The EU’s 17th sanction package on Russia: Targeting military technology and energy revenues
On 20 May 2025, the European Union (the “EU”) adopted its 17th sanction package against Russia. The new measures include economic and individual restrictive measures aimed at further restraining Russia’s access to key military technology and limiting its energy revenues. In this blog post, we summarize the key elements introduced in the latest sanctions package.
Please find our previous blog posts on the sanctions here, here and here.
Targeting Russia’s Shadow Fleet
Previous Russia sanction packages have enabled the EU to list vessels that support Russia’s warfare against Ukraine to prevent circumvention of sanctions. Listed vessels are subject to port access bans, and prohibitions to provide a wide range of maritime and related services. In its 17th package, the EU has listed 189 additional vessels that are part of Russia’s so-called “shadow fleet”, which is deemed to contribute to the country’s energy revenues. This brings the total number of listed vessels up to 342. These listings aim at restrict Russia’s ability to gain revenues by evading the oil price cap – a measure that limits the price at which Russian oil can be sold when Western services are used.
Additional listings and anti-circumvention measures
The 17th package furthermore imposes new sanctions on over 45 Russian companies and individuals that are deemed to provide the Russian army with drones, weapons, ammunition, military equipment, critical components and logistical support.
In addition, 31 new companies are listed due to their direct or indirect support to Russia’s military or participation in sanctions circumvention. It should specifically be noted that 13 of the listed companies are established in third countries (i.e., not originating from Russia). These countries are Serbia, the United Arab Emirates, Turkey, Vietnam and Uzbekistan. This highlights the importance to always perform a thorough due diligence of counterparties and contractual chains, irrespective of the counterparty’s origin.
The 17th package furthermore includes 75 additional listings of individuals and entities responsible for actions undermining the territorial integrity, sovereignty and independence of Ukraine. These are now subject to asset freezes, and EU citizens and entities are forbidden from making funds or economic resources directly or indirectly available to them. Listed natural persons are also subject to a travel ban, which prevents them from entering and transiting through EU Member States.
The listings also include one Russian shipping company (Joint Stock Company Volga Shipping) important for generating revenue and it also target actors involved in the looting of cultural heritage, and others who were active in occupied territories.
Trade measures related to advanced technology
The sanction package also expands the list of dual use and advanced technology items subject to export restriction. The aim is to further limit Russia’s access to key technologies for military use. This includes technologies such as chemical precursors to energetic material such as sodium chlorate, potassium chlorate, aluminum powder, magnesium powder and boron powder. It also includes spare parts such as ball screws and encoders and components of high-precision Computer Numerical Control (CNC) machine tools.
Concluding remarks
Each of the EU’s sanctions packages further strengthens and enhances the EU’s restrictive measures against Russia by restraining Russia from important economic and military resources. Looking ahead, the 18th sanctions package is expected to be significantly more comprehensive. We will continue to monitor developments and provide updates as the regulatory landscape evolves. In addition, we also provide advice as regards the Swedish sanctioning legislation in case of circumventions which enters into force 10 June 2025, please see our previous blogpost here.