The 15th sanctions package against Russia has been adopted – Here's what you need to know

According to the official press release by the Council, the key takeaways from the new sanctions may be summarised as follows (including our comments as applicable):

• 52 vessels (ships) originating from third countries have been targeted, bringing the total of designated vessels to 79. This includes a port access ban and happens on the back end of a vast focus on shadow fleets transporting crude oil through European territorial waters, which has also been subject to much media coverage in Denmark. The ban also covers the provision of services related to maritime transports.

• In the context of dual-use goods and technologies, a total of 32 new entities have been added to the list of those suspected of directly supporting the military and industrial complex of Russia – many of these entities being active outside of Russia, such as in China, India, Iran, Serbia and the United Arab Emirates.

• The major shift in 2023 and 2024 regarding the political focus targeting circumvention and non-Russian parties added to the Russia Sanctions therefore continues. As a groundbreaking first, the newest package even imposes fully-fledged sanctions on various Chinese actors suspected of supplying drone components and microelectronic components in support of Russia – these measures consisting of travel bans, asset freezes, and prohibitions to make economic resources available, and therefore differing from existing measures restricting Chinese interests in terms of EU export controls.

• In an attempt to protect EU businesses in litigation proceedings with Russian counterparts, a potentially radical new measure seeks to prohibit the recognition or enforcement in the EU of those rulings issued by Russian courts based on Article 248 of the Arbitration Procedure Code of the Russian Federation. This measure – an anti-suit injunction – follows a number of various developments in 2024, including Russian countersanctions.

• A new derogation has been introduced allowing the release of cash balances held by EU central securities depositories (CSDs) such as Belgium's Euroclear, i.e., when handling Russia's immobilised central bank assets. Due to this, the CSDs will in principle be able to ask competent authorities of EU member states to unfreeze cash balances if necessary to meet legal obligations with their clients.

• The EU has decided to extend the deadlines for certain derogations necessary to ensure divestments from Russia (i.e., exits from the Russian market). It is expected that this not only affects existing business in Russia but could also likely deter EU companies from considering setting up new entities in Russia.

The findings above will ultimately be subject to the final wording of the text as soon as it is made available in the Official Journal of the EU. We follow developments closely as they occur.

For now, EU operators should see the above as a natural continuation of the existing, far-fledged sanctions on Russia, especially in light of the increased focus on combating sanctions circumvention (such as Article 12) and even the more broadly worded "best efforts" obligation (Article 8a) pertaining to a number of key points for EU businesses with activities outside of the EU. For more information on these topics, please see our separate news item on the recent Article 8a.

The new sanctions also come in the direct aftermath of the European Commission's issuance of various new FAQ guidelines on aspects such as best efforts (published on 22 November 2024) and due diligence requirements for EU operators (published on 11 December 2024). The FAQs contain important guidance on the interpretation of various Articles in (for instance) the Russia Sanctions – as a result, they are relevant to consider for all parties subject to EU sanctions compliance obligations.

Read the official press release from the European Council

Read the new FAQs on best efforts and on circumvention and due diligence