The EU's 17th sanctions package focuses on military industries and cutting off Russian revenues

Below, we highlight the main additions forming the latest EU restrictive measures targeting Russian interests as adopted on 20 May 2025 and entering into force no later than today (21 May 2025).

Military industry, dual-use, and hybrid threats

The EU's latest sanctions and reasoning are as follows:

• More than 45 Russian companies and individuals have been listed on the basis of trade with drones, weapons, ammunition, military equipment, critical components, and logistical support for the benefit of Russia.

• Six Chinese companies have been listed for either providing high-tech machine tools or supplying critical components (including for drones) for the benefit of Russia.

• Non-Russian entities in both Belarus and Israel have been listed on the basis of suspected sanctions circumvention in the supply of products intended for the Russian military.

• 31 new entities have been added and will be subject to tighter export control restrictions. In a dual-use-related context, this includes references to entities in countries such as Serbia, the UAE, Türkiye/Turkey, Vietnam, and Uzbekistan.

• 75 persons (legal and natural) have been added to the asset freeze lists and the prohibition against making funds available to them.

• Additional products and technologies have been included for Article 2a(1) which prohibits the sale, supply, transfer or export, directly or indirectly, of goods and technology which might contribute to Russia's military and technological enhancement, or the development of the defence and security sector, as listed in Annex VII. Authorisations may be granted by authorities on a case-by-case basis under Article 2b.

The hybrid threats regime has also been expanded with 27 new listings, whilst listings have simultaneously been made on the basis of chemicals and exports of goods which contribute to Russia’s military and technological enhancement and similar measures.

Shadow fleet

189 shadow fleet vessels have been added to the sanctions list, including 183 oil tankers, mainly due to the risk of circumvention of existing sanctions. The new listings also include a major Russian oil company, an insurance provider providing insurance for the Russian energy sector, as well as a Russian shipping firm.

In line with earlier sanctions packages, the EU has once again ramped up its efforts not only directly targeting Russian interests, but also indirect connections: Such shadow fleet-related entities are registered in the UAE, Türkiye/Turkey, and Hong Kong, making due diligence efforts ever-more relevant for EU operators.

The focus on shadow fleets is by no means an unfamiliar sight under EU sanctions: The Russian maritime sector has long been targeted and was originally hit by EU sanctions in June 2024 as part of the 14th sanctions package restricting access to EU ports and imposing widespread sanctions across the sector. This has only intensified in number and scope since then.

The importance of internal compliance programmes

As the sanctions landscape becomes increasingly complex in volume and scope, Danish businesses directly or indirectly involved with high-risk countries and geographies should have in place adequate ICPs (internal compliance programmes). The same applies for Danish businesses conducting transactions involving goods or technologies subject to export controls or sanctions, or businesses otherwise at risk from a regulatory perspective. 

Although ICPs cannot follow a one-size approach in terms of how they are drafted, the European Commission has issued a set of interpretative guidelines highlighting the recommended steps and procedures forming part of such an ICP, see Commission Recommendation (EU) 2021/1700 of 15 September 2021.

The very existence of an ICP is often a prerequisite for operating in several sectors and industries, including military and national defence/security, and should be drafted and implemented with the specificities of the business in mind.

In light of the 17th sanctions package, Danish businesses should take the opportunity to assess – or revise – their existing measures to ensure that their ICPs will stand up to regulatory scrutiny and support international trade.

Want to know more?

Our legal experts are closely monitoring developments in sanctions and are available to assist with any questions you may have.

The new main EU sanctions package can be accessed here in multiple language versions. Please note that the various measures described in this insight have been adopted with reference to multiple different regulations, see here.

The press release regarding the EU sanctions package can be accessed here.