its war of aggression against Ukraine. 
• Regarding the increasing risk of circumvention of sanctions embodied by the Russian shadow fleet, the EU made 189 additional vessels subject to a port access ban and a ban on provision of services, bringing the total number of listings to 342. In this light, the 17th package of sanctions constitutes “the largest single G7 sanctions action targeting shadow fleet vessels”. 
• The Council improved the regime framework adopted in October 2024 regarding Russia’s hybrid threat actions, paving the way for a new transaction ban on tangible assets used in those actions and a broadcast prohibition. 
• Finally, “more sanctions are in the works” posted Kaja Kallas, High Representative of the European Union for Foreign Affairs and Security Policy, on X, announcing an upcoming 18^th package of sanctions. 

1. Individual Restrictive Measures

New Designations & Listing Criteria Amendment

Interestingly, the EU added a total of 133 persons to its Consolidated list of persons subject to EU financial sanctions under four different sanctions regimes, showing the willingness of the EU to use all the tools in its possession to increase the cost for Russia to continue its war.    

The newly listed individuals and entities are subject to asset-freezes and restricted access to funds. Natural persons are additionally subject to a travel ban, which prevents them from entering into or transiting through the territories of EU member states.

• Russia’s war efforts – The Council added 17 individuals and 58 entities to Annex I to Regulation 269/2014, including: 
  
  • 17 Russian individuals, especially members of Russian research institutes or Directors/shareholders of Russian strategic companies;
  • 58 entities, mainly operating in the military sector (e.g. PJSC Ufa Aggregate Enterprise “Gidravlika”), the energy sector (e.g. PJSC Surgutneftegaz), and in the area of scientific research (e.g. Joint Stock Company “Research Institute of Communication and Control Systems”). While the majority are registered in Russia, some are also registered in Ukraine, Belarus, China, United Arab Emirates, Turkey, Hong-Kong and Israel. 

• Hybrid threats – The Council added 21 individuals and 6 entities to Annex I to Regulation 2024/2642 listing those linked to Russia’s hybrid threats against EU Member States. Most of the listed natural persons work within the media industry.‍
  
  • Amendment of the criterion for listing under destabilising activities regime – The listing criterion of persons engaged in Russia’s destabilising activities has been slightly extended to notably include people generally “facilitating” these actions. 

• Chemical weapons – The Council added 3 new entities to Annex I of Regulation 2018/1542 concerning restrictive measures against the proliferation and use of chemical weapons. These entities were added following the identification of a pattern of riot control agent use as a method of warfare on the frontlines in Ukraine. 

• Human rights and democracy in Russia – The Council added 28 additional individuals to Annex IV to Regulation 2024/1485, recognised for their human rights violations and repressions in Russia. 

2. Sectoral Sanctions

New Transaction Bans

• Tangible assets used for or involved in Russia’s destabilising activities. – The Council introduced a new provision enabling transaction bans on transactions including tangible assets used or involved in Russian destabilising activities, as listed in the new Annex III to Regulation 2024/2642. It is intended to include vessels, aircraft, real estate, ports, airports, and physical elements of digital and communication network and others where these are used for activities of a “destabilising character”.
  
  • Derogations and exemptions are included under this new transaction ban.  
    
    • This new transaction ban is an interesting development in EU sanctions law as it does not target an individual or an entity but a specific asset instead. Such a restriction will certainly generate operational issues for companies which will now have to be able to identify these tangible assets. This will have an impact on how companies have to conduct their due diligence before entering into a new relationship or a new transaction as they would also have to potentially screen the assets involved.     

• Crypto asset services involved in transactions facilitating Russia’s destabilising activities – The Council has added a new transaction ban concerning (i) non-EU financial institutions or entities providing crypto asset services involved in transactions that facilitate Russia’s destabilising activities or that support persons, entities or bodies that engage in such activities, and (ii) entities providing technical or operational assistance to these persons. No entities have been added yet to the new Annex IV to Regulation 2024/2642.
  
  • Exemptions are included under this new transaction ban.  

Export/Import-Related Restrictions

• Military-industrial complex –The Council added 31 entities to Annex IV to Regulation 833/2014 which have been identified as forming part of Russia’s military and industrial complex. EU exporters are prohibited from sending dual-use items and items contributing to Russia’s military and technological enhancement to these entities. 
  
  • These additions are mainly focused on drones and computer numerical control machine tools sectors, as well as laboratory equipment suppliers.
  • The list includes certain entities based in countries outside of Russia, such as Serbia, UAE, Turkey, Vietnam and Uzbekistan, that indirectly contribute to Russia’s military and technological enhancement thereby enabling the circumvention of export restrictions.

• Goods which might contribute to Russia’s military and technological enhancement, or the development of the defence and security sector (Annex VII to Regulation 833/2014)
  
  • Energetic materials and precursors – The Council added additional export restrictions on energetic materials and precursors such as boron and chlorates of sodium. These additions can be found in the list below. ‍
    
    • New listed CN codes‍
      
      • 2804 50 10
      • 2829 11 00
      • 2829 19 00
      • 7603 10 00
      • 7603 20 00
      • 8104 30 0‍
  • Machinery parts, assemblies and components – The Council added additional export restrictions on new machinery parts, assemblies and components. ‍
    
    • New listed CN codes‍
      
      • 8482 40 00
      • 8482 91
      • 8483 40 30
      • 8484 90 00
      • 9031 80 20

Energy Sector

• New designations of vessels contributing to Russia’s energy revenues (Annex XLII to Regulation 833/2014) – ‍
  
  • 189 additional vessels have been added to Annex XLII of Regulation 833/2014 subjecting them to a port and locks access ban as well as prohibiting them from receiving a broad range of services related to maritime transport. These additions are aimed at “further constrain[ing]” the “shadow fleet” of oil tankers contributing to Russia’s energy revenue.

• Sakhalin exemption - The duration of the exemption from the oil price cap which allows, in view of energy security concerns, the transport, by vessel, of crude oil originating in the Sakhalin-2 Project in Russia to Japan, was extended until 28 June 2026.

Media Sector

• Broadcast prohibition - The Council has strengthened restrictions on Russian media with a new prohibition on operators to broadcast or to enable, facilitate or otherwise contribute to broadcasting, any content by new listed entities, including through transmission or distribution by any means (including traditional TV mediums as well as internet TV providers and internet video sharing platforms), as listed in the new Annex V.
  
  • No legal persons, entities or bodies have been listed yet.

3. Conclusion

With this sanctions package, the EU has sent a strong signal that it is willing to continue to impose heavy and wide-ranging sanctions on Russia by using all of the tools at its disposal. In particular this round, the EU has further clamped down on Russia’s shadow fleet where it has extended its port access ban to almost 200 additional vessels. The EU is showing no signs of slowing down, with indications that work for an 18^th package is underway which is likely to include further measures on the energy and banking sectors. 

Companies, including non-EU operators, should be mindful of the further expansion of EU sanctions. EU operators should ensure they perform targeted and up-to-date EU-specific risk assessments. The last version of the European Commission FAQs is 28 April 2025.

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