EU adopts 17th sanctions package against Russia; makes new designations relating to other regimes
4 min read
On 20 May 2025, the EU adopted its 17th package of sanctions against Russia since its invasion of Ukraine in 2022. The package expands the products included in the export ban on advanced technology items, subjects more entities to tighter export controls, and added more vessels to the list of "shadow fleet" which are banned from EU ports. The package adds 58 individuals and 17 entities to the EU's asset freeze list. On the same day, the EU adopted additional asset freeze measures under its sanctions regimes targeting the use of chemical weapons, the alleged human rights situation in Russia, and Russian so-called "hybrid threats".
Export ban on advanced technology items expanded
The EU has expanded the product scope in relation to the export ban on advanced technology items by adding chemicals such as boron and sodium chlorates, as well as certain machinery parts such as needle roller bearings, ball or roller screws and certain instruments for measuring and checking geometrical quantities (which to some extent were already subject to an export ban under other sanctions provisions).1
Additional entities are subject to stricter export controls for dual-use or advanced technology
The list of parties targeted by stricter export controls on listed dual-use or advanced technology items increases to 31 additional entities linked to the Russian military industrial complex in this package. These additions include companies from Serbia, Türkiye, UAE, Uzbekistan and Vietnam. The Chinese entity Qisda Optronics (Suzhou) was removed from this list.2
Additions to tackle the "Shadow Fleet"
The list of "shadow fleet" vessels banned from EU ports (and subject to other restrictions) was expanded significantly with the addition of 189 new vessels.3
Asset Freeze additions
The EU has designated 58 more entities and 17 more individuals. Among the newly listed entities are the Russian companies Insurance Joint Stock Company "VSK", PJSC Surgutneftegaz and Petropavlovsk PLC, as well as certain companies based in China, UAE, Türkiye and Israel.4
The EU has also recently made certain amendments to the substantive provisions of the asset freeze regulation in this regime. The changes to the substantive EU asset freeze provisions in relation to Russia (i) introduces a new designation criterion in relation to certain parties that have participated in or enabled transfers of ownership, control or economic benefit of the business interests of sanctioned Russia-related businesspersons and thereby significantly frustrated the sanctions (with no such listings to date), and (ii) clarifies the burden of proof for maintaining designated Russia-related businesspersons on the EU asset freeze list even after they may have transferred their relevant business interests.5
Summary of key changes to other EU sanctions regimes targeting Russia adopted around 20 May 2025:
Hybrid Threats Regime
The EU imposes sanctions in response to alleged destabilising actions by Russia (not just in relation to the EU, but also "hybrid activities" involving cyber-attacks, information manipulation, etc. against international organisations and third countries) under the so-called Hybrid Threats regime.6
The EU also added to the EU asset freeze list of six entities active in the media, internet and maritime sectors and 22 individuals.7
The EU has made substantive changes to the regime entered into force on 21 May 2025. The substantive changes to the regime include the introduction of new transaction bans (in relation to listed tangible assets and non-EU crypto-asset services providers, not yet designated), a new broadcasting and content distribution ban (against listed operators, not yet designated), and a widening of the criteria for asset freeze designation.8
Chemical Weapons Regime
The EU has added to the EU asset freeze list three Russian Armed Forces entities alleged to be involved in the development and use of chemical weapons under the Chemical Weapons regime.9 The three entities were added as of 20 May 2025.10
Human Rights Regime
Under the EU sanctions regime established to address alleged human rights violations in Russia, the EU has designated 28 new individuals on the EU asset freeze list. The newly listed individuals are mainly engaged in judiciary, investigative and prosecutorial services in Russia.11
Kate Malone (Trainee, Brussels) and Ruth Benbow (Knowledge Manager, London) contributed to the development of this publication.
1 Revised Annex VII of Regulation 833/2014 as amended by Regulation 2025/932.
2 Revised Annex IV to Regulation 833/2014 as amended by Regulation 2025/932.
3 Revised Annex XLII to Regulation 833/2014 as amended by Regulation 2025/932.
4 Regulation 269/2014 as amended by Implementing Regulation 2025/933.
5 New Articles 3(1)(m) and 3(1b) of Regulation 269/2014 as amended by Regulation 2025/903, which entered into force on 15 May 2025.
6 See Regulation 2024/2642.
7 Revised Annex I of Regulation 2024/2642 as amended by Regulation 2025/965 and Regulation 2025/968.
8 Regulation (EU) 2024/2642 as amended by Regulation 2025/964.
9 See Regulation 2018/1542.
10 Revised Annex I of Regulation 2018/1542 as amended by Regulation 2025/959.
11 Regulation 2018/1542 as amended by Regulation 2025/958.
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