Russia Sanctions Tracker - EU (2024-25)

24 February 2025

EU's 16th package of restrictive measures

European Council press release and

European Commission press release

Council Regulation (EU) 2025/390 of 24 February 2025 amending Regulation (EU) No 269/2014

Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014

The EU has introduced its 16th package of sanctions against Russia, which includes the following key elements:

• Asset freeze listings: 83 additional listings, including 48 individuals and 35 entities, such as those supporting the Russian military complex, active in sanctions circumvention, Russian crypto assets exchanges and in the maritime sector. Addition of another criterion for listing individuals and entities that are part of Russia's military and industrial complex, support it, or benefit from it.
• Anti-circumvention measures: 74 additional vessels, bringing the total number of listed vessels to 153, linked to Russia's "shadow fleet" or contributing to Russia's energy revenues; new listing criterion, targeting those who support the operations of unsafe oil tankers.
• Export/import measures: targeted export restrictions on 53 new companies supporting Russia's military-industrial complex or engaged in sanctions circumvention; direct import ban on import of processed aluminium goods from Russia; dual use export restrictions covering dual-use chemical precursors, software related to Computer Numerical Control (CNC) machine tools used to manufacture weapons, and video-game controllers used by the Russian army to pilot drones on the battlefield and chromium ores and compounds.
• Energy measures: prohibition of the temporary storage or free zone processing of Russian crude oil and petroleum products in EU ports; prohibition to provide goods, technology, and services for completing Russian LNG and crude oil projects.
• Financial sector measures: additional listing of 13 financial institutions subject to the prohibition to provide specialised financial messaging services; additional listing of 3 banks subject to the transaction ban due to their use of the Financial Messaging System of the Central Bank of Russia (SPFS) system to circumvent EU sanctions; extension of transaction ban to enable the EU to list financial institutions and crypto asset providers that participate in the circumvention of the Oil Price Cap and facilitate transactions with listed vessels of the shadow fleet.
• Transport: extension of the flight ban to include third-country airlines operating domestic flights in Russia or supplying aviation goods, barring them from flying to the EU, and tightening of road transport rules by prohibiting Russian ownership above 25% in EU road transport companies to close sanction loopholes.
• Infrastructure: full transaction ban on key Russian airports (including Vnukovo and Zhukovsky), major seaports (Ust-Luga, Primorsk, Novorossiysk, Astrakhan, and Makhachkala), and prohibition EU operators from providing construction services in Russia.
• Measures against disinformation: Ban on 8 Russian media outlets for supporting and justifying Russia’s war against Ukraine.

27 January 2025 

Extension of existing measures against Russia for another 6 months

Press release

New listings in response to Russia’s hybrid threats

European Council press release

On 27 January 2025 the Council renewed the EU restrictive measures in view of the Russian Federation’s continuing actions destabilising the situation in Ukraine for a further 6 months, until 31 July 2025.

On 27 January 2025 the Council adopted additional restrictive measures against three Russian individuals responsible for a series of cyberattacks carried out against the Republic of Estonia in 2020. The individuals listed are officers of the General Staff of the Armed Forces of the Russian Federation (GRU) Unit 29155. The newly listed individuals are:

• Nikolay Alexandrovich KORCHAGIN
• Vitaly SHEVCHENKO
• Yuriy Fedorovich DENISOV
   

20 December 2024 

Updated FAQs - Restrictions on diamonds

The EU Commission has updated a Russia sanctions FAQ on the restrictions on diamonds. The main focus of the updates is on:

• the application and scope of the prohibition of Article 3p of Council Regulation 833/2014;
• the traceability-based verification and certification mechanism for rough diamonds;
• importing diamonds into the Union;
• the Kimberly Process (KP) certification;
• the requirements considered for importation of rough or polished natural diamonds between 1 March 2024 and 28 February 2025 ("sunrise period"); and
• stocks of diamonds (“grandfathering”).

See updated FAQs 2, 4, 6, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19.

The EU Commission has updated a Russia sanctions FAQs on the "no re-export to Russia" clause and "divestment from Russia" issues.

The updates on the "no re-export to Russia" clause include:

• Clarification of the meaning of "adequate remedies": in cases of breaches, "adequate remedy" can consist of e.g. (non-cumulative): termination of deliveries and suspension, interruption or termination of the contract, application of financial penalties, or the determination of a competent court able to recognise this re-export as contrary to the provisions set out in the contract.
• Clarification on public contract exemption: exemption in Art. 12g (2)a of Council Regulation 833/2014 applies for both existing and future contracts; clarification on the obligation to notify (scope and content).
• Clarification on form of the "no re-export to Russia" clause: e.g. operators can include "no re-export to Russia" clause into general clauses; clause can be incorporated into general terms and conditions (provided that they are validly incorporated into the contract between the exporter and counter party).
• Clarification on scope of the "no re-export to Russia" clause: no obligation to include the "no re-export to Russia" clause in intra-EU contracts; unilateral communication possible in existing contracts under certain circumstances in case of refusal of contractual counterparty to incorporate clause.

The update on the section "divestiture from Russia" explains why the exemptions in Art. 12b (1) and (2) of Council Regulation 833/2014 were introduced and what requirements need to be met for operators to request an authorisation to enable the sale, supply or transfer of goods and listed technologies.

EU's 15th package of restrictive measures

European Council press release and European Commission press release

First listings in response to Russia’s hybrid threats

European Council press release

The EU has introduced its 15th package of sanctions against Russia, which includes the following key elements:

• Asset freeze listings: new listings of 84 entities and individuals, including 54 persons and 30 entities undermining Ukraine’s territorial integrity; the additions to individual listings mainly target the military unit responsible for the striking of the Okhmadyt children hospital in Kyiv, senior managers in leading companies in the energy sector, individuals responsible for children deportation, propaganda and circumvention, as well as two senior DPRK officials; the additions to entity listings mainly target Russian defence and shipping companies transporting crude oil and oil products, a civil Russian airline ("PJSC UTAIR") providing logistical support to the military, a chemical plant (Federal State Enterprise “Kamensky ‘Combine’”) and Chinese suppliers of drone and microelectronic components aiding Russia's military.
• Anti-circumvention measures : extension of port access ban and a ban on provision of services to the so called "shadow fleet" (targeting 52 new vessels).
• Export measures: additional listing of 32 new entities (also located in third countries: China, India, Iran, Serbia and the United Arab Emirates) which are now subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector.
• Financial sector measures: mitigating increasing litigation and retaliatory measures in Russia that result in the seizing of assets of EU Central Securities Depositories (CSDs) by introducing a loss recovery derogation and a no liability clause for EU CSDs.
• Measures to protect interests of EU operators: prohibition to recognise or enforce in the EU some specific rulings issued by Russian courts that give exclusive mandatory competence to Russian courts in disputes between Russian and EU companies, regardless of the prior agreement of the parties; extension of existing derogations that enable EU operators to divest from Russia.

For the first time, the Council decided to impose restrictive measures against 16 individuals and three entities responsible for Russia’s destabilising actions abroad (hybrid threats). 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.

The measures impose asset freezes, prohibitions to make funds available and travel bans on the listed persons.

Updated FAQs – Circumvention and due diligence

New FAQs - enhanced due diligence for operators manufacturing and/or trading with common high priority (CHP) items

The EU Commission has updated the Russia sanctions FAQs on circumvention and due diligence and published new FAQs on enhanced due diligence obligations under Art. 12gb of the Regulation 833/2014 for operators manufacturing and/ or trading CHP items.

The updated FAQs 5, 6, 7, 9, and 10 on circumvention and due diligence primarily address the following issues:

• compliance obligations of banks processing trade-related payment: trade-related sanctions do not only target operators initiating the trade but also banks processing related payments. Banks should adopt a risk-based approach on establishing compliance mechanisms.

• clarification on the interpretation of the "anti-circumvention clauses" in the EU sanctions regimes: in the context of the prohibition to participate in activities to circumvent imposed sanctions, in accordance with the jurisprudence of the Court of Justice of the European Union, “knowingly and intentionally” is to be interpreted as not only deliberately seeking the object or effect of circumventing sanctions, but also participating in an activity having that object or effect, being aware that such participation may have that object or effect, and accepting that possibility.
• non-liability clause application and due diligence standard (Art. 10 (2) of the Regulation 269/2014 and Art. 10 of the Regulation 833/2014): non-liability cannot be invoked where the EU operator has failed to carry out appropriate due diligence. The standard of due diligence obligations generally depends on the individual risk exposure of the business operators activities; at minimum level it should include: proper processing of publicly or readily available information; screening of all parties to the transaction; control of the goods and services, including whether the goods – finished product or components – are subject to other control regulations (dual-use, military); comprehensive risk analysis of the transaction.

The new FAQs on enhanced due diligence obligations for operators handling CHP items under Art. 12gb of the Regulation 833/2014 primarily address the following issues:

• purpose and application of the provision: the provision responds to the issue of re-exportation of CHP items (FAQ 1); it applies to natural and legal persons, entities and bodies required to comply with EU sanctions as per Article 13 of Regulation that sell, supply, transfer or export CHP items (FAQ 2, - exceptions to application see FAQ 13).
• scope of due diligence requirements: generally, also here, a risk-based approach to due diligence efforts should be applied by business operators, however the Commission sets out recommendations for specific checks at different levels (on stakeholders’ level; on level of the transaction and flows of money, as well as transportation/logistics and route of goods) (FAQ 4) and identifies risk factors for re-exportation (FAQ 5); it further provides clarification on definitions and requirements regarding the scope of obligations established in Art. 12 gb (1)(a) and (b) of the Regulation (FAQ 6, 7, 9, 10, 11).
• enforcement of the provision: national competent authorities will carry out routine checks to verify whether EU operators are implementing this provision (FAQ 12).
• requirements in para. 3: the paragraph is to be read in conjunction with the "best effort clause" in Article 8a of the Regulation and therefore only comprises actions that are feasible for the EU operator in view of its nature, its size and the relevant factual circumstances, in particular the degree of effective control over the entity outside the EU.

The EU Commission has updated the Russia sanctions FAQs on the "best effort obligations" laid down in Article 8a of the Council Regulation 833/2014. In particular the FAQs explain:

• the definition and scope of "best efforts": The concept of "best efforts" involves all suitable and necessary actions to prevent the undermining of EU sanctions. These actions must be feasible for the EU operator, considering its nature, size, and the degree of effective control over the non-EU entity. On the basis of that, the EU operators must ensure awareness of the activities of non-EU entities they own or control as well as their risk of undermining EU sanctions. This could include implementing internal compliance programs, sharing corporate compliance standards, sending newsletters and sanctions advisories, setting up mandatory reporting and training to prevent sanctions violations as well as setting up procedures to rapidly react to sanctions violations (FAQ 1 and 5).
• the meaning of the concept of "undermining" and the difference to "circumvention": "Undermining" refers to activities that result in effects that the EU sanctions aim to prevent. This is separate from the concept of "circumventing," which refers to activities that have the aim or result of enabling the author to avoid the application of EU sanctions under the cover of formal appearance (FAQ 2).
• the standard of liability: If an EU operator is aware of and accepts activities by a non-EU entity that undermine EU sanctions, it constitutes a breach of Article 8a. Furthermore, protection against liability cannot be invoked where EU operators have failed to carry out proper due diligence to show awareness of the actions by an owned or controlled non-EU entity. Therefore, adopting feasible due diligence measures, ensuring awareness of the non-EU entity's activities, is crucial to avoid liability (FAQ 6).

Iran: Trade restrictions and asset freeze – new listings

European Council press release

Council Decision (CFSP) 2024/2894 of 18 November 2024

and

Council Regulation (EU) 2024/2897 of 18 November 2024

and

Council Implementing Regulation (EU) 2024/2896 of 18 November 2024 implementing Regulation (EU) 2023/1529

The EU Council has widened its restrictive measures against Iran due to its military support to Russia and armed groups in the Middle East and Red Sea, specifically targeting the use of vessels and ports for the transfer of Iranian-made UAVs, missiles, and related technologies. The Key provisions include:

Individual listings:

• Mohammad Reza KHIABANI
• Islamic Republic of Iran Shipping Lines (IRISL)
• Arapax LLC
• VTS Broker LLC
• MG Flot LLC

Trade restrictions:

• prohibition on the export, transfer, supply, or sale from the EU to Iran of components used in the development and production of missiles and UAVs;
• transaction ban prohibiting any transaction with ports and locks that are owned, operated or controlled by listed individuals and entities, or are used for the transfer of Iranian UAVs or missiles or related technology and components to Russia

The European Banking Authority (EBA) has published two sets of guidelines introducing a harmonized European standard for internal policies, procedures and controls that financial institutions should implement to comply with EU restrictive measures. The guidelines will apply from 30 December 2025.

The key takeaways are:

• First Set of Guidelines (EBA/GL/2024/14): Addresses all institutions within the EBA's supervisory remit, focusing on ensuring sound governance and risk management systems to pre-vent breaches or evasion of restrictive measures
• Second Set of Guidelines (EBA/GL/2024/15): Tailored for payment service providers (PSPs) and crypto-asset service providers (CASPs), detailing compliance requirements for transfers of funds or crypto-assets under restrictive measures

8 October 2024

The EU's new restrictive measures against those responsible for destabilising activities against the EU and its Member States

Press release

New framework for imposition of asset freezes, prohibitions to make funds available and travel bans.

Council Regulation (EU) 2024/2642 of 8 October 2024 concerning restrictive measures in view of Russia’s destabilizing activities

and

Council Decision (CFSP) 2024/2643 of 8 October 2024 concerning restrictive measures in view of Russia’s destabilising activities

In force from 10 October 2024

The Council of the EU has established a new framework and legal basis for restrictive measures against individuals and entities responsible for destabilising activities against the EU and its Member States.

The key provisions include:

• an asset freeze for all funds and economic resources belonging to, owned, held or controlled by entities and individuals listed in Annex I of the Regulation (see Article 2 of Council Regulation);
• the prohibition to make funds or economic resources available to or for the benefit of entities and individuals listed in Annex I of the Regulation (see Article 2 of Council Regulation);
• a travel ban on individuals listed in the Annex of the Council Decision (see Article 1 of Council Decision);

The framework sets out the criteria determining which persons and entities are to be listed; the criteria focus on actions that undermine or threaten democracy, the rule of law, stability, or security within the EU, its Member States, international organizations, or third countries. The key actions include:

• obstruction or undermining of democratic processes (especially undermining electoral processes);
• support for violent demonstrations and acts of violence;
• information manipulation and interference (especially the spread of disinformation);
• targeting democratic institutions and critical infrastructure (also through malicious cyber activities);
• instrumentalization of migrants;
• exploitation of armed conflicts and instability and
• instigating armed conflicts

13 September 2024

Notices to designated persons

The EU has published three notices for the attention of designated persons:

• Applications to use frozen resources: designated persons are able to (i) apply to a competent authority to use frozen funds or economic resources, (ii) apply to the Council for reconsideration of their designation, and (iii) challenge any decision by the Council before the General Court.
• Data protection: confirming the legal basis for the processing of data in respect of data subjects to whom the EU's Russia sanctions regulations apply.
• Reporting requirements: designated persons must comply with reporting requirements and cooperate with Member State competent authorities. Failure to do so will be considered circumvention of asset freeze measures.

Asset freeze – removals

The entries for five deceased persons and two other persons, as well as one duplicate entry, have been removed from the list of designated persons in the Annex to Regulation (EU) No 269/2014:

• Vladimir Albertovich LEBEDEV (deceased)
• Maria Vladimirovna PIROGOVA (deceased)
• Mikhail Valerievich ZHUKOV (deceased)
• Mikhail Vasilyevich GOLUBOVICH (deceased)
• Valeriy Alexandrovich VOSTROTIN (deceased)
• Violetta PRIGOZHINA (deleted)
• Nikita Dmitrievich MAZEPIN (deleted)
• Sergei Yuryevich KUZOVLEV (duplicate)

5 September 2024

Updated FAQs – Provision of Services

The EU Commission has updated a Russia sanctions FAQ on the provision of services. The FAQ clarifies that nationals of EU Member States are subject to the prohibition to provide services even if the services are provided a an employee of an EU mother company to a subsidiary in Russia (see FAQ 37).

Updated FAQs - Asset freeze and prohibition to make funds and economic resources available

The EU Commission has updated its Russia sanctions FAQs on asset freezes and prohibitions to make funds and economic resources available. In particular, the FAQs explain what a firewall is (see FAQ 42) and explain how aggregate ownership should be considered when determining whether an entity is owned by listed persons (FAQ 8).

5 August 2024 

Belarus: Asset Freeze

The EU Council has imposed restrictive measures against 28 individuals.

These individuals are subject to restrictive measures for their role in the ongoing internal repression and human rights violations in Belarus, including their support for the Lukashenka regime. Those sanctioned include of the Main Department for Combating Organised Crime and Corruption, the judiciary, the heads of various correctional institutions, members of the state press and regime propagandists.

26 July 2024

Updated FAQs – Import, Purchase and Transfer of Listed Goods

The EU Commission has updated its Russia sanctions FAQs on import, purchase and transfer of listed goods. In particular the FAQs explain what the newly introduced status of “partner countries for the importation of iron and steel” in Art. 3g(1)(d) means for the import and purchase of iron and steel products processed in third countries (FAQ 12).

Updated FAQs – Export-related restrictions for dual use goods and advanced technologies

The EU Commission has updated its Russia sanctions FAQs on export related restrictions for dual use goods and advanced technologies. In particular the FAQs list the partner countries (the U.S., Japan, the United Kingdom, South Korea, Australia, Canada, New Zealand, Norway, Switzerland, Liechtenstein and Iceland) to Council Regulation 833/2014 and detail the benefits they enjoy pursuant to the Regulation.

The EU Commission has also updated the Correlation Annex (Annex VII) which accompanies the Regulation.

24 July 2024

Updated FAQs – Central Securities Depositories

The EU Commission has updated its Russia sanctions FAQs on central securities depositaries. In particular the FAQs:

• outline the limitations on converting Depositary Receipts of Russian issuers into the underlying shares (FAQ 22) but explain that the derogation provided for in Article 6(b)5aa of Council Regulation (EU) No 269/2014 makes it possible to convert Depositary Receipts on the basis of an authorisation granted by the national competent authorities of the Member States after 25 December 2023 (FAQ 23);
• explain that, subject to certain conditions, the ‘free-of-payment’ transfer of a Russian security not targeted by sanctions between two counterparts with sub-accounts opened within the same financial institution or within the same central securities depository is not prohibited (FAQ 24);
• explain that, subject to certain conditions, the transfer or sale of depositary receipts with Russian underlying securities held with NSD on the secondary market is not prohibited (FAQ 25); and
• clarify that it is not possible for EU persons and entities to participate in an "asset swap" scheme that would be implemented within the framework of the Russian Presidential decree 844 (FAQ 26).

 Updated FAQs - Chemicals

The EU Commission has updated its Russia sanctions FAQs on chemicals. In particular FAQs 2, 3. 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 22, 23, 25 have been updated.
Please consult this document for details on each FAQ.

23 July 2024 

Renewal of EU economic sanctions

In view of Russia's continuing actions destabilising the situation in Ukraine, the Council decided to renew the restrictive measures for a further 6 months, until 31 January 2025.

15 July 2024

New FAQ – 'no export to Russia' clause

The EU Commission has launched a new set of FAQs on the 'no export to Russia clause' under Article 12g of Regulation 833/2014.

2 July 2024

Updated FAQs – Provision of Services

The EU Commission has updated its Russia sanctions FAQs on the Provision of Services. In particular the FAQs:

• clarify the application of the exemption under Article 5n(7) of Regulation 833/2014 (see FAQ 16, 17 and 18);
• explain that the prohibitions in Article 5n do restrict the possibility to provide services to Russian entities controlled by foreign companies which are not from the EU, EEA, Switzerland or one of the partner countries as listed in Annex VIII (see FAQ 19);
• explain how EU operators can request authorisation to provide "inter-group" services as per Article 5n(1)(h) (see FAQ 35).

Updated FAQs – Divestment from Russia

The EU Commission has updated its Russia sanctions FAQs on Divestment from Russia. In particular the FAQs explain why the derogations in Article 12b(1) and (2) of Council Regulation 833/2014 were introduced (see FAQ 1).

Updated FAQs – State-owned Enterprises

The EU Commission has updated its Russia sanctions FAQs on State-owned Enterprises. In particular the FAQs explain why the exemption in Article 5aa of Council Regulation 833/2014 cannot apply to Sovcomflot after its listing in Council Regulation 269/2014 (see FAQ 16).

Updated FAQs – General Questions

The EU Commission has updated its Russia sanctions General FAQs. In particular the FAQs explain that the prohibitions, derogations and exemptions in Council Regulation 269/2014 and Council Regulation 833/2014 operate independently and must be complied with as such (see FAQ 18 and FAQ 19).

New FAQs – Targeted Vessels

The EU Commission has launched a new set of FAQs on Targeted Vessels in relation to Article 3S of Council Regulation 833/2014.

The FAQ explains that a vessel, targeted in Annex XLII, laden with dangerous or polluting goods at the date of targeting, such as oil, can receive port access and services for a unique emergency port call for the offloading of the dangerous or polluting goods on board at the date of the targeting of the vessel within a reasonable time, and in any case not later than 30 days from the date of targeting.

EU's 14th package of restrictive measures

European Council press release (asset freeze) and press release (other measures).

European Commission press release and Q&A

 The EU has introduced its 14th package of sanctions against Russia, which includes the following:

• Asset freeze listings in respect of additional 69 individuals and 57 entities, including business persons, propagandists and public figures, members of the army and the judiciary, companies actively involved in circumventing EU sanctions, several Russian military and defence industry companies, companies providing vital dual-use technologies used in the battlefield and transporting weapons and military personnel, and several leading companies in the energy sector. Listed companies include Volga Dnepr Group and its subsidiaries, and Sovcomflot, Russia's largest shipping company.
• Energy-related measures targeting LNG, including prohibitions on providing goods, technology or services to LNG projects under construction in Russia; the transshipment of Russian LNG through EU ports; and the import of Russian LNG into specific terminals which are not connected to the EU gas pipeline network
• Anti-circumvention measures, including a best efforts obligation on EU companies concerning foreign subsidiaries; a requirement for a “No Russia” clause for Intellectual Property Rights transfers; and due diligence requirements for CHP (Common High priority List) goods.
• Financial sector measures, including a prohibition for EU banks outside Russia to connect and carry out transactions using the Financial Messaging System of the Central Bank of Russia (SPFS) and to engage with specified third-country banks which are using SPFS; and a prohibition on transactions with banks and crypto assets providers, in Russia and third countries, that facilitate transactions supporting Russia's defence-industrial base.
• Export measures, including an extension of the export restrictions on dual use/advanced technology items; a reinforcement of the current export bans on industrial goods focusing on four sectors which are key to Russia's war economy: chemicals, plastics, vehicles parts and machinery; and the addition of 61 Russian and third-country entities to the list of entities associated to Russia's military-industrial complex.
• Import measures, including an import ban on Russian helium; finetuning of the import ban on Russian diamonds; an extension of the Common High Priority (CHP) list; and a ban on importing stolen Ukrainian cultural items.
• Transport measures, including a new restrictions on flights, a tightening the existing prohibition to transport goods by road in the EU; and a prohibition on port access and services for listed vessels.
• Measures to protect EU operators, including the creation of a legal basis for compensation claims in Member States courts by EU operators for damage caused by Russian companies linked to sanctions; and a transaction ban to protect arbitration.
• Measures protecting intellectual property rights, comprising a prohibition on the acceptance, by EU and Member States' intellectual property offices and authorities, of applications for registration of, among others, new trademarks and patents requested by Russian persons and persons resident in Russia.
• Measures combatting Russian interference, comprising a prohibition on accepting financing from the Russian state and its proxies by political parties, NGOs and media service providers in the EU.
• Additional measures, including extending the prohibition on EU and Member States funding to all Russian entities.

For a detailed update on the 14th package please see our briefing: 14th sanctions package against Russia: anti-circumvention measures and LNG export ban. The relevant Council Regulations can be accessed at the following links:

• Implementing and amending Regulation 269/2014 – here and here; and
• Implementing and amending Regulation 833/2014 – here and here.

Asset freeze – new listing

(additions to Annex of Decision (CFSP) 2019/797)

Press release

The EU council has imposed restrictive measures against the following 6 individuals for their role in cyber attacks affecting information systems in EU member states:

• Ruslan Aleksandrovich Peretyatko
• Andrey Stanislavovich Korinets
• Oleksandr Skilanko
• Mykola Chernykh
• Mikhail Mikhailovich Tsarev
• Maksim Sergeevich Galochkin

The restrictions are made under the EU cyber sanctions regime but each of the 6 individuals are either or both a Russian national or a member of a hacker group backed by the Russian Federal Security Service (FSB).

 27 May 2024

Asset freeze – new listing

(additions to Annex of Decision 2014/145/CFSP)

Press release

 The EU Council has imposed restrictive measures against two individuals and one entity:

• Artem Pavlovich Marchevskyi;
• Viktor Volodymyrovych Medvedchuk; and
• Voice of Europe.

These individuals and entity have been added to the Annex of the Council Decision 2024/1508 for conducting propaganda actions targeted at civil society in the EU and its neighbouring countries, distorting and manipulating the facts in order to justify and support Russia's war of aggression against Ukraine.

27 May 2024

The EU's new package of restrictive measures against those responsible for human rights violations

Press release

Council Regulation (EU) 2024/1485 of 27 May 2024 concerning restrictive measures in view of the situation in Russia – new

In force from 27 May 2024

The EU Council has established an new framework for restrictive measures against those responsible for serious human rights  serious human rights violations or abuses, repression of civil society and democratic opposition, and undermining democracy and the rule of law in Russia.

The key provisions include:

• an asset freeze on entities and individuals listed in Annex IV of the Regulation (see Article 6 and articles 7 to 11);
• a travel ban on individuals listed in Annex IV of the Regulation;
• a prohibition on the sale, supply, transfer or export of, and the provision of technical assistance, brokering services, financing or financial assistance in relation to equipment which might be used for internal repression as listed in Annex I of the Regulation, to any individual or entity in Russia or for use in Russia (see Article 2);
• a prohibition on the sale, supply, transfer or export of equipment, and the provision of technical assistance, brokering services, financing or financial assistance in relation to technology or software listed in Annex II, to an entity or individual in Russia or for use in Russia (see Article 3 to 5);
• reporting requirements on individuals, entities and bodies to facilitate compliance with the Regulation (see Article 12); and
• a requirement that the Commission and Member States inform each other of the measures taken under the Regulation (see Article 16).

The Regulation contains the following Annexes:

• Annex I: List of equipment which might be used for internal repression as referred to in Article 2;
• Annex II: List of equipment, technology and software referred to in Article 3;
• Annex III: Websites for information on the competent authorities and address for notifications to the Commission; and
• Annex IV: List of natural and legal persons, entities and bodies referred to in Article 6.

Individuals or entities listed in Annex IV will be subject to an asset freeze. Those listed in Annex IV will include those who:

• are responsible for serious violations or abuses of human rights or the repression of civil society and democratic opposition, or whose activities otherwise seriously undermine democracy or the rule of law in Russia;
• provide financial, technical, or material support for, or are otherwise involved in, acts set out above, including by planning, directing, ordering, assisting, preparing, facilitating, or encouraging such acts; or
• associated with the natural or legal persons, entities or bodies referred to in either of the points above.

Asset freeze – new listings 

(additions to Annex IV Regulation 2024/1485) 

One entity and 19 individuals have been added to the EU's list of persons subject to an asset freeze. The 19 individuals are also subject to a travel ban.

These listings target those responsible for systematic abuses and ill-treatment of political prisoners in Russia, specifically in relation to the death of Alexei Navalny and the sentencing of Oleg Orlov and Alexandra Skochilenko. The new listings include:

• The Federal Penitentiary Service of the Russian federation;
• Nikolai Pavlovich Dubovik;
• Eduard Borisovich Erdyniev;
• Andrey Vladimirovich Fedorov;
• Ekaterina Vasilevna Fedotova (Naumova);
• Inna Alexandrovna Fesenko;
• Ekaterina Viktorovna Galyautdinova;
• Dmitry Evgenevich Pankratov;
• Evgeniy Borisovich Rastorguev;
• Alexander Sergeevich Ermolenko;
• Irina Geroldovna Kim;
• Kirill Sergeevich Nikiforov;
• Sergey Vladimirovich Blinov;
• Evgeny Vladimirovich Borisov;
• Tatyana Stanislavovna Dodonova;
• Elena Sergeevna Astakhova;
• Sergey Vorobyov;
• Ilya Andreevich Savchenko;
• Oksana Vasilyevna Demyasheva; and
• Alexander Yurievich Gladyshev.

 17 May 2024

Council Regulation (EU) 2024/1428 – Amendment to Regulation (EU) No 833/2014

Additions to Annex XV

Press release

The EU Council has suspended the broadcasting activities of four media outlets:

• Voice of Europe;
• RIA Novosti;
• Izvestija; and
• Rossiiskaja Gazeta.

These entities have been added to Annex XV of Regulation (EU) No 833/2014 by virtue of their role supporting and justifying the war in Ukraine.

 14 May 2024

Updated FAQs - Media

The EU Commission has updated its Russia sanctions FAQs on Media. In particular, the FAQs:

• explain the grounds on which the EU imposed restrictions on certain Russia media outlets (see FAQ 1);
• explain that journalists can report content created by targeted entities, without breaching the regulation, provided they act in good faith and are not motivated by the circumvention of sanctions (see FAQ 5);
• explain what freezing the "economic resources" of media outlets means (see FAQ 10); and
• clarify that displaying content, produced by those listed in Annex 1 to Regulation 269/2014, on online video sharing platforms and media streaming service providers, breaches the Regulation (see FAQ 11). 

 24 April 2024

Penalties for sanctions breaches: breach of EU sanctions added to the list of 'EU crimes'

Directive (EU) 2024/1226

European Parliament press release

European Council press release

The EU Council has adopted, and since published, an EU Directive which adds the violation and circumvention of EU sanctions to the list of 'EU crimes'.

The new Directive sets out definitions for the violations which are punishable as 'EU crimes'. These include not freezing funds, not adhering to travel bans or arms embargoes, transferring funds to designated persons, doing business with state owned entities of designated states, and providing financial services or legal advice in violation of sanctions. 

The new law introduces minimum rules for the enforcement of, and penalties relating to, the above sanctions violations in member states. The penalties include a maximum of five years imprisonment and dissuasive fines to be issued by national judges. 

The Directive will come into force on 15 May 2024. After this, member states have 12 months to transpose the EU Directive into their national legislation. 

18 April 2024

Updated FAQs - Oblasts

The EU Commission has updated its Russia sanctions FAQs on Oblasts. The FAQs explain how operators assess which areas in the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts are subject to restrictions (see FAQ 1), and the restrictions and conditions on banks processing financial transactions in connection with trade done in the Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts (see FAQ 4).

Updated FAQs – Import, Purchase and Transfer of Listed Goods

The EU Commission has updated its Russia sanctions FAQs on the Import, Purchase and Transfer of Listed Goods. In particular the FAQs explain what the newly introduced status of “partner countries for the importation of iron and steel” in Art. 3g(1)(d) means for the import and purchase of iron and steel products processed in third countries (see FAQ 12).

 12 April 2024

Updated FAQs – Reporting on Outgoing Transfers

The EU Commission has updated its Russia sanctions FAQs on reporting obligations surrounding transfers involving Russian-owned entities outside the EU.

In particular, the FAQs clarify the application and scope of Article 5r of EU Council Regulation 833/2014 (see FAQ 1, 2, 3, 4, 5, 8, 9 , 11, 13, 15 and 16).

The FAQs also explain the criteria for "indirect transfer of funds out of the EU" (see FAQ 6); the minimum threshold amount when cumulative operations are involved (see FAQ 7); the criteria to determine indirect ownership (see FAQ 10); and the information financial institutions utilise to identify a legal person, entity or body referred to in Article 5r paragraph 1 (see FAQ 12).

The FAQs announce the EU Commission has published a reporting template (see FAQ 14).

 25 March 2024

Updated FAQs – State owned enterprises

The EU Commission has updated its Russia sanctions FAQs on state owned enterprises, in particular in respect of providing insurance coverage to a vessel calling into a port owned by an entity listed in Annex XIX, and paying out an insurance claim for damage under the policy. – see FAQ 6 and FAQ 6a.

 22 March 2024

Asset freeze – additions

Global Sanctions Regime – restrictive measures against serious human rights violations and abuses

The EU Council have placed restrictive measures on 33 individuals and 2 entities linked to the imprisonment of the Russian opposition politician, Alexei Navalny.
These individuals and entities are now subject to an asset freeze and travel ban.

 12 March 2024

Asset freeze: extension of restrictive measures

Council Decision

Commission Regulation

Press release

The EU Council has decided to prolong the restrictive measures targeting those responsible for undermining or threatening the territorial integrity, sovereignty and independence of Ukraine for another six months, until 15 September 2024.

The EU Council also decided not to renew the listings of three individuals and remove nine deceased persons from the list, as follows:

• Dimitriy Valerievich Utkin
• Nikolay Ivanovich Bortsov
• Viktor Vladislavovich Subarev
• Anton Valerevich Kuprin
• Serguey Achotovich Mndoiants
• Oleg Nikolaevich Popov
• Arkady Yurievich Volozh
• Jozef Hambálek
• Gennadiy Valeryevich Zhidko
• Elena Osipovna Avdeeva
• Igor Vladimirovich Panchenko
• Oleg Yurievich Tsokov

 1 March 2024

Updated FAQs – Restrictions on Diamonds

The EU Commission has updated its Russia sanctions FAQs on restrictions on diamonds, in particular in respect of:

• whether the prohibition of Article 3p also applies to restricted goods that are already within the territory of the Union before entry into force of the relevant restrictive measures;
• the traceability-based verification and certification mechanism for rough diamonds;
• importing diamonds into the Union;
• the Kimberly Process (KP) certification; and
• the requirements considered for importation of rough or polished natural diamonds between 1 March 2024 and 31 August 2024 ("sunrise period").

These updates are in response to various countries expanding their restrictions on the import of Russian diamonds following the G7 statement last year – see FAQ 6, FAQ 8, FAQ 9, FAQ 10 and FAQ 12.

23 February 2024
EU's "13th package" of restrictive measures

EU Commission Press Release

European Council Press Release

Asset freeze: new listings

 An additional 106 individuals and 88 entities have been added to the EU's list of persons subject to an asset freeze.
The new listings target primarily the military and defence sectors and associated individuals, including those involved in DPRK armament supply to Russia, as well as members of the judiciary, local politicians and people responsible for the illegal deportation and military re-education of Ukrainian children.

Trade restrictions: goods which could contribute to the enhancement of Russian industrial capacities - amendment
(amendments to Article 3k)

A new exception has been added confirming that for CN codes 8504 10, 8504 21, 8504 22, 8504 23, 8504 31, 8504 40, 8504 50 and 8504 90, the existing prohibitions shall not apply to the execution until 25 May 2024 of contracts concluded before 24 February 2024.

Trade restrictions: entities supporting Russia's military/industrial complex – additions
(amendments to Annex IV)

 27 new entities were added to the list in Annex IV of those directly supporting Russia's military and industrial complex in its war of aggression against Ukraine. They will be subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia's defence and security sector.
In view of the key enabling role of electronic components, that list certain entities in third countries other than Russia which trade in such components (China, Kazakhstan, India, Serbia, Thailand, Sri Lanka, and Turkey), as well as certain Russian entities involved in the development, production and supply of electronic components for Russia’s military and industrial complex.

Trade restrictions: items which might contribute to Russia's military and technological enhancement or to the development of its defence and security sector – amendment
(amendments to Annex VII, Part B)

 The list of items (Annex VII, Part B) which are subject to existing export restrictions has been expanded to include: components used for the development and production of drones, such as electric transformers, static converters and inductors found inter alia in drones, as well as aluminium capacitors, which have military applications, such as in missiles and drones and in communication systems for aircrafts and vessels.

Trade restrictions: Russian iron and steel - amendment
(amendments to Annex XXXVI )

The list of partner countries referred to in Article 3g(1) has been updated to include Switzerland, Norway and the United Kingdom.

 23 February 2024

EU's "13th package" of restrictive measures 

EU Commission Press Release 

European Council Press Release

The EU has introduced its 13th package of sanctions, which includes the following:

• Additional asset freeze listings: The Council imposed restrictive measures on an additional 106 individuals and 88 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. The new listings target primarily the military and defence sectors and associated individuals, including those involved in DPRK armament supply to Russia, as well as members of the judiciary, local politicians and people responsible for the illegal deportation and military re-education of Ukrainian children.
• Import-export controls and restrictions: 
  • The Council added 27 new entities to the list of those directly supporting Russia’s military and industrial. They will be subject to tighter export restrictions concerning dual use goods and technologies. Some of these entities are located in third countries (India, Sri Lanka, China, Serbia, Kazakhstan, Thailand, and Türkiye) and have been involved in the circumvention of trade restrictions, others are Russian entities involved in the development, production and supply of electronic components for Russia’s military and industrial complex. 
  • The package also expands the list of restricted items that could contribute to the technological enhancement of Russia’s defence and security sector by adding components for the development and production of unmanned aerial vehicles (UAV). 
  • The EU has introduced further restrictions on exports of goods which contribute in particular to the enhancement of Russian industrial capabilities, such as electrical transformers.
• Iron and steel: The package adds the United Kingdom to a list of partner countries which apply a set of restrictive measures on imports of iron and steel from Russia, and a set of import control measures, that are substantially equivalent to those of the EU.

Further detail on the 13th package will be added to this tracker in due course. The relevant Council Regulations can be accessed here (amending Regulation 833/2014) and here (implementing Regulation 269/2014).

 12 February 2024

Financial restrictions: management of reserves and assets of the Central Bank of Russia - amendments

Press release

(amendment to Article 5A, Regulation 833/2014)

The existing prohibition on transactions related to the management of reserves as well as of assets of the Central Bank of Russia has been amended, as follows.

A new exception has been added to confirm that the existing prohibition does not apply to transactions carried out on or after 28 February 2022;

From 15 February 2024, central securities depositories holding assets and reserves for/on behalf of the Central Bank of Russia (incl. the Russian National Wealth Fund) with a total value exceeding EUR 1 million are required to apply the following rules regarding such cash balances:

• cash balances shall be accounted for separately;
• revenues accruing from such cash balances from 15 February 2024 shall be registered separately in financial accounts;
• net profits determined in respect of revenues referred to in the point above may not be disposed of by way of to the benefit of shareholders or any third party until the Council has approved a proposal for the possible use of such funds for the reconstruction of Ukraine;
• central securities depositories may apply to its supervisory authority to release any such funds if required under any statutory requirements.

Central securities depositories shall report to the Commission and to their national supervisory authorities, by 30 June of each year, on the total amount of such cash balances, revenues and net profits.

 6 February 2024

Updated FAQs – Software

The EU Commission has updated its Russia sanctions FAQs on software, in particular in respect of the prohibition of certain business-relevant services to the Russian government and the types of software covered by the prohibition in Art.5n(2b) – see FAQ 1, FAQ 2, FAQ 3 and FAQ 4. 

 26 January 2024

Updated FAQs – Public Procurement

The EU Commission has updated its Russia sanctions FAQs on public procurement, in particular in respect of ongoing contracts and new contracts and the relationship between Article 5k of Council Regulation (EU) 833/2014 and Article 2 of Council Regulation 269/2014 - see FAQ 11 and FAQ 49.

3 January 2024

Asset freeze: new listings

1 individual and 1 entity have been added to the EU's list of persons subject to an asset freeze. The new listings include:

• Pavel Alekseevich Marinychev, CEO of PJSC Alrosa.
• PJSC Alrosa, Russia's largest diamond producer which accounts for over 90% of all Russian diamond production.