EU restrictive measures in view of Russia’s war of aggression against Ukraine

KEY POINTS

• The original sanctions on Russia, which date from 2014, have been amended multiple times, for example to update lists of individuals or to prolong existing sanctions.
• Since Russia’s decision in February 2022 to recognise non-government-controlled areas of the Donetsk and Luhansk oblasts of Ukraine as independent entities and its subsequent invasion of Ukraine, the EU has adopted the largest-ever set of restrictive measures, in a series of decisions comprising 16 packages and targeting several sectors of Russia’s economy and individuals supporting Russia’s war of aggression.

Targeted sanctions

The EU has put in place various types of sanctions with different targets and objectives.

Individual sanctions

These sanctions target individuals, entities and bodies that have, among other things, committed acts undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. These sanctions include:

• freezing assets held in the EU;
• prohibiting EU citizens and companies from making funds available;
• banning the travel of individuals, preventing them from entering or transiting through EU territories;
• a unique listing criterion targeting non-EU individuals or entities facilitating infringements of the prohibition against the circumvention of EU sanctions by individuals or entities.

The lists of individuals, bodies and entities are updated regularly. They have also been expanded to include some Russian-controlled entities based in illegally annexed Crimea and Sevastopol, and actors in non-EU countries directly supporting Russia’s war effort.

The February 2025 sanctions package lists:

• an additional 48 individuals, including executives of companies involved in the mining and energy sectors, politicians and proxies from the non-government-controlled areas of Ukraine, individuals involved in the mass abduction, illegal re-education, deportation and forced transfer of Ukrainian children to Russia, and two senior officers in the Korean People’s Army;
• 35 entities operating in or connected to the military–industrial complex, including entities manufacturing military equipment and technology (i.e. vehicles, missiles and armaments) and transporting military equipment, entities transporting Russian crude oil and oil products, propagandistic media (NewsFront and SouthFront, which present distorted interpretations of history and manipulated information), Garantex (a cryptocurrency exchange based in Russia) and operators in non-EU countries directly supporting Russia’s war effort, such as a Chinese company producing satellite imagery.

This latest package means that EU restrictive measures in respect of measures undermining or threatening the territorial integrity, sovereignty and independence of Ukraine now target a total of over 2,400 individuals and entities.

Economic sanctions

• Sanctions on the financial sector, including:
  • significant restrictions on Russia’s access to EU capital markets and services;
  • the disconnecting of key Russian banks from the SWIFT (Society for Worldwide Interbank Financial Telecommunication) system;
  • a ban on providing any credit-rating services, crypto-assets, advice on trusts and financial assistance for trade or investment, and a full transaction ban on key Russian banks;
  • a prohibition on EU nationals holding any posts in the governing bodies of any Russian state-owned or -controlled legal persons, entities or bodies established in Russia;
  • a prohibition on Russian nationals or natural persons residing in Russia holding any posts in the governing bodies of the owners/operators of critical infrastructure¹, European critical infrastructure²</sup> or critical entities;
  • sanctions on financial institutions using the Russian SPFS (system for transferring financial messages) to circumvent restrictive measures and the prohibition on EU banks using the system and, since February 2025, a transaction ban on credit or financial institutions outside Russia using the SPFS;
  • sanctions on Garantex, a Russian-based cryptocurrency exchange.
• Sanctions on the energy sector, including bans on:
  • Russian coal and other solid fossil fuels;
  • the import, purchase or transfer from Russia of crude oil and refined petroleum products above a fixed price known as the oil price cap (with limited temporary exceptions for certain heavily dependent EU Member States);
  • the export of jet fuel to Russia;
  • new investments in the Russian mining sector;
  • providing gas storage capacity to Russian nationals, natural persons residing in Russia or legal persons, entities or bodies established in Russia;
  • liquefied natural gas re-export, along with a prohibition on investing in Russian liquefied natural gas projects;
  • the import of liquefied propane, which came into force on 20 December 2024.
• Sanctions on airspace, maritime and road transport, including:
  • a ban on the export, sale, supply or transfer to Russia of all aircraft, aircraft parts and equipment, along with goods used in the aviation sector;
  • the closure of EU airspace to all Russian-owned, -registered or -controlled aircraft, including the private jets of oligarchs;
  • a ban on the export of maritime navigation goods and radio communication technology to Russia;
  • a ban on Russian vessels accessing EU ports or locks;
  • the listing of 27 additional vessels, which have been prohibited from accessing EU ports and locks (including related services) to tackle the so-called shadow fleet;
  • a ban on Russian or Belarusian road transport operators entering the EU;
  • a road transport ban on EU operators owned by Russian individuals;
  • a ban on transactions with the Russian Maritime Register of Shipping;
  • a ban on landing in, taking off from or overflying EU territory for both manned and unmanned Russian aircraft;
  • a ban on direct exports of drone engines to Russia;
  • an obligation for aircraft operators of non-scheduled flights between Russia and the EU or over EU airspace, operated directly by or via a non-EU country, to provide all relevant information concerning the flight to their competent authorities upon request by the competent Member State;
  • a ban on non-EU tankers that are part of Russia’s shadow fleet circumventing the oil price cap mechanism, support Russia’s energy sector or transport military equipment for Russia or grain stolen from Ukraine.
• Sanctions on diamonds, including:
  • the EU’s December 2023 package of measures prohibiting the direct or indirect import, purchase or transfer from Russia of non-industrial natural and synthetic diamonds, along with diamond jewellery, as of 1 January 2024;
  • the June 2024 package providing for a Russian diamond indirect import ban, for which the entry into force is to be coordinated with the Group of Seven.
• Sanctions on export control and export financing, including:
  • a comprehensive export restriction on equipment, technology and services for the energy industry in Russia (with some exceptions);
  • a restriction on the export of euro-denominated banknotes and the sale of euro-denominated transferable securities;
  • a restriction on items that may contribute to Russia’s military and technological, defence and security sectors;
  • an obligation for EU parent companies to make their best efforts to ensure that their subsidiaries in non-EU countries comply with EU sanctions.
• An arms embargo, including:
  • a prohibition on selling, supplying, transferring or exporting arms and related materiel of all types to Russia;
  • export bans on civilian firearms;
  • a prohibition on the transit via the Russian territory of firearms, their parts and essential components and on ammunition exported from the EU.
• Sanctions on dual-use goods and advanced technology items, including the following.
  • Export prohibitions for dual-use goods and other advanced goods and technology that might contribute to Russia’s technological enhancement of its defence and security sector.
  • A list of restricted items, including drone engines, further chemical and biological equipment, riot control agents and electronic components, generators, toy drones, laptops, hard drives, IT components, night-vision and radio-navigation equipment, cameras, lenses, rare earth elements and compounds, electronic integrated circuits, thermographic cameras, electronic components, semiconductor materials, manufacturing and testing equipment for electronic integrated circuits and printed circuit boards, precursors to energetic materials, precursors to chemical weapons, optical components, navigational instruments, metals used in the defence sector and marine equipment.
  • Chemicals, including manganese ores and compounds of rare earth elements, plastics, excavating machinery, monitors and electrical equipment, were also restricted by the 14th package.
  • The introduction of a no-Russia clause for EU exporters through which they contractually prohibit the re-exportation of sensitive goods and technology (including battlefield items) to Russia.
  • A prohibition on transit via the territory of Russia of dual-use goods and technology exported from the EU to minimise the risk of EU sanctions being circumvented, along with goods and technology that may contribute to Russia’s military and technological enhancement or to the development of the defence or security sector, goods and technology suited for use in the aviation or space industries, and jet fuel and fuel additives exported from the EU to non-EU countries. The December 2023 package extended the transit ban to all battlefield goods.
  • The June 2023 package added 87 entities to the list of those directly supporting Russia’s military–industrial complex in its war of aggression against Ukraine – the list includes entities in non-EU countries producing and exporting drones to Russia, along with others involved in circumventing sanctions and supplying electronic components to Russia.
  • The December 2023 package required EU exporters to contractually prohibit the re-exportation to Russia and re-exportation for use in Russia of particularly sensitive goods and technology when selling, supplying, transferring or exporting them to a non-EU country, with the exception of partner countries. This requirement relates to prohibited items used in Russian military systems found on the battlefield in Ukraine or critical to the development, production or use of those Russian military systems, along with aviation goods and weapons.
  • The December 2023 package also extended the list of restricted items that could contribute to enhancing Russia’s defence and security sector to cover chemicals, lithium batteries, thermostats, DC motors and servomotors for unmanned aerial vehicles (UAVs), machine tools and machinery parts.
• Trade restrictions and bans on goods, including iron, steel, coal, cement, bitumen and asphalt, carbon, synthetic rubber, seafood, helium, Russian-origin gold and other luxury goods.
• An export ban on products in areas where Russia has a high dependency on the EU (including semiconductors, sensitive machinery, transportation and chemicals).
• A prohibition on providing accounting, auditing, statutory audit, bookkeeping and tax consulting services, business and management consulting, public relations services, architectural and engineering services, IT consultancy services and legal advisory services to the Russian government and to legal persons, entities or bodies established in Russia. The December 2023 package extended this list to include software for company management and for industrial design and manufacture.
• A prohibition on providing advertising, market research and public opinion polling services, along with product testing and technical inspection services.
• A prohibition on transporting goods into the EU by road via trailers and semi-trailers registered in Russia, including when hauled by trucks registered outside of Russia.
• A prohibition on access to EU ports and locks by any vessels that engage in ship-to-ship transfers, if the competent authorities have reasonable cause to suspect that the vessel is either in breach of the ban on importing seaborne Russian crude oil or petroleum products into the EU or transporting Russian crude oil or petroleum products purchased above the price cap agreed by the Price Cap Coalition.
• An import ban on goods from areas of Ukraine not under government control, including the oblasts of Donetsk, Luhansk, Zaporizhia and Kherson, and from illegally annexed Crimea and Sevastopol.
• An import ban on goods that generate significant revenue for Russia (thus enabling its war of aggression against Ukraine to continue), such as pig iron and spiegeleisen (an alloy of iron and manganese used in steel-making), copper wires, aluminium wires, foil, tubes and pipes.
• A ban on purchasing, importing, transferring or exporting Ukrainian cultural property goods and other goods of archaeological, historical, cultural, rare scientific or religious importance for which there are reasonable grounds to suspect that the goods have been unlawfully removed from Ukraine.

A circumvention tool

The tool was introduced as part of the June 2023 sanctions package to address the growing circumventing of EU sanctions. To deprive Russia of the resources that allow it to pursue its war of aggression against Ukraine, the tool takes the form of taking appropriate individual measures to address the involvement of non-EU-country operators in facilitating circumvention. Thereafter, where substantial and systemic circumvention persists, the EU has the possibility to take exceptional, last-resort measures. When this arises, the Council of the European Union may unanimously decide to restrict the sale, supply, transfer or export of goods and technology the export of which to Russia is already prohibited in relation to non-EU countries whose jurisdictions are demonstrated to be at a continuing and particularly high risk of being used for circumvention. To further hinder circumvention, the December 2023 package also banned Russian nationals from owning, controlling or holding any posts on the governing bodies of legal persons, entities or bodies providing crypto-asset wallets, accounts or custody services to Russian persons and residents.

Restrictions on Russian media

These restrictions include the suspension of transmission, distribution and broadcasting by a number of Russian-state-owned entities in order to curb systematic propaganda, media manipulation and disinformation. The June 2024 sanctions package suspended the broadcasting licences of four further organisations for their continuous and concerted propaganda initiatives targeted at EU civil society and neighbouring countries, gravely distorting and manipulating facts. The package also introduced measures banning financial support for political parties, non-governmental organisations, think tanks and media services coming from Russia and its affiliates, in order to combat Russian interference and propaganda.

Sanctions on Belarus

These were introduced in view of the situation in that country and the involvement of Belarus in the Russian aggression against Ukraine (see summary).

• Swiftly after the adoption of the 14th sanctions package against Russia, a Belarus alignment package was adopted on 29 June 2024. The sanctions on Belarus largely reproduced the sectoral measures taken against Russia in order to close existing loopholes and to limit circumvention possibilities. The package included an export ban on dual-use and advanced goods and technologies, along with import prohibitions on gold, diamonds, helium, coal and mineral products, including crude oil. It also broadens the road transport ban and mirrors the best-efforts clause for EU operators’ subsidiaries in non-EU countries. Lastly, it added a no-Belarus clause for EU exporters.
• A further package of sanctions on Belarus, adopted in parallel with the 16th sanctions package on Russia, expanded the list of exports that might advantage Belarus’s military and industrial capacity to include items such as chemical precursors to riot control agents, software related to computer numerical control machines, chromium ores and compounds, controllers used to guide UAVs, pyrotechnic goods and combustible materials.

Sanctions on Iranian individuals and entities

These were introduced in view of the participants’ roles in developing and delivering UAVs used by Russia in its war against Ukraine.

• On 20 July 2023, the Council established a new framework for restrictive measures in view of Iran’s military support for Russia’s war of aggression against Ukraine, which prohibits the export from the EU to Iran of components used in the construction and production of UAVs and provides for travel restrictions and asset-freezing measures that could be imposed against individuals responsible for, supporting or involved in Iran’s UAV programme (see summary). This new sanctions regime complements the three previously adopted packages of drone-related sanctions targeting individuals and entities. On the same day, the Council also decided to list six Iranian individuals under two already existing sanctions regimes for Iran’s military support for Russia’s war of aggression against Ukraine (drones) and for the Syrian regime (air defence systems).
• On 31 May 2024, the Council adopted restrictive measures against six individuals and three entities for their roles in the transfer of UAVs to Russia in support of its war of aggression against Ukraine or the transfer of UAVs or missiles to armed groups and entities undermining peace and security in the Middle East and the Red Sea region, or for being involved in Iran’s UAV programme.
• On 24 June 2024, one Iranian entity was listed due to its involvement in Iran’s UAV and missile programmes and in transferring Iranian UAVs to Russia in support of its war of aggression against Ukraine.

Diplomatic measures

These include suspending visa-free travel for diplomats and visa facilitation for service passport holders and businesspeople.

Exemptions

• To safeguard global food and energy security, sanctions do not target Russia’s exports of agricultural and food products, including wheat and fertilisers, or the supply of oil and petroleum products to non-EU countries.
• The assets of certain individuals who held a significant role in international trade in agricultural and food products, including wheat and fertilisers, prior to their listing can be unfrozen; funds and economic resources can also be made available to them.
• EU sanctions do not prevent non-EU countries and their nationals outside of the EU from purchasing pharmaceutical or medical products from Russia.
• An emergency clause allows the transport of oil beyond the price cap, the provision of technical assistance, brokering or financing services, or financial assistance related to its transport to non-EU countries, to urgently prevent or mitigate events likely to have a serious impact on human health and safety or the environment, or as a response to natural disasters.

Annexes to the various decisions and regulations include the lists of the individuals, entities, bodies, goods and technology impacted by the restrictive measures.