knowledge 9 June 2025 |

What’s Included in the EU’s 17th Sanctions Package Against Russia?

Introduction

On 20 May 2025, the Council of the European Union (the “Council”) adopted its 17th package of restrictive measures against Russia (the “17th Package”).¹ The economic and individual restrictive measures aim to cut off Russia’s access to key military technology and quell Russia’s energy revenues.  The package builds on the 16th package of sanctions (see our previous briefing note here) and further targets Russia’s ‘shadow fleet’ of oil tankers, their operators, and a major Russian oil producer. The Council also announced broader measures targeting Russia’s hybrid activities (including sabotage, disruption of critical infrastructure, cyber-attacks, information manipulation and interference, and attempts to undermine democracy, including in the electoral process, against the European Union and its member states), domestic violations of human rights and the use of riot control agents by Russian forces in Ukraine, under three other sanctions regimes. 

Kaja Kallas, the High Representative for Foreign Affairs and Security Policy and chair of the Foreign Affairs Council has described the 17th Package as “the most wide-sweeping since the start of the war” in 2022.²

Highlights from 17th package of restrictive measures

Russia’s shadow fleet

The Council has doubled the number of vessels, now totalling 342, included in the list of Russia’s shadow fleet subject to a port access ban and a ban on the provision of a broad range of services. The port access ban, in force since 16 April 2022, prohibits vessels registered under the Russian flag or certified by the Russian Maritime Register of Shipping from entering EU ports and the ban on the provision of services includes technical assistance or insurance services. These measures aim to weaken the shadow fleet’s functional capabilities and reduce the oil revenue sustaining Russia’s wartime economy.

The EU has also imposed asset freeze restrictions on actors deemed to enable the operation of the shadow fleet. These included targeted restrictions on companies from the United Arab Emirates, Türkiye and Hong Kong who transport oil products.

Energy

The EU has imposed asset freeze restrictions on further entities deemed to generate considerable funds for the Russian government through the production of oil. New listed entities include PJSC Surgutneftegaz, a significant Russian oil and gas company.

Crypto asset services

The 17th package includes provision for sanctions to target (i) non-EU financial institutions or entities providing crypto asset services which are involved in transactions that facilitate Russia’s destabilising activities or that support persons, entities or bodies that engage in such activities, and (ii) entities providing technical or operational assistance to these persons. However, no entities have yet been added to this list.³

Military-industrial sector

The 17th package imposes restrictions on over 45 Russian entities supplying military equipment to the Russian army and also imposes restrictions on three Chinese companies, a Belarussian company and an Israeli company which have supplied Russia with military components, including for drone production.

Additionally, the Council has added 31 new organisations to the list of entities facing stricter export controls on dual-use items and technologies, due to their involvement in supporting Russia’s military in its war of aggression against Ukraine. Some of these organisations are based in third countries (including Serbia, the United Arab Emirates, Türkiye, Vietnam, and Uzbekistan) and have participated in circumventing export bans, including those involving UAVs (Unmanned aerial vehicles) or CNC (computer numerical control) machinery.

The EU has also imposed broader export restrictions on goods that support Russia’s military, technological, and defence capabilities, including weapon components, chemical precursors, and machinery parts.

Additional sanctions designations

The Council made additional designations of legal persons and entities involved in human rights violations in Russia, Russian hybrid threats, and the use of chemical weapons in Ukraine.

Chemical Weapons

On 20 May 2025, the EU added three entities to the list of restricted entities sanctioned due to involvement in the development and use of chemical weapons under the Chemical Weapons Regime.⁴

Hybrid Threats

The EU has implemented a comprehensive sanctions framework to address Russia's hybrid threats.⁵ Hybrid threats are covert and unconventional tactics aimed at destabilising EU member states and third countries. Examples of hybrid threats include undermining electoral processes and democratic institutions, spreading false information, interfering with public opinion, and exploiting migration flows for political purposes.

On 20 May 2025 the Council imposed additional restrictive measures against 21 individuals and 6 entities responsible for Russia’s destabilising actions abroad⁶. The Council broadened the scope of the hybrid threat regime to allow the EU to target tangible assets linked to Russia’s destabilising activities, such as vessels, aircraft, real estate, and physical elements of digital and communication networks, as well as transactions of credit institutions, financial institutions and entities providing crypto-assets services that directly or indirectly facilitate Russia’s destabilising activities.

Restrictions imposed under this regime include asset freezes, travel bans, and funding restrictions. Entities like Russia’s military foreign intelligence agency (GRU) and pro-Russian disinformation networks in Africa such as the African Initiative have been targeted. These measures aim to protect EU security and democratic institutions.

Human Rights

The EU has imposed new sanctions targeting individuals and entities involved in activities that threaten democracy, the rule of law, or security in EU Member States.⁷ Newly designated individuals include Olesya Mendeleyeva - a judge at Moscow’s Meshchansky Court who sentenced activist Alexei Gorinov to 7 years in prison under what is generally considered politically motivated charges for criticizing Russia’s war against Ukraine.

Conclusion

The 17th package demonstrates the EU’s firm commitment to severing Russia’s access to essential military technology and reducing the energy income it requires to support its war against Ukraine. Additional designations also demonstrate the EU’s willingness to target Russia’s hybrid activities, human rights violations and use of chemical weapons.

Operators should be mindful of the new expanded reach of EU sanctions and note that the EU remains ready to step up pressure on Russia, including by adopting further sanctions. In this regard Kaja Kallas recently announced that work on an upcoming 18th package of sanctions is underway.⁸ 

For further information or tailored advice on compliance with EU sanctions, please contact your usual firm representative.

Links to new restrictive measures announced on 20 May 2025:

New asset freeze designations and travel bans:

• Council Decision (CFSP) 2025/936 of 20 May 2025 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine here
• Council Implementing Regulation (EU) 2025/933⁹ of 20 May 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine here

Hybrid threats regime:

• Council Decision (CFSP) 2025/966 of 20 May 2025 amending Decision (CFSP) 2024/2643 concerning restrictive measures in view of Russia’s destabilising activities here
• Council Implementing Regulation (EU) 2025/965 of 20 May 2025 implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities here¹⁰

Human rights regime:

• Council Decision (CFSP) 2025/957 of 20 May 2025 amending Decision (CFSP) 2024/1484 concerning restrictive measures in view of the situation in Russia here
• Council Implementing Regulation (EU) 2025/958 of 20 May 2025 implementing Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia here¹¹

Chemical weapons regime:

• Council Decision (CFSP) 2025/960 of 20 May 2025 amending Decision (CFSP) 2018/1544 concerning restrictive measures against the proliferation and use of chemical weapons here
• Council Implementing Regulation (EU) 2025/959 of 20 May 2025 implementing Regulation (EU) 2018/1542 concerning restrictive measures against the proliferation and use of chemical weapons here

New designation criteria (under Russian hybrid threats regime)

• Council Decision (CFSP) 2025/963 of 20 May 2025 amending Decision (CFSP) 2024/2643 concerning restrictive measures in view of Russia’s destabilising activities here
• Council Regulation (EU) 2025/964¹² of 20 May 2025 amending Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilizing activities here

Sectoral sanctions targeting Russia:

• Council Decision (CFSP) 2025/931 of 20 May 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine here
• Council Regulation (EU) 2025/932 of 20 May 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine here¹³

European Commission FAQs

• The latest version of the European Commission FAQs on sanctions against Russia and Belarus is available here.