15th package of EU sanctions: EU reaction to Russian invasion of Ukraine (regularly updated)

Since the Russian invasion of Ukraine in February and March 2014 and the subsequent annexation of Crimea and Sevastopol to the Russian Federation (Russia) on 16 March 2014, declared illegal also by the UN General Assembly (UNGA/11493, 27 March 2014), the EU has adopted, under articles 29 of the TEU and 215 of the TFEU, a series of restrictive measures against persons and entities for their role in actions threatening the territorial integrity, sovereignty and independence of Ukraine[1].

Following Russia’s recognition of the Luhansk and Donetsk People’s Republics’ independence on 21 February 2022 and its further invasion of Ukraine on 24 February 2022, the EU adopted a first package of sanctions.

In view of the gravity of the situation, and in response to Russia’s continued military aggression against Ukraine, the EU has adopted a series of new restrictive measures.

More than two years after Russia’s invasion and war of aggression against Ukraine, on December 16, 2024, the EU adopted its 15th package of sanctions against Russia.

The following are among the main measures implemented to crack down on Russia’s shadow fleet, fight against sanctions circumvention, and protect EU operators from retaliatory measures:

15th package of sanctions

Council Decision (CFSP) 2024/3174 of 16 December 2024 amending Decision (CFSP) 2024/2643 concerning restrictive measures in view of Russia’s destabilising activities, and Council Implementing Regulation (EU) 2024/3188 of 16 December 2024 implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilizing activities[2]:

First listings under the new sanctions regime in response to Russia’s hybrid threats:

• Following the establishment,on 8 October 2024, of a new sanctions regime in response to Russia’s hybrid threats[3], the Council imposed for the first time restrictive measures against 16 individuals and 3 entities responsible for Russia’s destabilising actions abroad.
  • The listed persons and entities are subject to asset freeze and EU citizens and companies are forbidden from making funds available to them, while natural persons are also subject to a travel ban which prevent them from entering or transiting through EU territories
  • Among those listed there are[4]:
    • GRU Unit 29155, a covert unit within the Russian military intelligence agency (GRU), known for its involvement in foreign assassinations and destabilisation activities such as bombings and cyber-attacks across Europe;
    • Groupe Panafricain pour le Commerce et l’Investissement, a disinformation network carrying out pro-Russian covert influence operations;
    • African Initiative, a news agency involved in spreading Russian propaganda and disinformation on the African continent;
    • Sofia Zakharova, the department head in the Office of the President of the Russian Federation for the Development of Information and Communication Technologies and Communications Infrastructure, and Nikolai Tupikin, head and founder of GK Struktura;
    • Vladimir Sergiyenko, a former parliamentary assistant of the Member of the German Bundestag, Eugen Schmidt, who actively colluded with Russian intelligence officers;
    • Visa Mizaev, a Russian entrepreneur and his business partner and wife, who played a key role in a Russian intelligence operation against the German Federal Intelligence Service (BND) in which highly classified information was passed to the FSB;
    • Collaborators of the Government of the Russian Federation in France: Alesya Miloradovich, a Russian government employee, and Anatolii Prizenko, a Moldovan businessman who coordinated the dispatch of several Moldovan citizens to France in October 2023.

Council Decision (CFSP) 2024/3182 of 16 December 2024 amending Decision 2014/145/CFSP, Council Regulation (EU) 2024/3189 of 16 December 2024 amending Regulation (EU) No 269/2014, and Council Implementing Regulation (EU) 2024/3183 of 16 December 2024 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine[5]:

• Addition of 54 persons and 30 entities to the list of persons/entities subject to restrictive measures (asset freezes and travel bans) set out in Annex I to Regulation (EU) No 269/2014 and consisting of:
  • Russian military companies that manufacture aircraft parts, drones, electronics, engines, high-tech components for weapons, and other military equipment;
  • Senior managers in companies active in the Russian energy sector (including shipping companies), providing important revenues to the Russian government;
  • The military unit responsible for the striking of the Okhmadyt children hospital in Kyiv as well as individuals responsible for children deportation and propaganda;
  • Seven Chinese persons and entities, facilitating the circumvention of EU sanctions, and supplying sensitive drone components and microelectronic component to the Russian military industry in support of Russia’s war of aggression against Ukraine;
  • Two senior officials from the Democratic People’s Republic of Korea.

• Introduction of a derogation in Article 6b of Regulation (EU) No 269/2014 allowing the release of (freezed) cash balances that are held by central securities depositories in the Union and attributable to designated entities as a response to increasing litigation and retaliatory measures in Russia.

Council Decision (CFSP) 2024/3187 of 16 December 2024 amending Decision 2014/512/CFSP and Council Regulation (EU) 2024/3192 of 16 December 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine[6]:

Trade-related measures:

• Addition of 32 entities to the list, set out in Annex IV to Decision 2014/512/CFSP, of those directly supporting Russia’s military and industrial complex on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector, are imposed (including 20 Russian firms, 7 under Chinese/Hong Kong jurisdiction, 2 from Serbia, and 1 each from Iran, India and United Arab Emirates).

Anti-circumvention measures:

• Addition of 52 vessels to the list set out in Annex XVI to Decision 2014/512/CFSP, targeting Russia’s shadow fleet (a total of 79 listed non-EU vessels) subject to a port access ban and a ban on provision of services.

Protection of EU operators:

• Prohibition to recognise or enforce in the EU injunctions, orders, judgments or other court decisions pursuant to or in relation to Article 248 of the Arbitration Procedure Code of the Russian Federation or equivalent Russian legislation that give exclusive mandatory competence to Russian courts in disputes between Russian and EU companies (anti suit injunctions). This measure will protect EU companies from the recognition of damages illegally awarded against them in Russia.
• Extension of certain derogations enabling EU operators to divest from Russia, granted on a case-by-case basis by Member States and focused on allowing an orderly divestment process from the Russian market.
• A loss recovery derogation enabling EU central securities depositories to request competent authorities of the Member States to unfreeze cash balances and use them to meet their legal obligations with their clients.
• A no liability clause for EU central securities depositories clarifying that EU CSDs are not liable to pay interest or any other form of compensation to the Central Bank of Russia, beyond interest contractually due.

In response to Belarus’s involvement in Russia’s unprovoked invasion against Ukraine, the EU has introduced the following new measures.

Council Implementing Decision (CFSP) 2024/3175 of 16 December 2024 implementing Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, and Council Implementing Regulation (EU) 2024/3177 of 16 December 2024 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine[7]:

• Addition of 26 natural persons and 2 legal persons to the list of persons/entities subject to restrictive measures set out in Annex I to Regulation (EC) No 765/2006.

---

[1] Council Decision 2014/145/CFSP of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 16–21; and Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 6–15;

Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine OJ L229, 31.7.2014, p. 13–17; and Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 229, 31.7.2014, p. 1–11.

[2] Council Decision (CFSP) 2024/3174 of 16 December 2024 amending Decision (CFSP) 2024/2643 concerning restrictive measures in view of Russia’s destabilising activities, OJ L, 2024/3174, 16.12.2024;

Council Implementing Regulation (EU) 2024/3188 of 16 December 2024 implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilizing activities, OJ L, 2024/3188, 16.12.2024.

[3] The new sanctions regime was established to target those engaged in actions or policies by the Government of the Russian Federation which undermine the fundamental values of the EU and its member states, their security, stability, independence and integrity, as well as those of international organisations and third countries through hybrid activities of various kinds, including the use of coordinated information manipulation and interference (Legal bases: Council Decision (CFSP) 2024/2643 of 8 October 2024 concerning restrictive measures in view of Russia’s destabilising activities, OJ L, 2024/2643, 9.10.2024; and Council Regulation (EU) 2024/2642 of 8 October 2024 concerning restrictive measures in view of Russia’s destabilizing activities, OJ L, 2024/2642, 9.10.2024).

[4] Council of the EU, Press release, “Russian hybrid threats: EU agrees first listings in response to destabilising activities against the EU, its member states and partners”, 16 December 2024 (available here).

[5] Council Decision (CFSP) 2024/3182 of 16 December 2024 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2024/3182, 16.12.2024;

Council Regulation (EU) 2024/3189 of 16 December 2024 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2024/3189, 16.12.2024;

Council Implementing Regulation (EU) 2024/3183 of 16 December 2024 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2024/3183, 16.12.2024.

[6] Council Decision (CFSP) 2024/3187 of 16 December 2024 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L, 2024/3187, 16.12.2024;

Council Regulation (EU) 2024/3192 of 16 December 2024 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L, 2024/3192, 16.12.2024.

[7] Council Implementing Decision (CFSP) 2024/3175 of 16 December 2024 implementing Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2024/3175, 16.12.2024;

Council Implementing Regulation (EU) 2024/3177 of 16 December 2024 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2024/3177, 16.12.2024.