On May 20, 2025, the European Union (EU) adopted its 17th sanctions package against Russia. It consists of the following regulations, all dated May 20, 2025: Regulation (EU) 2025/932 amending Regulation (EU) No 833/2014 (“Regulation 833/2014”); Regulation (EU) 2025/964 amending Regulation (EU) 2024/2642 (“Regulation 2024/2642”); Implementing Regulation (EU) 2025/933 implementing Regulation (EU) No 269/2014 on sanctions against Russia (“Regulation 269/2014”); Implementing Regulation (EU) 2025/958 implementing Regulation (EU) 2024/1485 (“Regulation 2024/1485”); and Implementing Regulation (EU) 2025/965 implementing Regulation 2024/2642. The EU 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 relating to Russian-occupied territories of Ukraine were not initially tightened. The following are the main changes under the 17th Sanctions Package: Extension of personal restrictions: Further natural and legal persons were added. Persons, organizations and entities (“POEs”) are listed whose assets are frozen and to whom no funds or economic resources may be made available (so-called “prohibition of provision”). Implementing Regulation (EU) 2025/933 expanded the list of POEs in Annex I to Regulation 269/2014 by 17 natural persons and 28 entities. These are primarily persons and entities active in the Russian military and defense industry and belonging to the military-industrial complex. Furthermore, the list of POE in Annex IV to Regulation 2024/1485 was also expanded by 27 natural persons. These are judicial officials in Russian courts and prosecutors' offices who were or are involved in various capacities in the state prosecution and conviction of politician Alexei Navalny and other individuals. Furthermore, the list of POE (Persons of External Action) listed in Annex I of Regulation 2024/2642 has been expanded by 21 natural persons and a total of six legal persons, organizations and bodies. The listed persons are primarily held responsible for disinformation campaigns and destabilization measures abroad, in particular through the dissemination of misinformation or the provision of technical support for such activities. Expansion of the list of ships of the so-called "shadow fleet" The EU is once again focusing on Russia's so-called "shadow fleet," which is allegedly used to circumvent the existing oil price cap. A further 189 ships were listed in Annex XLII of Regulation (EC) No 833/2014, bringing the total number of listed ships to 342. This listing does not result in a comprehensive freezing order or prohibition on making these ships available for use. Instead, the sectoral restrictions pursuant to Article 3s(1) of Regulation (EC) No 833/2014 apply. Among other things, these vessels may not enter ports, anchorage zones, or locks within the territory of the Union; they may not be imported into or exported from the Union, acquired, sold, or chartered; they may not be provided with any financial resources or assistance, including insurance; and they may not be provided with any ship-related services such as ship brokerage, bunkering, ship replenishment, crew changes, cargo loading and unloading, fendering, or towing services. Further restrictions on trade in Advanced Technologies: Goods listed in Annex VII of Regulation (EC) No 833/2014 may not be sold, supplied, transferred, or exported, directly or indirectly, to or for use in Russia by POE (Article 2a(1) of Regulation (EC) No 833/2014). The transit of these goods through Russia is also prohibited (Article 2a(1a) of Regulation (EU) No 833/2014), and prohibitions on the provision of services apply (Article 2a(2) of Regulation (EU) No 833/2014). Furthermore, 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 POE listed in Annex IV of Regulation (EU) No 833/2014, and to provide related technical or financial assistance, even if the goods are not intended for use in Russia in the specific case (Article 2b(1) and (1a) of Regulation (EU) No 833/2014). Annex IV has now been supplemented by 31 additional companies. Among the newly listed companies are again non-Russian companies, namely those from Turkey (six new entries), Vietnam (three new entries), the United Arab Emirates (two new entries), and Uzbekistan and Serbia (one new entry each). It is worth noting that the Chinese company Qisda Optronics (Suzhou) Co. Ltd., which filed a lawsuit against its listing on February 26, 2025 (Case T-139/25), has been removed from the list. This brings the total number of companies listed in Annex IV of Regulation (EC) No 833/2014 to 790. Furthermore, Annex VII, Part B of Regulation (EC) No 833/2014 has been extended 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. New Transaction Prohibitions: The newly inserted Article Article 1a(1) of Regulation (EU) 2024/2642 prohibits direct or indirect transactions relating to or concerning the tangible assets listed in Annex III of Regulation (EU) 2024/2642. Annex III of Regulation (EU) 2024/2642 is currently empty. Assets such as ships, aircraft, real estate, ports, airports, and physical elements of digital and communications networks may be listed there in the future. Furthermore, it is now prohibited to directly or indirectly conduct transactions with physical entities (POE) listed in Annex IV of Regulation (EU) 2024/2642. This annex is also currently empty. It is intended for (i) legal persons, organizations or bodies established outside the EU which are credit or financial institutions or bodies providing crypto services and which are involved in transactions which directly or indirectly facilitate or otherwise support the activities of POE involved in destabilizing acts (Art. 1b para. 1 lit. a) Regulation 2024/2642; the reference to Annex IV is missing in the German language version in this respect); and (ii) legal persons, organizations or bodies providing technical or operational assistance to POE involved in destabilizing activities (Article 1b(1)(b) of Regulation 2024/2642).

Exemption for the Sakhalin-2 Project

The existing exemption for the Sakhalin-2 Project from the prohibitions under Article 3n(1) and (4) of Regulation 833/2014 has been extended until 28 June 2026. This means that, for the time being, it remains possible to transport crude oil of HS subheading 270900 with condensate originating from the Sakhalin-2 (Сакакин-2) project to Japan by ship, and to provide technical assistance, brokerage services, financing, and financial aid in connection with such transport. Further measures in the media sector: The newly inserted Article 1c of Regulation 2024/2624 introduced further restrictions in the media sector, but these will initially have no practical significance because the relevant Annex V of Regulation 2024/2624 has not yet been populated. Once legal persons, organizations, or bodies are included in Annex V of Regulation 2024/2624, the prohibition will apply on broadcasting their content or enabling, facilitating, or otherwise contributing to such broadcasting. (Article 1c(1) of Regulation 2024/2624). Furthermore, the prohibition will then apply on advertising products or services in content produced or broadcast by the legal persons, organizations or bodies listed in Annex V to Regulation 2024/2642 (Article 1b(3) of Regulation 2024/2642).