Law Messenger

Overview of the 17th package of EU sanctions

26.05.2025

On 20 May 2025, the EU Council adopted the 17th package of sanctions[1] against Russia. The new measures are primarily aimed at the activities of the so-called "shadow fleet" used to transport Russian oil. In particular, 189 vessels have been added to the list of ships banned from entering the ports of EU member states. In addition, a new EU Regulation has been adopted to counter Russia’s destabilizing actions abroad.

See below for more details.

BLOCKING SANCTIONS: INDIVIDUALS AND LEGAL ENTITIES

As part of the 17^th package of EU sanctions, restrictions have been imposed against Russian and some foreign individuals and legal entities[2].

The updated list in the Annex to Decision 2014/145/CFSP includes 17 individuals and 58 organizations. Among the individuals are senior executives of KAMAZ PJSC, TSNII Electron JSC, Space Instrumentation Research Institute JSC, UEC-Saturn PJSC, UAP Gidravlika JSC, State Grain Operator State Unitary Enterprise, Aerofrigat LLC, and Center for Integrated Unmanned Solutions LLC. Among the legal entities are Surgutneftegaz PJSC, NIISSU JSC, Novosibirsk Instrument-Making Plant JSC, UAP Gidravlika JSC, State Grain Operator State Unitary Enterprise, and Center for Integrated Unmanned Solutions LLC. The Sevastopol Historical and Archaeological Museum-Reserve "Tauric Chersonesos", as well as its director Elena Morozova, have also been added to the sanctions list.

Also targeted by the sanctions are companies from China (Dalian Machine Tool Group, Shandong Ou Rui Laser Technology, Wuhan Skywalker Technology), the Republic of Belarus (Minsk Wheel Tractor Plant OJSC) and Israel (Texel F.C.G. Technology), which supply production equipment and components to Russia that can be used, for example, for the production of drones. The Israeli company was included on the grounds of circumventing the EU sanctions regime in connection with the supply of European electronics allegedly used to make weapons.

It is also worth mentioning the use of the ground introduced in the 16th package for inclusion in the sanctions list (ownership, operation and support of ships carrying Russian oil products). On that ground, sanctions have been imposed on Volga Shipping Company JSC, VSK JSC and several foreign companies from Turkey, Hong Kong and the UAE – for example, Eiger Shipping DMCC (UAE), which is the Dubai shipping division of the Russian oil trader Litasco (a Lukoil entity).

Adjustments have been made to the grounds for inclusion in the sanctions lists[3]. Sanctioned businessmen claiming to have withdrawn from Russian businesses after 24 February 2022 will continue to be listed unless they provide convincing evidence of loss of control over assets and lack of ties with the Russian authorities. Such evidence includes documents relating to the sale of assets and termination of control and public statements condemning the actions of the Russian authorities. These changes were prompted by recent cases in which the European Court of Justice annulled sanctions due to insufficient evidence from the EU. Now, the burden of proof has been shifted to the sanctioned individuals, which complicates the appeal process.

Furthermore, sanctions may also now be extended to persons who provided advice and other support in connection with the withdrawal of top businessmen from Russian assets.

SECTORAL SANCTIONS

The EU has updated the list of vessels in Annex XVI to Decision 2014/512/CFSP to include a further 189 vessels that are part of the "shadow fleet" of oil tankers or contribute to Russia's energy revenues, bringing the total number of listed vessels to 342[4][5].

The vessels were identified jointly with Member States and the European Maritime Safety Agency (EMSA). They are now subject to a ban on entering ports and a ban on services being provided to them.

The 17^th package includes an extension of the exemption from the oil price cap for Japanese customers of the Sakhalin-project 2 for one year until 28 June 2026[6]. The exemption allows the transportation of crude oil and condensate produced under the Sakhalin-2 project in Russia by ships to Japan, and the provision of technical assistance, brokerage services, and financing related to such transportation.

The package further expands the list of dual-use goods and advanced technologies subject to export restrictions, and in particular those intended for military use[7], such as:

chemical precursors for energy materials (sodium chlorate, potassium chlorate, aluminum powder, magnesium powder and boron powder)
spare parts and components of high-precision computer numerical control (CNC) machines. Although the machines are already largely covered by the sanctions already in place, spare parts such as ball screws and encoders have been added to the package.

31 names have been added to the list of individuals and entities set out in Annex IV to Decision 2014/512/CFSP[8]. The annex contains a list of entities from industry and the military-industrial complex that should be subject to stricter export restrictions on the supply of dual-use and military goods. The update includes 18 companies established in Russia, 6 in Turkey, 3 in Vietnam, 2 in the UAE, 1 in Serbia and 1 in Uzbekistan.

SANCTIONS CLARIFICATIONS

On 28 April, the European Commission published a new update to the "Consolidated Version of Frequently Asked Questions" on the application of Council Regulations No. 833/2014 and No. 269/2014. Although the clarifications contained in the document are not legally binding, they reflect the EU's approaches to the application of sanctions and serve as a guide for enforcement[9]. Clarifications regarding the provision of notarial services in the EU are important for companies from all industries. Notarial services of EU notaries which fall under the legal services ban include the certification of contracts, signatures and factual circumstances, i.e. activities involving the preparation, execution and verification of legal documents, where such services are provided to Russian legal entities or the Russian state and are not covered by applicable exceptions, are prohibited. However, the ban does not apply to cases where a notary acts independently, without representing the interests of the parties, and does not provide legal assistance – for example, when certifying a real estate purchase and sale transaction without providing additional legal support. In addition, the ban on the provision of legal services does not apply to the services of translators in the course of notarial procedures.

OTHER SANCTIONS RESTRICTIONS

Quite a lot of restrictions are introduced under the new EU Regulation 2024/2642 on measures to counter Russia's destabilizing influence abroad.

Under this program, sanctions can now be imposed on tangible assets, which are defined as identifiable movable and immovable property associated with destabilizing activities, including vessels, aircraft, real estate, ports and airports, and physical elements of digital and communication networks.

EU legal entities and individuals will be prohibited from directly or indirectly participating in any transactions involving such assets. So far, the list of such assets is empty.

A ban is imposed on European persons entering into transactions and establishing relations with financial institutions and crypto providers from third countries if they are involved in transactions that directly or indirectly support the activities of persons and entities included in Annex IV to the new Regulation 2024/2642 on measures to counter the destabilizing influence of Russia abroad[10].

The list in Annex IV is currently empty, but it may include entities that provide technical or operational support to the above individuals and entities.

The sanctions list may include media outlets, legal entities and organizations from any country that disseminate or facilitate the dissemination of content if they are involved in a systematic, international campaign of information manipulation and distortion of facts.

Restrictions on such entities include:

the suspension of broadcasting licenses in EU countries,
a ban on the distribution and advertising of content in any format (broadcast, online, print and digital channels),
a ban on the conclusion of content distribution agreements in the EU.

As in the case of other new sanctions instruments under the anti-destabilization program, the list of such entities is currently empty.