On May 20, 2025, the European Union (EU) adopted the 17th sanctions package against Russia. It consists of the following regulations, each dated May 20, 2025:

• Regulation (EU) 2025/932 amending the Russia Embargo Regulation (EU) No. 833/2014 (“REG 833/2014”);  

• Regulation (EU) 2025/964 amending Regulation (EU) 2024/2642 (“REG 2024/2642”);  

• Implementing Regulation (EU) 2025/933 implementing the Russia Sanctions Regulation (EU) No. 269/2014 (“REG 269/2014”);  

• Implementing Regulation (EU) 2025/958 implementing Regulation (EU) 2024/1485 (“REG 2024/1485”); and

• Implementing Regulation (EU) 2025/965 implementing REG 2024/2642.

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The EU’s sanctions against Belarus laid down in Regulation (EC) No. 765/2006 and the sanctions laid down in Regulations (EU) No. 692/2014 and (EU) No. 2022/263 regarding Russian-occupied parts of Ukraine were not amended.

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We sum up the main amendments contained in the 17th sanctions package:

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Extension of personal restrictions

Further natural and legal persons, entities and bodies (“PEB”) have been listed. As a result, the assets of the newly listed PEB are frozen and neither funds nor economic resources may be made available to them.  

Implementing Regulation (EU) 2025/933 added 17 natural persons and 28 entities to the list of PEB in Annex I of REG 269/2014. In particular, these are persons and entities that are active in the Russian military and defense industry and belong to the military-industrial complex.

Furthermore, a further 27 natural persons were added to the list of PEB in Annex IV of REG 2024/1485. These are judicial officials in Russian courts and prosecutor’s offices who were or are involved in various capacities in the state prosecution and conviction of the politician Alexei Navalny and other persons.

In addition, further 21 natural persons and a total of six legal persons, entities and bodies were added to the list of PEB in Annex I of REG 2024/2642. The listed PEB are primarily held responsible for disinformation campaigns and destabilization measures abroad, in particular by spreading misinformation or providing technical assistance for this.

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Extension of the list of vessels of the so-called “shadow fleet”

The EU is once again focusing on Russia’s so-called “shadow fleet”, which is used to circumvent the existing oil price cap. A further 189 vessels were listed in Annex XLII of REG 833/2014, meaning that a total of 342 vessels are now listed here.

The listing does not result in the freezing of assets or a prohibition to provide funds or economic resources to these vessels. Instead, the sectoral restrictions pursuant to Art. 3s (1) REG 833/2014 apply. Among other things, these ships may not call at ports, anchorage zones and locks in the territory of the EU, they may not be imported into or exported from the EU, purchased, sold or chartered out, no financing and financial assistance, including insurance, may be made available to them and no typical vessel services such as ship broking services, bunkering, ship supply services, crew changes services, cargo loading and discharge services, fendering and tug services may be provided to them.

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Further restrictions on trading in Advanced Technologies

Goods listed in Annex VII of REG 833/2014 may not be sold, supplied, transferred or exported, either directly or indirectly, to PEB in Russia or for use in Russia (Art. 2a (1) REG 833/2014). The transit of these goods through Russia is also prohibited (Art. 2a (1a) REG 833/2014) and bans of related services apply (Art. 2a (2) REG 833/2014). In addition, it is prohibited to sell, supply, transfer or export goods listed in Annex VII (as well as goods listed in Annex I of the Dual-Use Regulation (EU) 2021/821) to PEB listed in Annex IV of REG 833/2014 and to provide related technical assistance or financial assistance, even if the goods are not intended for use in Russia in the concrete case (Art. 2b (1), (1a) REG 833/2014).

Further 31 companies have now been listed in Annex IV to REG 833/2014. The newly listed companies once again include non-Russian companies, namely companies from Turkey (six new entries), Vietnam (three new entries), the United Arab Emirates (two new entries) as well as Uzbekistan and Serbia (one new entry each). It should be emphasized that the Chinese company Qisda Optronics (Suzhou) Co. Ltd., which had filed a complaint against its listing on February 26, 2025 (Case No. T-139/25), has been removed from the list. This means that a total of 790 companies is now listed in Annex IV of REG 833/2014.

In addition, Annex VII Part B of REG 833/2014 was expanded to include goods of CN subheadings 2804 5010, 2829 1100, 2829 1900, 7603 1000, 7603 2000, 8104 3000, 8482 4000, 8483 4030, 8484 9000 and 9031 8020 as well as goods of HS subheading 8482 91.

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New transaction bans

The newly inserted Art. 1a (1) REG 2024/2642 prohibits engaging, directly or indirectly, in any transaction relating to or involving any tangible asset as listed in Annex III of REG 2024/2642. Annex III of REG 2024/2642 currently does not have any entries. Assets such as vessels, aircraft, real estate, ports, airports and physical elements of digital and communication networks may be listed here in the future.

In addition, it is now prohibited to engage, directly or indirectly, in any transaction with PEB listed in Annex IV to REG 2024/2642. This Annex is currently empty, too. It may be filled with (i) legal persons, entities or bodies established outside the EU that are 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 PEB engaged in destabilizing activities (Art. 1b (1) (a) REG 2024/2642; note that the reference to Annex IV is missing in the German version); and (ii) legal persons, entities or bodies providing technical or operational assistance to PEB engaged in destabilizing activities (Art. 1b (1) (b) REG 2024/2642).

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Exemption for the Sakhalin-2 project

The previously existing exemption for the Sakhalin-2 project from the prohibitions under Article 3n (1) and (4) REG 833/2014 was extended until June 28, 2026. Therefore, for the time being, it remains possible to transport by vessel to Japan crude oil of HS subheading 2709 00 commingled with condensate, originating in the Sakhalin-2 project (Сакакин-2), and to provide technical assistance, brokering services, financing and financial assistance in connection with such transportation.

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Further measures in the media sector

With the newly inserted Art. 1c REG 2024/2624, further restrictions in the media sector were adopted, but these remain of no practical significance for the time being because the relevant Annex V of REG 2024/2624 has no entries.

As soon as legal persons, entities or bodies are listed in Annex V of REG 2024/2624, the ban on broadcasting their content or enabling, facilitating or otherwise contributing to such broadcasting will apply (Art. 1c (1) REG 2024/2624). In addition, the ban on advertising products or services in any content produced or broadcast by the legal persons, entities or bodies listed in Annex V of REG 2024/2642 will apply (Art. 1b (3) REG 2024/2642).