The 17th sanctions package against Russia

I. Background

It was just at the end of February 2025 that EU member states decided on far-reaching financial and economic sanctions against Russia. The focus was not only on measures against Russia's “shadow fleet,” but above all on far-reaching trade restrictions. A new import ban on unwrought aluminium (CN code 7601), was introduced. Export restrictions were also imposed on goods that contribute to improving Russia's industrial capabilities, such as certain chemicals and plastics.

The package also expanded the list of restricted goods that contribute to the technological strengthening of Russia's defense and security sector. New items including chemicals for chloropicrin and other irritants, software for CNC machines, and controls for unmanned aerial vehicles (UAVs) were added.

In addition, further companies were added to the list of entities supporting the Russian military-industrial complex. These companies are now also subject to stricter export restrictions; for example, dual-use goods may no longer be supplied to them. Furthermore, the already severely restricted export of dual-use goods to Russia may no longer be authorized by the competent national authorities if these goods would indirectly reach relevant companies through export to Russia.

Finally, it is worth mentioning the extension of the so-called “best efforts obligations”. These obligations were already partially introduced with the 14th sanctions package but have now been extended to all sanctions regimes applicable to Russia and Belarus. According to these obligations, European companies must endeavor to influence their subsidiaries in third countries, where possible, to also comply with the European sanctions.

The current package of sanctions builds on these regulations and adds to them horizontally.

II. The 17th Sanctions Package

On May 20, 2025, the EU member states adopted Decision (CFSP) 2025/931 / Regulation (EU) 2025/932 with regard to Regulation (EU) 833/2014 and Decision (CFSP) 2025/936 / Implementing Regulation (EU) 2025/933 with regard to Regulation (EU) 269/2014, imposing further financial and economic sanctions. These will be implemented with immediate effect through corresponding updates to the mentioned EU regulations and are therefore directly applicable law.

The package of measures focuses on the following details:

• Measures against more than 30 individuals, organizations, or entities supporting Russia's military-industrial complex. Making full use of the legal framework already established in the 16th sanctions package, the EU is extending sanctions to Russia's industrial suppliers. As part of these measures, the EU is targeting Russia's supporters in third countries and adding Chinese, Belarusian, and Serbian companies to the list in order to combat the circumvention of export restrictions, for example in connection with UAVs. European companies must therefore increasingly ensure that they comply with Russian sanctions even when exporting outside of Russia.

• Extension of the list of goods used to strengthen Russia's military and technological capabilities or to develop its defense and security sector to include goods used by Russia in its war of aggression against Ukraine, as well as goods that contribute to the development or manufacture of its military systems, including chemical precursors for energy materials and spare parts for machine tools.

• Extension of the list of measures against Russia's “shadow fleet” to include more than 180 ships. These ships are now also banned from European ports and from receiving various services. This means that almost 350 ships are namely subject to sanctions now. 

• Imposition of further financial (individual) sanctions against a large number of persons, entities and bodies. With the 17th sanctions package now in force, the individuals and companies affected will no longer be able to access their funds or economic resources in the EU, which are to be frozen. In addition, they are subject to a prohibition on making funds or economic resources available to them. This means that a total of more than 2,400 persons, entities and bodies are now directly affected by individual sanctions through listings.

III. Conclusion

Sanctions of the current package mainly focus on a horizontal tightening of existing sanctions. Companies should nevertheless use this respite in the ongoing sanctions marathon to review the effectiveness and completeness of their existing export compliance systems. In particular, compliance with the (indirect) prohibition on making funds or economic resources available to the steadily growing number of designated companies and the (indirect) export bans on companies that strengthen Russia's military-industrial complex can pose a particular challenge for European companies, which should seek ongoing legal advice on this matter.

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.

COUNCIL IMPLEMENTING REGULATION (EU) 2025/933 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.