On 20 May 2025, the EU approved what is now its 17th sanctions package in response to Russia’s war of aggression against Ukraine. The new package aims to restrict Russia’s access to important military technology and further reduce its energy revenues. To do so, it imposes restrictions on Russia’s shadow fleet – cargo vessels transporting goods including oil and oil products in violation of sanctions, often under false flags and with vessel tracking systems disabled. But while the new sanctions package again expands existing restrictions, it largely avoids introducing new sanctions instruments and does not materially toughen the existing sanctions regime against Russia.
The 17th sanctions package was partly adopted in response to the failure to achieve the Ukraine ceasefire called for by Germany, France and Poland. It builds on the 16th sanctions package, which also targeted Russia’s shadow fleet, financial institutions, and persons connected to Russia’s military-industrial complex. However, the 17th sanctions package does not qualitatively toughen the sanctions against Russia.
The 17th sanctions package incorporates the following acts:
- Amending Regulation (EU) 2025/932 amends the largely trade-related sanctions set out in Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.
- Implementing Regulation (EU) 2025/933 implementing Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine – which largely contains personal financial sanctions – adds additional persons and entities to its Annex I.
- Implementing Regulation (EU) 2025/958, which adds to the Annex IV to Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation of Russia, also expands personal financial sanctions.
- The 17th sanctions package also features Implementing Regulation (EU) 205/965 and Regulation (EU) 2025/964, which both amend Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities.
The following changes to the sanctions regime are particularly noteworthy:
Tougher sanctions against Russia’s shadow fleet
The EU has amended Regulation (EU) 833/2014 to address Russia’s ongoing use of its shadow fleet to bypass sanctions and transport key resources such as oil and oil products. The new sanctions package targets an additional 189 ships from third countries, increasing the number of sanctioned ships listed in Annex XLII to 342. According to Article 3s Regulation (EU) 833/2014, which remains unchanged, it is prohibited to grant these ships access to ports in the EU or to provide various other services for listed vessels.
In addition to these measures targeting ships, individual financial sanctions against operators of the shadow fleet have been added to the list in Annex I Regulation (EU) 269/2014. This specifically targets shipping companies responsible for transporting crude oil and oil products by sea in circumvention of the sanctions regime, including companies from Turkey and the United Arab Emirates.
Expansion of export-related restrictions
The expansion of export bans has been limited to adding specific items to Annex VII to Regulation (EU) 833/2014 that bolster Russia’s military and technological capabilities, contribute to the development of its defence and security sector or are used in the production of military systems. In particular chemical precursors to energetic materials and spare parts for machine tools have been added.
Action against Russia’s military-industrial complex
A further 31 entities have been added to Annex IV to Regulation (EU) 833/2014 for their role in supporting Russia’s army and military industry, for example for supplying unmanned aerial vehicles (UAVs). Some of the entities are based in third countries such as Turkey and Vietnam. Following the amendments to Article 2b Regulation (EU) 833/2014, any entity listed in Annex IV is now subject to a separate export ban on dual-use goods and goods listed in Annex VII to Regulation (EU) 833/2014 (see our article on the 16th sanctions package).
New personal sanctions
By expanding the lists in Annex I to Regulation (EU) 269/2014, Annex IV to Regulation (EU) 2024/1485 and Annex I to Regulation (EU) 2018/1542, the 17th sanctions package imposes personal sanctions on a number of additional persons, entities and bodies. Their assets in the EU are being frozen, no funds or economic resources may be made available to them and they are prohibited from entering the EU.
Annex I to Regulation (EU) 269/2014 now includes Surgutneftgaz, one of Russia’s most important oil companies, and JSC Volga Shipping, one of the leading Russian shipping companies. However, these are the only sanctions in the latest sanctions package that directly affect the Russian energy sector. No import or export bans targeting the energy sector have been added.
The additions to Annex IV to Regulation (EU) 2024/1485 mainly concern members of the Russian judiciary and prosecution authorities, including those involved in the persecution and prosecution of opposition politician Alexei Navalny, who died in February 2024.
Russian entities allegedly involved in the development or use of chemical weapons were also added to Annex I to Regulation (EU) 2018/1542 concerning restrictive measures against the proliferation and use of chemical weapons.
Expansion of EU sanctions against Russia’s destabilising activities
Regulation (EU) 2024/2642 is the only regulation to which the 17th sanctions package adds new prohibitions. This regulation was previously limited to personal financial sanctions but has now been expanded to include transaction bans and measures aimed at countering the dissemination of misinformation (e.g. by revoking broadcasting licences).
Newly added Article 1a Regulation (EU) 2024/2642 prohibits EU persons from engaging, directly or indirectly, in transactions relating to or affecting listed tangible assets including vessels, aircraft, real estate, ports, airports and physical elements of digital and communication networks. Crucially, it sanctions transactions concerning specific assets and not contract partners or persons involved. However, because Annex III does not yet list any assets, the ban is not yet enforceable. Once tangible assets have been listed, the scope of the transaction ban will need to be clarified. To date, transaction bans under the Russia embargo have applied exclusively to transactions involving specifically listed individuals or entities.
The 17th sanctions package also expands Article 1b Regulation (EU) 2024/2642, which prohibits transactions with the financial institutions and crypto-asset service providers listed in Annex IV – also currently empty – that support Russia’s destabilising activities.
This introduction of new sanctions is accompanied by additions to Annex I Regulation (EU) 2024/2642, making more persons subject to financial sanctions including persons involved in disseminating Russian propaganda and parties who undermine the democratic process in Estonia and Germany. Two fishing companies have also been sanctioned in connection with espionage and sabotage targeting critical infrastructure.
Outlook
Most of the 17th sanctions package came into force on the day of its publication, 20 May 2025. The amendments to Regulation (EU) 2024/2642 took effect the next day. The only new prohibitions introduced by the package are found in Regulation (EU) 2024/2642. Otherwise, the package is limited to additions to existing annexes, expanding the scope of existing sanctions instruments. It is therefore likely to have fewer serious implications for EU companies than previous packages.
While the significantly tougher sanctions regime that had been anticipated has failed to materialise so far, the EU is already working on proposals to end the import of fossil fuels from Russia as part of the “RePowerEU Roadmap”. Concrete legislative proposals are expected in June. Work has also already begun on an 18th sanctions package. On 17 May 2025, Commission President von der Leyen raised the prospect of this including sanctions targeting Nord Stream and Nord Stream 2, stating that the idea was to dissuade any interest, notably interest from investors, from pursuing any activity in connection with Nord Stream and Nord Stream 2 in future. It remains to be seen what specific sanctions might be adopted to that end. According to diplomatic sources, discussions are also underway about lowering the oil price cap for Russian crude oil from its current level of USD 60.
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