We inform you that on 20 May 2025, the European Union adopted the seventeenth package of sanctions against Russia.
Among the various new features that emerge from the new sanctions package, we would like to point out the following.
OBJECTIVE RESTRICTIONS
The new EU Regulation 2025/932 has introduced some changes to the list of restricted products set out in Annex VII, the so-called quasi-dual products, the sale, transfer and export of which are prohibited operations in Russia.
In particular, some goods have been added to the list and an extension to 28 June 2026 of the exemption provided for by art. 3 quindecies of Reg. 833/2014 has been provided. Therefore, sea transport to Japan and technical assistance, intermediation and financial activities with regard to the transport of crude oil from the Sakhalin-2 project located in Russia are permitted.
SUBJECTIVE RESTRICTIONS
The seventeenth package includes 75 additional listings: 17 natural persons and 58 entities, responsible for actions that undermine the territorial integrity, sovereignty and independence of Ukraine.
The measures applied include asset freezing, a ban on making financial resources available to them, and, in the case of natural persons, a travel ban. The new listings mainly concern Russia’s military and defense sectors, as well as entities active in the plundering of cultural heritage and others who operated in the occupied territories.
ANTI-EVASION MEASURES
The EU has listed 189 ships that are part of the “shadow fleet” and contribute to Russia’s energy revenues, for a total of 342 vessels, now subject to a ban on accessing ports and providing services.
For this reason, exporting Russian oil has become a complex and costly operation for the Kremlin, recording a 76% decrease.
Finally, these measures lead to a significant reduction in Russia’s ability to obtain revenues from oil price evasion, including through the identification of 31 companies involved in sanctions evasion practices (now listed). The package adds 31 new companies to the list that provide direct or indirect support to the Russian military industrial complex or are involved in sanctions evasion practices. Among them are 18 companies established in Russia and 13 companies established in third countries (6 in Türkiye, 3 in Vietnam, 2 in the United Arab Emirates, 1 in Serbia and 1 in Uzbekistan).
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In order to export goods and products in compliance with the EU regulations as last amended, we remind you that it is not sufficient to simply consult the annexes of the European Regulations or other blacklists, but it is considered necessary to carry out a limited and specific due diligence activity, both objective and subjective.
For this reason, the professionals of our firm, who offer assistance in matters of export control and international sanctions, remain available for any clarification and further information.
