The EU has adopted a 17th sanctions package against Russia. The package focuses on cutting Russia’s access to military technology and limiting energy revenues through further designations and export restrictions. In parallel, the EU has updated three other sanctions regimes related to Russia, including news sanctions targeting Russia’s destabilization actions. This newsletter contains an overview of the new sanctions measures and an update on recent changes to Denmark’s export control rules.
The new 17th sanctions package against Russia was adopted on 20 May 2025. The measures are set out in several Implementing Regulations, which can be found here.
Below, we summarise some of the most significant changes. We also provide an update on some general changes to the Danish national export control landscape.
Targeting the Russian ‘shadow fleet’, the EU has doubled the number of vessels for which a port access ban and a ban on provision of various services apply. A large number of the 189 newly designated vessels operate under the flag of different third countries, highlighting the need for due diligence prior to engaging with vessels from various countries also outside of Russia.
The EU has also imposed new asset freezes targeting the network supporting the shadow fleet. These sanctions for the shadow fleet ecosystem target various actors with activities linked to sea transport of crude oil and oil products, including companies from the United Arab Emirates, Turkey, and Hong Kong, and a significant insurer within the Russian oil shipping industry, and Russian oil major Surgutneftegaz.
The EU had further imposed sanctions against more than 45 companies and individuals delivering military equipment and support to the Russian army.
The sanctions target direct manufacturers of military equipment as well as so-called ‘industrial enablers’, which could be Russian and Chinese entities supplying machine tools to the Russian military and its broader supply chain. The sanctions illustrate the EU’s focus on suppliers from third countries, as three Chinese entities, one Belarusian and one Israeli entity are added to the list for providing critical components to the military of Russia.
With regard to dual use goods and technologies, 31 new entities have been added to the list of subjects for which stricter export restrictions apply. Among the 31 new entities, several are located in third countries such as Serbia, the United Arab Emirates, Türkiye, Vietnam and Uzbekistan.
Further, the EU has implemented additional export limitations on goods that aid in Russia’s military and technological advancements, as well as the growth of its defense and security sectors. These restrictions cover, inter alia, chemical precursors and spare parts for machine tools used in the development or production of military systems.
The 17th sanctions package is accompanied by updates to three other EU sanctions regimes against Russia targeting Russia’s destabilization actions/hybrid warfare, domestic violations of human rights and the use of riot control agents by Russian forces in Ukraine.
Notably in light of recent damages and sabotage of undersea cables in the Baltic Sea, the EU has updated the sanctions designation criteria for entities involved in destabilization actions to include tangible assets (such as vessels, aircraft, ports etc.) used in connection with activities that damage critical infrastructure, including submarine infrastructure.
On a related topic, it is worth noting that the Danish export control regime has been updated. As of 1 January 2025, the Danish Business Authority no longer has authority to conduct export control inspections. Previously, the Danish Business Authority could conduct inspections at company premises without warning. However, the Danish Business Authority is still permitted to require access to information, including documents, inventory records, customer records, etc., in order to inspect companies’ compliance with export control regulations. Therefore, companies must still be prepared to submit the requested documentation if authorities demand it.
In addition, a legislative proposal to increase the maximum penalty for violations of the export control regime targeting inter alia export of weapons and other products listed on the EU Common Military List has been proposed by the Danish Minister of Justice. If adopted, the penalties for violations of export control rules will range from a fine or imprisonment for up to five years (as opposed to currently two years) under normal conditions, and up to 8 years in particularly aggravating circumstances. The proposal is currently being read in the Danish Parliament and is available here.
Gorrissen Federspiel closely follows the developments of export controls and sanctions, 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 February 2025, 17 December 2024, 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.