Posted: 04/06/2025
On 20 May 2025, the EU and the UK announced further sanctions against Russia. This marks the EU’s 17th package of restrictive measures in response to the ongoing war in Ukraine. The new measures continue to target critical points of Russia’s economic and military infrastructure, while tightening enforcement and addressing circumvention through third countries and shadow intermediaries.
This article summarises the additions and amendments to both sets of sanctions regimes, focusing on the impact and commercial considerations pertinent to the shipping sector.
The EU's 17th package aims to strengthen measures in response to the ongoing conflict in Ukraine. This latest package introduces significant expansions, targeting individuals, entities, and sectors linked to Russia's military and economic activities.
Regulation 269/2014: individual sanctions
The legal basis for future designations has been widened, allowing the EU to sanction individuals and entities that have facilitated the transfer of ownership, control, or economic benefits of Russian business interests. This change aims to close a major loophole exploited via asset restructurings and nominee arrangements. It allows the EU to respond more dynamically to evolving evasion tactics especially via family members, offshore vehicles, or complex trust structures.
The EU's 17th package has expanded its sanctions list by adding 66 individuals and 67 entities in a continued effort to limit Russia’s war capabilities. Among those targeted are operators and insurers of Russia’s 'shadow fleet', which are vessels used to evade sanctions, particularly those related to oil exports that bypass the price cap mechanism. The sanctions also include a major Russian oil company, aiming to further restrict fossil fuel revenues that support the war effort. Key suppliers to Russia’s military industrial complex, many of which are located outside the EU, have also been sanctioned. The EU also targeted entities involved in the exploitation of Ukrainian agriculture and cultural heritage, especially in the occupied region of Crimea. These listings are designed to disrupt logistics and trade directly supporting the war, whilst also targeting the economic benefits Russia derives from occupied territories.
Regulation 833/2014: sectoral sanctions
The 17th package adds 189 vessels to Annex XLII of Regulation 833/2014, bringing the total number of listed vessels that are subject to a port access ban and a ban on the provision of services related to maritime transport to 342. By targeting the logistics of oil trade directly, the EU seeks to undermine Russia’s ability to monetise energy exports without visibility or regulation. It also aims to deter insurers and service providers from facilitating opaque shipping practices.
17 individuals and 58 entities have been added to the EU's asset freeze list. These additions include figures active in Russian defence and energy sectors, as well as those involved in the 'shadow fleet' and insurance industries.
31 new entities linked to Russia's military industrial sector have been identified, including companies based in China, India, Kyrgyzstan, Turkey, Singapore and Vietnam. These entities are now subject to enhanced export licensing requirements for dual use and military grade goods. These measures expand the scope of restricted technologies to include a broader range of electronics and machine components with potential military end-uses. Exporters must conduct heightened due diligence on goods at risk of diversion through intermediary jurisdictions such as the UAE, Turkey, and Central Asian states.
These developments reflect a substantial tightening of the EU’s export control regime. The inclusion of third country entities underscores the EU’s growing emphasis on anti-circumvention enforcement, particularly targeting indirect procurement routes used by Russia to access Western-origin components. As Russia increasingly relies on such third country intermediaries, these updated controls are designed to disrupt those supply chains and impose greater compliance obligations on EU exporters.
Businesses must now reassess their export control frameworks, with a particular focus on supply chain transparency and end-use verification, to mitigate the risk of inadvertent breaches and ensure regulatory compliance.
In parallel with the EU, the UK imposed over 100 new sanctions, reflecting alignment on the key themes above.
Shipping
A further 18 ships responsible for carrying Russian oil in the 'shadow fleet' have been added to the sanctions list. This follows the Prime Minister announcing 110 shadow fleet related sanctions ahead of his visit to Ukraine earlier this month.
Asset freeze
The UK has imposed asset freezes and trust services restrictions on 20 individuals and 62 entities as part of its latest sanctions package targeting Russia. These measures affect parties involved in the supply chains for Russian weapons systems, including those linked to the production of Iskander missiles. Notably, 46 financial institutions have been designated, such as the St. Petersburg Currency Exchange, the Non-bank Credit Organization Joint-Stock Company Petersburg Settlement Center, and the State Corporation Deposit Insurance Agency (DIA), which insures Russian banks.
The sanctions also target individuals allegedly supporting Russia’s shadow fleet operations, including British national John Michael Ormerod and two Russian tanker captains, as well as 14 members of the Kremlin-linked Social Design Agency, accused of conducting state-sponsored information operations.
The 17th sanctions package reflects a sharpened focus on enforcement and circumvention, with increased attention on third countries, facilitators, and indirect asset ownership. It also indicates a growing willingness to impose secondary consequences, particularly through measures that affect global shipping and financial services. The EU is already formulating its 18th sanctions package with discussions focusing on tightening the oil price cap and introducing further restrictions in the energy and financial sectors.
This article was co-written by Laura Stigaite, trainee solicitor in the marine, trade and aviation team.
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