The EU Council has adopted its 15th sanctions package against Russia, a significant step in the EU’s ongoing efforts to address Russia’s actions in Ukraine and its attempts to circumvent international sanctions.
The focus of this package is to keep cracking down on Russia’s shadow fleet, as well as combating sanctions’ circumvention. It also includes substantial individual and entity listings related to the Russian military-industrial complex and increases the legal protection of EU Central Securities Depositories (EU CSDs). With this package, the EU has, for the first time, imposed ‘fully-fledged’ sanctions (travel ban, asset freeze and prohibition to make economic resources available) on various Chinese actors.
Anti-circumvention measures
As Russia continues to seek ways to evade the Oil Price Cap, the EU is determined to strengthen measures to prevent such evasion. This package targets 52 new vessels from Russia’s shadow fleet, bringing the total number of such listings to 79.
These non-EU vessels are subject to a port access ban and a ban on the provision of services. They have been found engaged in high-risk shipping practices, such as transporting Russian oil, petroleum products, arms deliveries, grain theft, or supporting the Russian energy sector.
This EU approach increases the cost for Russia to use these vessels, reducing the fleet’s capacity to carry Russian crude oil. The listings also address the maritime safety and environmental risks posed by the often outdated and underinsured vessels in the shadow fleet.
The EU will continue to monitor Russian oil trade and efforts to circumvent the oil price cap, focusing on compliance by G7 operators and operations of the shadow fleet.
Additional listings
This package includes 84 additional listings, including 54 individuals and 30 entities, responsible for actions undermining Ukraine’s territorial integrity, sovereignty, and independence.
These individuals and entities are now subject to asset freezes, and individuals also face travel bans. The listings primarily target Russian military companies involved in manufacturing aircraft parts, drones, electronics, and other military equipment.
The sanctions also focus on senior managers in Russian energy companies, including shipping firms, that provide key revenues to the Russian government. Furthermore, the EU has sanctioned the military unit responsible for attacking the Okhmadyt children’s hospital in Kyiv and those involved in child deportation and propaganda.
For the first time since Russia’s invasion, the EU has imposed fully-fledged sanctions (including a travel ban, asset freeze, and prohibition on making funds available) on seven Chinese individuals and entities.
These include one individual and two entities facilitating the circumvention of EU sanctions, as well as four entities supplying sensitive drone components and microelectronics to Russia’s military.
The package also includes sanctions on two senior officials from North Korea, following discussions on third countries’ support for Russia’s war and the deployment of North Korean troops to Russia.
Trade
The sanctions package adds 32 new companies to the list of entities supporting Russia’s military-industrial complex in its war against Ukraine. These include 20 Russian firms, seven from China and Hong Kong, two from Serbia, and one each from Iran, India, and the UAE. Stricter export restrictions on dual-use goods and advanced technology will now apply to these companies.
Protecting the interests of EU operators
This package includes a prohibition on recognizing or enforcing certain rulings from Russian courts that grant exclusive competence to Russian courts in disputes between Russian and EU companies, regardless of prior agreements. This measure aims to protect EU companies from having damages illegally awarded against them in Russia. Additionally, the package extends existing derogations that provide more time for EU operators to divest from Russia.
Financial sector measures
To address the growing litigation and retaliatory measures in Russia that result in the seizure of assets of EU Central Securities Depositories (CSDs), the package introduces two key amendments:
- A loss recovery derogation, allowing CSDs to unfreeze cash balances and use them to meet legal obligations with their clients.
- A no-liability clause for EU CSDs, clarifying that they are not liable to pay interest or other forms of compensation to the Central Bank of Russia beyond interest contractually due.
