EU adopts its 17th sanctions package against Russia

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On 20 May 2025, the EU adopted the 17^th package of economic and individual restrictive measures against the Russian Federation.

The measures were adopted through (i) Council Regulation (EU) 2025/932 of 20 May 2025 amending Regulation (EU) 833/2014; (ii) Council Implementing Regulation (EU) 2025/933 of 20 May 2025 implementing Regulation (EU) 269/2014; (iii) Council Regulation (EU) 2025/964 of 20 May 2025 amending Regulation (EU) 2024/2642; (iv) Council Implementing Regulation (EU) 2025/965 of 20 May 2025 implementing Regulation (EU) 2024/2642; (v) Council Implementing Regulation (EU) 2025/959 of 20 May 2025 implementing Regulation (EU) 2018/1542; and (vi) Council Implementing Regulation (EU) 2025/958 of 20 May 2025 implementing Regulation (EU) 2024/1485.

Outlined below are the main elements of the latest package.

New designations

A total of 75 new listings, which comprise 17 individuals and 58 entities, have been introduced in Annex I to Regulation (EU) 269/2014. The newly adopted listings predominantly target entities and individuals operating within the Russian military and defense sectors.

These designations are grounded in recently established listing criteria under the 16^th package (criteria “k”), including those pertaining to facilitators of the so-called “shadow fleet.” The new listings of entities based in Russia as well as in the United Arab Emirates, Türkiye, and Hong Kong are the first examples of designations under criteria “k.”

In addition, the listings encompass a key Russian shipping company, Joint Stock Company Volga Shipping, and a major Russian oil company, PJSC Surgutneftegaz, on the basis of their roles in the generation of state revenue. The scope of the designations further extends to include actors allegedly involved in the unlawful appropriation of cultural heritage.

The number of persons and entities subject to EU asset freeze measures pursuant to Regulation (EU) 269/2014 is now over 2,400.

Moreover, the newly introduced provisions have led to the imposition of asset-freezing measures under different regulations, including the following designations:

• of 3 entities linked to the Ministry of Defense of the Russian Federation in Annex I of Regulation (EU) 2018/1542 against the proliferation and use of chemical weapons;
• of 28 new individuals in Annex IV to Regulation (EU) 2024/1485 addressing the human rights situation in Russia; as well as
• of 21 new individuals and 6 entities (including two German nationals, one Russian-Estonian dual national, two Moldovan nationals, a Cameroonian national, a Togolese national and a British company) in Annex I to Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia's destabilizing activities.

Russian shadow fleet

Among the persisting priorities there is anti-circumvention, with dedicated outreach to third countries and the establishment of common lists of high-priority sanctioned goods.

As outlined above, a central focus of the package is the intensification of action against Russia’s so-called “shadow fleet” of oil tankers: the EU added 189 vessels to the list of vessels set out in Annex XLII to Regulation (EU) 833/2014, which are subject to port access bans and prohibitions on the provision of a wide range of maritime transport related services.

The 17^th package brings the total list of vessels subject to such restrictions to 342. Of note, EU imposed restrictions inter alia against three vessels owned by Japanese Mitsui which exported oil from the Arctic-LNG project.

These restrictive measures, coordinated with EU Member States and the European Maritime Safety Agency (EMSA), aim to dismantle the operational capacity of the fleet and, thereby, to curb Russia’s energy revenues.

Energy sector

The oil price cap exemption contemplated in Regulation (EU) 833/2014 for the Sakhalin‑2 project, which is extremely relevant for Japan’s energy security, has been extended until 28 June 2026.

Whilst there have been discussions on reducing the oil price cap, it was not reduced in the 17^th package.

Trade measures reinforcing defense sanctions

The package also imposes extensive new restrictions targeting Russia’s military and industrial base.

Among the amendments introduced to Regulation (EU) 833/2014, 31 additional entities have been inserted in Annex IV, containing the list of those subject to enhanced restrictions on the export of dual-use and advanced goods and technologies (as listed in Annex VII), including items essential for drone production and high-precision machine tools. Notably, this list includes entities from Russia, as well as from third countries such as China (including state-owned enterprises), Belarus, Israel, Serbia, Türkiye, Vietnam, the UAE, and Uzbekistan. These third-country actors have been identified as facilitating the circumvention of existing export controls or directly supplying the Russian military sector.

Specific new trade restrictions have also been added to Regulation (EU) 833/2014, targeting chemical precursors (such as sodium chlorate, potassium chlorate, aluminum powder, magnesium powder, and boron powder) which are linked to the manufacture of missile propellants, as well as components critical to the operation of Computer Numerical Control machine tools.

New sectoral measures against Russian hybrid threats

Regulation (EU) 2024/2642 adopted in response to Russia hybrid threats has been further amended through the introduction of additional provisions aimed at reinforcing this separate framework of restrictive measures.

In particular, the EU may now target tangible assets linked to Russia’s destabilizing activities. The EU has prohibited to engage, directly or indirectly, in transactions relating to tangible assets, such as vessels, aircraft, real estate, ports, airports, and physical components of digital and communication networks, as listed in Annex III, or concerning such assets. Such assets will need to be sufficiently identified/identifiable.

Moreover, the EU prohibited to conduct transactions with (i) credit or financial institutions or (ii) entities providing crypto assets services, which are established outside the European Union, as listed in Annex IV and which directly or indirectly facilitate Russia’s alleged destabilizing activities.

The EU prohibited the broadcasting of content originating from legal persons, entities, or bodies listed in Annex V. Broadcasting licenses of such persons and related contracts will be suspended. The listed persons will also be prohibited from distributing or circulating their content in the EU. The restriction also prohibits any form of contribution to such broadcasting activities, including facilitation.

However, as of the date of adoption, abovementioned Annexes III, IV and V remain empty, therefore requiring future designation of specific subjects and items within their respective scopes.

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The 17^th package is a further escalation in the EU’s sanctions against Russia, covering various sectors and spanning through various separate programs.