EU adopts 15th package of EU restrictive measures against Russia

On 16 December 2024, the Council of the EU adopted its fifteenth package of restrictive measures against Russia, which supplements those discussed in our previous newsflashes. This package notably subjects an additional 84 individuals and entities to an asset freeze and strengthens the EU’s efforts to prevent sanctions being circumvented. It also prohibits the enforcement of rulings issued by Russian courts and extends the deadlines for divesting certain assets.

The Council of the EU has adopted two regulations which both entered into force on 16 December 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.

• 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.

Persons subject to an asset freeze

This new package adds 54 individuals and 30 entities to the list of persons subject to an asset freeze, including Russian defence and shipping companies, military units, and North Korean officials.

In addition, the Council has imposed tighter export restrictions on 32 new entities, including several established in China, for their involvement in supporting Russia’s military and industrial complex. These restrictions relate to dual-use goods and technologies.

Protection from certain Russian rulings

The Council introduced a new provision designed to protect EU operators from rulings issued by Russian courts under Article 248 of the Russian Arbitration Procedure Code. These rulings, known as anti-suit injunctions, compel opposing parties to conduct legal proceedings exclusively in Russia. In response, the Council has now prohibited the recognition or enforcement of such rulings within EU Member States.

Release of cash balances held by CSDs and no-liability clause

A new derogation allows EU central securities depositories (CSDs) to request, under certain conditions, the unfreezing of certain cash balances to fulfil the CSD’s legal obligations to its clients.

Anti-circumvention

The Council added 52 new vessels associated with Russia’s “shadow fleet” to the list of vessels that are prohibited from accessing EU ports or receiving services in the EU. These vessels have been associated with the transportation of military goods, the circumvention of certain measures targeting the Russian energy sector and the transportation of stolen Ukrainian grain.

Extended deadlines to divest from Russia

To allow EU operators time to withdraw from Russia, the Council has extended the deadline for various derogations by a year, until 31 December 2025.

Additional restrictive measures

The EU imposed asset freeze restrictions on 16 individuals and three entities linked to Russia’s hybrid threats. This marks the first use of the framework introduced in October that aimed to target activities undermining the stability of the EU and its partners through disinformation and other malicious actions.

The targeted entities include a covert Russian military intelligence unit, a disinformation network operating in Africa, and individuals involved in intelligence operations and the dissemination of propaganda (see Regulation 2024/3188).

Separately, the Council has also added 26 individuals and two entities from Belarus to the list of persons subject to an asset freeze (see Regulation 2024/3177).