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A 15th package of EU sanctions against Russia was formally adopted by the European Council on 16 December 2024. The package focuses on preventing the current circumvention of EU sanctions by Putin’s shadow fleet as well as on weakening the Russian military and industrial complex. Further sanctions are imposed through individual listings and adding further vessels to the list of those subject to a port access ban. Moreover, measures to protect EU companies against Russian litigations risks and penalties are introduced. In connection with an extension of the deadlines of applying for certain divestment licences, the Council of the EU states that because of the risks of maintaining business activities in Russia, EU operators should consider winding down business there or refraining from starting new business.
The new 15th sanctions package against Russia was adopted on 16 December 2024. Part of the measures are set out in the implementing Regulation, which can be found here.
In addition, new asset freeze and travel ban restrictions have been imposed on new individuals and entities from Belarus. The measures are set out in the implementing Regulation, which can be found here here.
Below, we have summarised some of the most significant changes:
The Council has added new 84 listings consisting of 54 individuals and 30 entities that are responsible for actions that are threatening or undermining Ukraine’s territorial integrity, sovereignty and independence.
The individuals include members of the military unit responsible for striking the Okhmadyt children hospital in Kyiv, senior managers in leading companies in the energy sector, individuals responsible for child deportation, propaganda and circumventions of the sanctions, as well as two senior North Korean officials.
The newly listed entities are mainly Russian defence companies and shipping companies involved in the transportation of crude oil and oil products as they provide important revenues to the Russian government. It also lists a chemical plant and a civil Russian airline which provides important logistical support to the Russian military.
The package also targets Chinese suppliers of drone components and microelectronic components in support of Russia’s war against Ukraine.
Another restriction which has not been seen before, is the listing of 16 individuals and 3 entities responsible for Russia’s destabilising actions abroad. The listing includes GRU Unit 29155, a covert unit within the Russian military intelligence agency known for foreign assassinations and destabilisation activities. Also, the news agency, African Initiative, known for spreading Russian propaganda and disinformation, is now listed.
The listed individuals and entities are subject to an asset freeze, and EU citizens and companies are prohibited from making funds available to them. In addition, natural persons are subject to a travel ban which prohibits them from entering or transiting through an EU member state.
In order to target those non-EU tankers that are part of Russia’s shadow fleet, additional vessels are added to the list of those subject to a port access ban and a ban on provision of a broad range of services related to maritime transport. This includes 52 vessels originating from third countries, which increases the total number of sanctioned vessels to 79.
Moreover, 32 new entities who directly support Russia’s military and industrial complex are now subject to more strict export restrictions in regard to dual-use items as well as technologies that might contribute to the technological enhancement of Russia’s defence and security sector. Some of the entities are located in third countries such as China, India, Iran, Serbia, and the United Arab Emirates.
A key part of the 15th package is the introduction of a ban on the recognition or enforcement of rulings issued by Russian courts based on article 248 of the Russian Arbitration Procedure Code. These rulings have prevented opposing parties in litigation from commencing or continuing a proceeding in a jurisdiction other than Russia. The new measure ensures that those penalties cannot be executed against EU operators within the EU.
The Council has also introduced a derogation permitting the release of cash balances held by EU central securities depositories. This measure is necessary as litigation and retaliatory measures in Russia are rising, which have led to assets seizures in the EU. The derogation enables the national competent authorities to unfreeze these cash balances.
Last, the deadlines applicable to specific licenses needed for divestments from Russia have been extended. Notably, the Council of the EU has stated, in its press release on the 15th sanctions packages, which can be found here, that EU operators should consider winding down business operations in Russia and/or refrain from starting new businesses due to the risks of maintaining business activities there.
The Council has also decided to impose additional restrictions on Belarus by adopting the Council Implementing Regulation (EU) 2024/3177 of 16 December 2024.
This package imposes restrictive measures on 26 individuals and 2 entities from Belarus, raising the total number to 287 sanctioned individuals and 39 sanctioned entities.
Various judicial members responsible for politically motivated sentences are now listed. Further, individuals who, as business owners, part-owners, associates, or members of board of directors who contributed to circumvent EU sanctions and benefitted from the Lukashenka regime are listed.
Gorrissen Federspiel closely follows the developments of sanctions against Russia, and we can assist with interpretation of and compliance with applicable sanctions as well as the implementation of measures to ensure that sanctions are observed. If you have any questions, please feel free to contact a member of our Compliance & Sustainability team.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel’s newsletters of 25 June 2024, 27 February 2024, 19 December 2023, 26 June 2023, 27 February 2023, 19 December 2022, 7 October 2022, 8 June 2022, 11 April 2022, 16 March 2022, 10 March 2022, 2 March 2022, 28 February 2022, and 24 February 2022.