Posted: 10/01/2025
On 16 December 2024, the EU Council adopted a 15th package of sanctions against Russia.
The 15th package modifies Council Regulation (EU) numbers 269/2014 and 833/2014 by introducing new restrictive measures on an additional 54 individuals and 30 entities, amending derogations under the main asset freeze related to Russia, and by introducing new measures, some of which include reinforcing anti-circumvention measures.
This article summarises the two sets of amendments, focusing on the impact and commercial considerations specifically relevant to the shipping sector.
Additional listings
Council Regulations (CFSP) 2024/3189 and 2024/3183 of 16 December 2024 amending Regulation (EU) No 269/2014 include a significant package of 84 additional listings, ie, 54 individuals and 30 entities. The newly named 54 individuals and 30 entities are subject to asset freezes. Additionally, the regulation forbids EU citizens and companies from making funds available to those listed.
Among the 54 individuals, are the military unit responsible for striking the Okhmadyt children hospital in Kyiv, senior managers in leading companies in the energy sector, individuals responsible for child deportation, propaganda and circumvention, as well as two high-ranking officials in North Korea, including the Minister of Defence and the Deputy Chief of General Staff.
As regards entities, the EU targeted primarily Russian manufacturers of military aircraft parts, drones, electronics, engines, high-tech components for weapons, and other military equipment. The listings also target a number of shipping companies responsible for the transportation of crude oil and oil products by sea, providing important revenues to the Russian government.
Finally, for the first time, the EU Council has adopted 'fully-fledged listings’ on seven Chinese persons and entities facilitating the circumvention of EU sanctions, and supplying sensitive drone components and microelectronic component to the Russian military industry in support of Russia's war of aggression against Ukraine.
Introduction of a loss recovery derogation
Among other amendments, the EU Council introduced in article 6b of Regulation (EU) No 269/2014 a loss recovery derogation allowing the release of cash balances held by EU central securities depositories (CSDs). This new measure will allow CSDs to request the release of frozen cash balances, allowing them use them to use the funds to fulfil their legal obligations with clients.
In addition to the asset freeze measures described above, Council Decision (CFSP) 2024/3187 and Council Regulation (EU) 2024/3192 of 16 December 2024 provides for several amendments to regulation 833/2014, which is the main regime providing for sectoral sanctions relating to Russia.
In order to further constrain vessels operated to contribute to or assist actions or policies supporting Russia’s activities against Ukraine, Decision (CFSP) 2024/3187 adds 52 new vessels to the list in annex XVI to Decision 2014/512/CFSP targeting Russia’s shadow fleet. These vessels (non-EU) are now subject to the individual sanctions framework, introduced by the 14th sanctions package, that prohibits access to EU ports and locks and provides restrictions on maritime transport services.
The list is also expanded with 32 new entities (20 Russian firms, seven under Chinese/Hong Kong jurisdiction, two from Serbia, and one each from Iran, India and the United Arab Emirates). These entities will be subject to stricter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector.
In order to better protect European companies from litigation with Russian counterparties, the EU Council decided to introduce provisions to prohibit recognising, giving effect to or enforcing in the EU those injunctions, orders, judgments or other court decisions pursuant to or derived from article 248 of the Arbitration Procedure Code of the Russian Federation or equivalent Russian legislation. The new provisions explicitly seek to address the increase in anti-suit injunctions and protect EU companies from the recognition of damages illegally awarded against them in Russia.
Finally, the EU has extended a number of derogations that permit EU operators to divest from Russia until 31 December 2025. They are granted on a case-by-case basis by member states and will be focused on allowing the national competent authorities (NCAs) to authorise transactions that are necessary to wind down operations in Russia.
This new package is widely seen as just the beginning, paving the way for a more extensive and impactful set of restrictive measures anticipated for implementation next year.
This article was co-written with Eleni Meletlidou, paralegal in the marine, trade and energy team.
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