15th sanctions package: EU targets Putin's shadow fleet, circumvention and Chinese actors

On 16 December 2024, the EU adopted the 15th sanctions package against Russia. The package consists of Regulation (EU) 2024/3189, Regulation (EU) 2024/3183 and Regulation (EU) 2024/3192 which amend Regulation (EU) 269/2014 and Regulation (EU) 833/2014. The package is mainly designed to address the circumvention of EU sanctions already in place by targeting Russia's so-called "shadow fleet" and weakening the Russian military and industrial complex. It adds more persons and entities to the already existing sanctions list, and targets entities in Russia and in third countries that indirectly contribute to Russia’s military and technological enhancement, while also reinforcing protection of EU operators. Furthermore, for the first time, the Council decided to impose restrictive measures under its hybrid threats sanctions regime against 16 individuals and three entities responsible for Russia’s destabilising actions abroad.

The measures on asset freeze entered into force immediately upon publication in the Official Journal on 16 December 2024 while the sectoral sanctions adjustments entered into force on 17 December 2024.

Key takeaways

• The new EU sanctions package introduces several significant measures with a focus on combating circumvention, weakening Russia’s economy and protecting EU businesses.
• New measures are implemented specifically targeting the "shadow fleet."
• The package expands asset freeze measures by adding 84 new listings. This includes 54 individuals and 30 entities, with a notable inclusion of Chinese individuals and entities.
• To protect EU businesses, the new measures introduce a prohibition of the recognition or enforcement of rulings issued by Russian courts based on Article 248 of Russia’s Arbitration Procedure Code.

Individual sanctions listings – Sanctions against Chinese and North Korean actors

The package introduces 84 additional listings (i.e., 54 individuals and 30 entities)  held accountable for actions that compromise the territorial integrity, sovereignty, and independence of Ukraine. These actors are now subject to asset freeze measures and travel bans.

The individuals listings focus on senior managers in leading energy sector companies, as well as those responsible for the deportation of children, propaganda, and sanctions evasion. Among them are the Minister of Defence and the Deputy Chief of the General Staff of the Democratic People's Republic of Korea. Furthermore, the EU sanctions the military unit responsible for the attack on the Okhmadyt children's hospital in Kyiv.

As regards additional entities listings, the EU primarily targets military companies involved in producing aircraft parts, drones, electronics, engines, high-tech weapon components, and other military equipment. Also included are shipping companies responsible for transporting crude oil and oil products by sea, which generate significant revenue for the Russian government.

For the first time since the onset of Russia's invasion, the EU implements ‘fully-fledged listings' comprising a travel ban, asset freeze, and prohibition on making economic resources available—on seven Chinese individuals and entities. This includes one individual and two entities aiding in the circumvention of EU sanctions, along with four entities supplying drone components and microelectronics to support Russia's war against Ukraine.

Anti-circumvention measures

The package addresses Russia's efforts to bypass the Oil Price Cap by targeting 52 new vessels from Russia's shadow fleet, bringing the total number of such listings to 79. These ships have been identified as engaging in high-risk shipping practices, including the transportation of Russian oil or petroleum products, arms deliveries and grain theft, or are supporting the Russian energy sector.

They will be subject to a port access ban and it is prohibited to provide maritime transport services to these vessels.

Protection of EU importers

Another key feature of the new package is the safeguarding of EU importers' interests against litigation with Russian counterparts. The new Article 11c of Regulation (EU) No. 833/2014 prohibits the enforcement or recognition within the EU of rulings issued by Russian courts under Article 248 of the Arbitration Procedure Code of the Russian Federation.

These specific rulings previously granted exclusive mandatory jurisdiction to Russian courts in disputes between Russian and EU companies, irrespective of any prior agreements between the parties (anti-suit injunctions), and often resulted in disproportionately high financial penalties for European companies.

Divestment derogations

The Council has also extended the existing deadlines for certain derogations necessary for the divestment of EU operators from Russia, e.g in  Article 5aa(3)(d) and (3a) and Article 11(4) and Article 12b of Regulation (EU) No. 833/2014 until 31 December 2025. These extended derogations are granted on a case-by-case basis by Member States, focusing on facilitating an orderly divestment process.

Trade sanctions

The Annex IV list of Regulation (EU) 833/2014), designating actors directly supporting Russia's military and industrial sectors, has also been expanded by 32 new entities. These entities are subject to stricter export controls on dual-use goods and technologies, as well as on goods and technology that could enhance Russia's defence and security capabilities.

A number of these entities are based in third countries, including China, India, Iran, Serbia and the United Arab Emirates). They have been implicated in circumventing trade restrictions or procuring sensitive items for Russian military operations, such as unmanned aerial vehicles (UAVs) and missiles. 

Financial sanctions

In response to increasing litigation and retaliatory actions from Russia, which has been seizing the assets of EU Central Securities Depositories (CSDs), the new sanctions package includes two significant amendments: 

• A loss recovery derogation which allows for the release of cash balances held by EU CSDs These institutions can now request the competent authorities of Member States to unfreeze cash balances, enabling them to meet their legal obligations to their clients; and
• A no liability clause clarifying that EU CSDs are not liable to pay interest or any other form of compensation to the Central Bank of Russia, except for interest that is contractually due.

Hybrid threats

Following the establishment of the new framework targeting Russia's destabilising actions abroad, primarily through disinformation and other malicious operations (hybrid threats), for the first time, the Council listed 16 individuals and three entities linked to these activities. The listed persons are now subject to asset freezes, prohibitions to make funds available and travel bans. 

The sanctions focus on dismantling Russian disinformation networks in Africa and Europe, targeting digital campaigns, espionage activities, and collaborators linked to the Russian government, FSB, and GRU, such as GRU Unit 29155, Groupe Panafricain pour le Commerce et l’Investissement and African Initiative. 

Conclusions and what to expect for the near future

The latest package strengthens Europe's commitment to further curtail Russia's military capabilities by making it harder to circumvent EU sanctions and expanding the list of sanctioned entities and individuals, with a particular emphasis on China. EU importers and operators are granted additional time to divest, supported by the introduction of several protective measures related to litigation and Central Securities Depositories (CSDs).

This 15th sanctions package was adopted six months after the previous one in July 2024. The Commission is already preparing a 16th package of sanctions, as announced by the President of the Commission, Ursula Von der Leyen, at a plenary session of the European Parliament on 18 December 2024.