EU Sanctions Update – the 15th Russia Package Amongst Other Updates

On December 16, 2024, the EU issued its 15^th package of sanctions against Russia, new designations under the Belarus sanctions regime, and the first designations under the hybrid threats sanctions regime adopted in October 2024. These updates are summarized below.

 

1. Asset Freeze Measures

Russia (Regulation 269/2014)

New designations: 54 individuals and 30 entities are now subject to asset freeze measures in recognition of their actions against Ukraine, and EU persons are prohibited from dealing with any funds or economic resources which are owned, held or controlled by such individuals and entities. Those targeted include:

• shipping companies involved in the transportation of Russian crude oil and oil products by sea;
• senior managers of various energy companies;
• individuals and entities involved in the trading of Russian crude oil; and
• various other entities and individuals, such as Russian defense suppliers, a civilian Russian airline and a Russian private jet company, Chinese and Hong Kong companies supplying drone and microelectronic components to Russia, individuals responsible for child deportation, propaganda and circumvention, as well as two senior officials of North Korea.

New derogation for central securities depositories (CSDs): This allows the release of frozen cash balances held with EU CSDs where such cash balances are no longer due to persons designated under EU sanctions against Russia and to enable CSDs to fulfill their legal obligations to participants. The addition of this derogation is in response to Russian counter measures that enable the seizure of EU CSD assets held in Russia.

Availability of the licensing ground to authorize divestment activity by certain designated persons has been extended until June 30, 2025.

Belarus (Regulation 765/2006)

New designations: 26 individuals and 2 entities are now subject to asset freeze measures. Those targeted include the executives and owners of a Belarusian logistics company, members of the Belarusian judiciary, businesspersons, individuals involved in the circumvention of EU sanctions, and heads of correctional institutions.

Hybrid Threats (Regulation 2024/2642)

First designations: 16 individuals and 3 entities involved in misinformation campaigns, Wagner Group operations, and Russian intelligence activities are now subject to asset freeze measures under the EU’s hybrid threats regime.

 

2. Trade and Sectoral Measures

52 additional vessels now subject to the EU port access ban and maritime transport services prohibitions: These vessels are now subject to anti-circumvention measures targeting ships that are circumventing the oil price cap, supporting Russia’s energy sector or are involved in transporting maritime equipment for Russia or stolen Ukrainian grain.

32 new entities added to the EU “Entity List”: The EU Entity List includes companies subject to a licensing ban for: (i) the export of dual-use goods and technology; and (ii) goods and technology that may contribute to the technological advancement of Russia’s defense and security sector. The additions include entities located in Russia, China, Hong Kong, India, Iran, Serbia and the United Arab Emirates.

Extension of licensing ground and exemption to ensure Croatian and Czechian energy supply: Croatian sanctions authorities can now, subject to certain conditions, authorize the purchase, import or transfer of certain Russian oil until December 31, 2025. In addition, the exemption allowing Czechia to import and transfer certain Russian oil products into other EU member states (subject to certain overall volume limits) has been extended until June 5, 2025.

Extensions to derogations to facilitate exits from Russia: The availability of derogations that enable EU operators to conduct certain activities prohibited under EU Russia trade sanctions but necessary for divestments from Russia has been extended until December 31, 2025. These derogations are accompanied by a recommendation that EU operators: (i) consider winding down their operations in Russia as soon as possible; and (ii) avoid starting any new businesses in Russia, due to the “risk of maintaining business activities” there, which stems from Russian countermeasures and increased legal uncertainty in the country.

 

3. Russian Litigation and Liability Protections

New prohibition against recognition and enforcement of Russian Article 248 decisions: Article 248 decisions are also known as “anti-suit injunctions” and prevent parties from pursuing legal proceedings outside of Russia.

Enhanced safeguards for EU CSDs and their employees for compliance with EU sanctions introduced (barring cases of proven negligence).