A brief overview of the scope of the 17th sanctions package. Several regulations add, in particular, further listings of persons, companies, and the shadow fleet.
As announced, a further, the 17th, European sanctions package against Russia was published on 20 May 2025, this time jointly with the British. Although the scope of the embargo was, in part, mocked as mere “mini-sanctions” by the Handelsblatt on 20 May 2025, it nonetheless means considerable additional work for you in terms of immediate review and implementation.
Dr Ulrich Möllenhoff is offering support in this regard with a workshop on the Russia embargo on 2 June 2025, from 10:00 a.m. to 12:00 p.m. Feel free to register here.
Until the workshop, you will find below a list of the changes:
Regulation (EU) 2025/932 adds a further 31 natural or legal persons, organisations, or entities to Annex IV of Regulation (EU) No 833/2014, namely persons who are military end users, who belong to Russia’s military-industrial complex, or who maintain commercial or other connections with Russia’s defence and security sector, or who otherwise support it. Once again, supporters based outside Russia, in Hong Kong, Vietnam, Dubai, Uzbekistan, or Kazakhstan, have also been listed.
In addition, the list of goods in Annex VII to Regulation (EU) No 833/2014, covering goods that could contribute to the military and technological strengthening of Russia or to the development of its defence and security sector, has been extended to include goods that Russia has used in its war of aggression against Ukraine, as well as goods that contribute to the development or production of its military systems, including chemical precursors for energetic materials and spare parts for machine tools.
The shadow fleet list in Annex XLII to Regulation (EU) No 833/2014 has been extended by almost 200 vessels, in order to prevent the transport of Russian oil and Russian oil products.
Regulations (EU) 2025/964 and (EU) 2025/965 extend Regulation (EU) 2024/2642, which addresses restrictive measures in response to Russia’s destabilising activities. Transactions involving tangible assets that support destabilising activities originating from Russia, such as ships, aircraft, real estate, ports, airports, as well as physical elements of digital and communications networks, are now caught by prohibition provisions. Further measures are also being taken to prevent media manipulation and the falsification of facts aimed at destabilising the EU and its member states. The lists in the relevant annexes have been extended for this purpose as well.
Regulation (EU) 2024/1485 has likewise been extended, by Regulation (EU) 2025/958, to list further persons. A further addition to the list of companies also took place in connection with Regulation (EU) 2018/1542, aimed at preventing the proliferation of chemical weapons, by way of Regulation (EU) 2025/959.
With regard to Belarus as well, the extension of the embargo under Regulation (EU) No 269/2014 concerns additional listings of persons and institutions, made by Regulation (EU) 2025/933.
For you, this means, above all, once again carrying out a screening of the newly listed persons, organisations, and companies against your existing and future contracts, as well as a review of the goods lists in the area of machine tools and spare parts.
The 18th sanctions package has already been announced.
