17th package of EU sanctions against Russia

Key takeaways

On 20 May 2025, the European Union adopted the 17th round of sanctions against Russia. According to the official press release issued by the Council of the EU, the measures aim at “cutting off Russia’s access to key military technology and curbing Russia’s energy revenues that fuel its war of aggression against Ukraine”.   

The new package comprises amendments to the EU Chemical Weapons regime (Council Regulation (EU) 2018/1542) and to three separate Russia-related EU sanctions regimes:

• Sanctions implemented in response to Russia's “violation of Ukrainian sovereignty and territorial integrity” (Council Regulation (EU) 269/2014 and (EU) 833/2014);
• Sanctions implemented in response to Russia’s “hybrid threats” and “destabilising activities”, such as malicious cyber activity and disinformation campaigns (Council Regulation (EU) 2024/2642); and
• Sanctions implemented in respect of Russia’s “internal repression” (Council Regulation (EU) 2024/1485).

The key amendments to these regimes are summarised below.

 

Russia-Ukraine regime (Council Regulations (EU) 269/2014 and 833/2014)

New asset freeze measures

Council Regulation (EU) 2025/933 amends Council Regulation (EU) 269/2014 to impose asset freeze measures on an additional 17 individuals and 58 entities. These new listings notably include vessels in the Russian shadow fleet, entities in the military and defence sectors, a major Russian oil company and persons involved in the looting of Ukrainian cultural heritage.

Some of these designations target entities and individuals located in third countries, such as Belarus, China, the UK, the UAE, Israel or Türkiye.

New and amended designation criteria

Council Regulation (EU) 2025/903 of 13 May 2025 amends Council Regulation (EU) 269/2014 to introduce a new designation criterion. Asset freeze measures may now be imposed on any persons “that have participated in or enabled transfers of ownership, control or economic benefit of the business interests of leading businesspersons” who are targeted by EU sanctions.

The same Regulation also introduces an amendment permitting asset freeze measures to be maintained against such “leading businesspersons” who claim to have transferred the ownership, control or economic benefit justifying their designation (unless the transfer is sufficiently supported by reliable information).

Expansions to lists of restricted end-users, Annex VII items and prohibited vessels

Council Regulation (EU) 2025/932 amends Council Regulation 833/2014 to:

• Add 31 new entities to the list of persons to whom dual-use and critical industry goods and technologies (ie Annex VII items) may not be transferred because they “are military end-users, form part of Russia’s military and industrial complex [or] have commercial or other links with, [or] otherwise support[,] Russia’s defence and security sector”. The newly added entities are from Russia, Serbia, Vietnam, Turkiye or Uzbekistan and appear to have been added due to their involvement of trade diversion of defence and security items to Russia.
• Expand the list of critical industry goods and technologies subject to export and transfer restrictions, as listed in Annex VII. The newly added items include, for example, chemical precursors used as propellants in missiles by the Russian military, and spare parts and components of high-precision machine tools.
• Expand the list of vessels subject to a ban on entering EU ports and receiving related services, as listed in Annex XLII. The newly added 189 vessels are claimed to be part of the so-called Russian shadow fleet.

 

Russia hybrid threats regime (Council Regulation (EU) 2024/2642)

New asset freeze measures

Council Regulation (EU) 2025/965 amends Council Regulation (EU) 2024/2642 to impose asset freeze measures on an additional 27 individuals and entities. These persons have been added for their alleged involvement in destabilising activities, including propaganda efforts, espionage operations, and sabotage of critical infrastructure or electronic warfare.

The newly listed persons include entities based in Russia as well as in other countries such as the UK, Czech Republic, and Türkiye.

Amended designation criteria

Council Regulation (EU) 2025/964 amends Council Regulation (EU) 2024/2642 to broaden the scope of permitted designation criteria. 

These changes are implemented by way of tweaks to the previous criteria. For example to allow that both physical and non-physical violence can now qualify as action meriting designation (if done to silence, intimidate etc critics of the Russian Federation), or to specify that persons may be designated if they are “involved in” such violence even if they are not “responsible for” it.

New list-based sanctions targeting “tangible assets”  

In a noteworthy development, Council Regulation (EU) 2025/964 amends Council Regulation (EU) 2024/2642 to introduce a new type of list-based sanctions prohibiting any transactions “relating to or involving” specific “tangible assets”, which will be listed in Annex III.

No “tangible assets” are currently listed in Annex III. However, the sanctions regulations specify that such assets may include “vessels, aircraft, real estate, ports, airports, and physical elements of digital and communication networks”.

This type of sanctions are a novelty in the EU sanctions architecture, as they enable the EU to target specific assets deemed to be “used in” particular types of “activities of a destabilising character” attributable to or benefiting the Russian Federation, as well as assets “owned, chartered or operated” or “otherwise used in the name of, on behalf of, in relation with, or for the benefit of” persons targeted by asset freeze measures.

New ban on transactions with listed persons supporting destabilising activity

Council Regulation (EU) 2025/964 also amends Council Regulation (EU) 2024/2642 to introduce a new ban on transactions with persons that (broadly) engage in destabilising or hybrid threat activity (as specified in Article 2(3) of Regulation 2024/2642 and including, by way of example, activity such as sabotage, election interference and violent demonstrations). 

Specifically, the transaction ban extends to:

• Non-EU credit institutions, financial institutions and crypto-asset service providers that facilitate or support persons engaged in destabilising or hybrid threat activity; and
• Any person providing technical or operational assistance to persons engaged in such activity.

Such persons, when identified, will be listed in Annex IV. No persons are currently listed.

Broadcast ban

Council Regulation (EU) 2025/964 amends Council Regulation (EU) 2024/2642 to introduce a new prohibition on broadcasting content, and (broadly) enabling the broadcast of content by, entering broadcast distribution arrangements with and/or advertising for, specified persons, to be listed in Annex V.

No persons are currently listed in Annex V.

 

Russia internal repression regime and Chemical Weapons regime

New asset freeze measures

Council Regulation (EU) 2025/958 amends Council Regulation (EU) 2024/1485 to add 28 individuals to the list of asset freeze targets for their alleged involvement in the persecution and prosecution of opposition leaders and activists, as members of the Russian judiciary.

Council Regulation (EU) 2025/959 amends Council Regulation (EU) 2018/1542 to add three entities to the list of asset freeze targets, all of which are believed to be connected to the Russian Defence Ministry and have been allegedly involved in the use of riot control agents in Ukraine.