EU Imposes 17th Sanctions Package Against Russia: Key Measures and Business Impact
On 20 May 2025, the European Union adopted its 17th package of restrictive measures against the Russian Federation. We outline below the most important changes introduced by this package and their legal and practical implications for international businesses.
1. Sanctions against Tanker Fleet and Energy Exports
The EU has added 189 vessels, including 183 oil tankers, to its sanctions list. These vessels are associated with what the EU refers to as a "shadow fleet" allegedly used to bypass the EU oil embargo and the G7 price cap.
Implications: These vessels and their owners/operators are now subject to asset freezes and a prohibition on making funds or economic resources available to them. This affects charterers, insurers, port operators, and ship management firms across jurisdictions, especially in the UAE, Turkey, and Hong Kong.
Russian Oil Entities Targeted: Prominent companies such as Surgutneftegaz and Lukoil subsidiary (Eiger Shipping DMCC) engaged in oil trade have also been sanctioned.
2. Export Control and Dual-Use Technology Restrictions
The EU expanded the list of prohibited dual-use and advanced technology items and designated 31 foreign entities allegedly involved in supplying components to Russia’s "military-industrial complex." These entities are based in China, Turkey, UAE, Vietnam, Israel, Serbia, Belarus, and Uzbekistan.
Implications: Exporters must reassess due diligence processes, end-user certifications, and supply chain transparency to ensure full compliance with updated restrictions.
3. Sanctions Related to Activities Considered by the EU as “Hybrid Threats”
The EU imposed sanctions on a group of individuals and entities in connection with activities it qualifies as “cyberattacks,” “foreign interference,” “disinformation,” and other actions perceived as threatening to “public security” and institutional stability within the Union.
Key development: 27 individuals and entities were listed under this framework. For the first time, the EU imposed sanctions on EU citizens, as well as Russian and other foreign nationals permanently residing in EU Member States. This marks a shift in the EU’s approach toward addressing what it perceives as internal and cross-border risks.
Legal scope: The new regime allows the EU to block access to and freeze assets such as vessels, aircraft, real estate, and elements of digital and communication infrastructure allegedly used in connection with these activities.
4. Measures Related to Specific Military Entities and Legal Proceedings
Additional restrictive measures were imposed on:
Companies producing riot control agents and chemical products, reportedly used in "conflict-affected zones";
28 individuals, including judges and prosecutors, alleged to be involved in "politically motivated legal proceedings", including high-profile cases involving opposition figures.
Implications for International Business
These developments are especially relevant to businesses in shipping, energy, trade, high-tech, and financial services sectors.
🔹 Third-Party Risk Management
Companies must screen counterparties, logistics providers, and intermediaries against the updated EU sanctions lists.
Entities from the jurisdictions mentioned above present elevated compliance risks.
🔹 Shipping and Logistics Controls
Maritime and freight operators must ensure that they do not charter or service vessels subject to EU sanctions.
Non-compliance may result in enforcement actions and reputational damage.
🔹 Financial Sector Compliance
Banks, insurers, and payment service providers must update screening systems and ensure all dealings are in line with new asset freeze requirements.
🔹 Technology & Media Sector Considerations
Digital infrastructure providers, social media platforms, and cloud service providers must assess the risk of misuse of their platforms by sanctioned individuals or groups.
Outlook and Strategic Recommendations
The 17th package signals the EU’s intent to expand its sanctions framework beyond traditional financial and trade restrictions, introducing function-based measures focused on “hybrid threats,” cyber activities, and internal destabilization.
In this environment, companies must act proactively to mitigate risk:
🔸 Review and update internal compliance programs
🔸 Conduct enhanced due diligence on supply chains and counterparties
🔸 Seek legal guidance on licensing requirements or exemptions
🔸 Prepare for increased regulatory scrutiny and enforcement
How We Can Support You
At Milutin & Partners, we assist clients in navigating complex international sanctions regimes. Our services include:
Risk assessment and compliance audits
Implementation of internal control systems
Advisory on sanctions screening and licensing
Representation in EU sanctions-related disputes and litigation
📩 If your business is engaged in sensitive cross-border transactions, we invite you to schedule a confidential consultation.
Contact Milutin & Partners today