17th EU sanctions package
On 20 May 2025, legal acts formalising the 17th package of EU restrictive measures (sanctions) were published:- Council Regulation (EU) 2025/932 amending Regulation (EU) No. 833/2014 (“Regulation No. 932” and “Regulation No. 833,” respectively).
- Council Implementing Regulation (EU) 2025/933 implementing Regulation (EU) No. 269/2014 (“Regulation No. 933”);
- Council Implementing Regulation (EU) 2025/958 implementing Regulation (EU) No. 2024/1485 (“Regulation No. 958”);
- Council Implementing Regulation (EU) 2025/959 implementing Regulation (EU) No. 2018/1542 (“Regulation No. 959”);
- Council Regulation (EU) 2025/964 amending Regulation (EU) No. 2024/2642 (“Regulation No. 964” and “Regulation No. 2642,” respectively).
- Council Implementing Regulation (EU) 2025/965 implementing Regulation (EU) No. 2642 (“Regulation No. 965”).
Introduction of blocking sanctions on tangible assets
Regulation No. 2642, adopted on 8 October 2024, introduced new grounds for EU blocking sanctions against Russian persons involved in so-called “destabilising activities,” which we covered previously in more detail.The EU has expanded the scope of this Regulation by creating a new list of sanctions targets, which will include tangible assets to be blocked, rather than individuals or legal entities.
Thus, a new Article 1a has been added to Regulation No. 2642, prohibiting EU PersonsThe EU sanctions measures are binding:
- within the EU territory;
- on EU nationals regardless of their location;
- on EU-registered legal entities and their branches and representative offices;
- on any persons within the EU territory, regardless of their nationality; and
- on board any aircraft or vessel under the jurisdiction of a Member State
As at the date of this legal update, the Annex does not contain any designations. However, it is anticipated that it will subsequently include tangible assets which:
- are used in activities of a destabilising character that:
- endanger or damage critical infrastructure, including submarine infrastructure, and that are attributable to or benefitting the Government of the Russian Federation;
- violate national, European or international air, marine or land traffic regulations, and that are attributable to or benefitting the Government of the Russian Federation;
- include espionage and surveillance, the transport of weapons or military equipment and personnel, information manipulation and interference, and that are attributable to or benefiting the Government of the Russian Federation;
- are owned, chartered or operated by natural or legal persons, entities or bodies listed in Annex I to Regulation No. 2642, or otherwise used in the name of, on behalf of, in relation with, or for the benefit of, such persons.
New ground for the imposition of EU “secondary” sanctions
Regulation No. 2642 was also supplemented by a new Article 1b, which provides an example of the extraterritorial application of the EU sanctions regime by allowing for the possibility of imposing restrictive measures on third-country persons.Thus, Article 1b prohibits EU Persons from engaging, directly or indirectly, in any transaction with:
- a legal person, entity or body established outside the European Union that is a credit or financial institution or an entity providing crypto assets services, involved in transactions that facilitate, directly or indirectly, activities by or otherwise supporting persons, entities or bodies, as listed in Annex I to Regulation No. 2642 (persons subject to blocking sanctions for “destabilising activities”); and
- a legal person, entity or body providing technical or operational assistance to natural or legal persons, entities or bodies, as listed in Annex I to Regulation No. 2642.
Therefore, the EU has provided a new ground for imposing sanctions on financial institutions and crypto-service providers established outside the EU (i.e. in Russia and other third countries) for engaging in transactions with persons sanctioned for “destabilising activities.”
Sanctions targeting media outlets
New Article 1c of Regulation No. 2642 introduces a prohibition on EU Persons from engaging in the following activities with legal persons, entities or bodies that are involved in “a systematic, international campaign of media manipulation and distortion of facts in order to enhance its destabilising strategy against the Union” and are listed in Annex V to this Regulation (“Specifically-Designated Media Outlets”):- to broadcast or to enable, facilitate or otherwise contribute to broadcasting, any content by Specifically-Designated Media Outlets, including through transmission or distribution by any means, such as cable, satellite, IP-TV, internet service providers, internet video-sharing platforms or applications, whether new or pre-installed; and
- to advertise products or services in any content produced or broadcast by Specifically-Designated Media Outlets, including through transmission or distribution by any of the means referred to above.
As at the date of this legal update, Annex V to Regulation No. 2642 does not yet contain any designations either.
EU blocking sanctions
The list of EU blocking sanctions has been expanded by imposing restrictions on, among others:- 17 individuals and 58 legal entities (including from China, Turkey and the UAE), including Surgutneftegas PJSC, Insurance Joint Stock Company VSK, Volga Shipping JSC, Atlas Mining LLC, the CEO of Kamaz PJSC S. A. Kogogin (under Regulation No. 933);
- 28 individuals, including Russian judges, prosecutors and investigators (under Regulation No. 958); and
- 21 individuals and six legal entities, including war correspondents, politicians, Voice of Europe, Murmansk Seafood (under Regulation No. 965).
As a reminder, EU blocking sanctions have the following consequences:
- EU Persons are required to block (freeze) funds and economic resources owned, held or controlled by sanctioned persons; and
- EU Persons are prohibited from directly or indirectly making funds and economic resources available to or for the benefit of sanctioned persons.
Amendments to Regulation No. 833
Regulation No. 932 amended certain Annexes of Regulation No. 833, in particular:- 189 vessels have been added to the list of vessels of the so-called “shadow fleet” of Russia in Annex XLII, which are subject to prohibitions on access to ports and on the provision of a wide range of services related to maritime transportation. Currently this list already contains 342 vessels;
- 31 new persons from Russia, Belarus, UAE, Turkey, Serbia, Vietnam and Uzbekistan have been added to Annex IVThis Annex lists natural or legal persons, entities or bodies which are military end-users, form part of Russia’s military and industrial complex or which have commercial or other links with or which otherwise support Russia’s defence and security sector.. EU persons are prohibited from directly or indirectly selling, supplying, transferring or exporting to these persons goods and technology, including dual-use goods and technology listed in Annex VIIThis Annex lists goods and technology that could contribute to Russia’s military and technological enhancement or to the development of Russia’s defence and security sector.;
- new items have, in turn, been added to Annex VII, including certain energy materials and chemical precursors, as well as machinery parts, assemblies and components; and
- the exemption from the ban on a number of services related to the transportation of Russian oil and compliance with the oil price cap was extended for the Sakhalin-2 project until 28 June 2026.
Expansion of the UK sanctions list
The UK announced sanctions against 20 individuals, 62 legal entities and 18 vessels linked to the Russian military-industrial complex, energy trade, financial and information sectors.The blocking sanctions have been imposed on, among others:
- 18 vessels of the so-called “shadow fleet.” This measure follows the imposition of sanctions on 100 other vessels announced earlier by the UK on 9 May 2025;
- 50 legal entities from the Russian financial sector, including the St. Petersburg Currency Exchange, Non-bank Credit Organisation Joint-Stock Company Petersburg Settlement Center (JSC PSC), State Corporation Deposit Insurance Agency, and a number of registrars and depositories (including Specialised Depository Infinitum JSC, Independent Registrar R.O.S.T Company JSC, VTB Registrar JSC, VTB Specialised Depository JSC, New Registrar JSC, etc.);
- 12 individuals and legal entities involved in supporting the Russian defence sector; and
- two individuals and legal entities involved in the Russian energy sector, including John Michael Ormerod, a British national who allegedly purchased vessels for the Russian “shadow fleet.”
- to freeze (block) assets of sanctioned persons: funds, securities, movable and immovable property, etc.; and
- to refrain from making funds or economic resources available, directly or indirectly, to or for the benefit of sanctioned persons (in the absence of prior authorisation in the form of a licence).
As at the date of this legal update, the UK has issued two new general licences in connection with the abovementioned sanctions restrictions.
- General Licence No. INT/2025/6279615 authorises making or processing insurance premiums payable to the Deposit Insurance Agency. This licence is perpetual; and
- General Licence No. INT/2025/6275812B authorises winding down from any transactions with the St Petersburg Currency Exchange and NCO JSC Petersburg Settlement Center, including the closing out of any positions. This licence is valid until 19 June 2025.
