22 May '25
In our blog of 24 February 2025, we reflected on three years of war in Ukraine. A central focus was the vast number of sanctions that have since been implemented, which companies must comply with. The adoption of the seventeenth sanctions package by the European Union this past Tuesday shows that the flow of new measures has by no means come to an end. This package once again includes serious restrictions and expansions, which could have significant implications for many organisations. In this blog, we outline the key components of the new sanctions package.
One of the most striking measures is the expansion of the list of sanctioned vessels. An additional 189 ships, mostly oil tankers, have now been added to this list. This so-called ‘shadow fleet’ is used to circumvent existing sanctions and transport stolen goods – such as Ukrainian grain. These ships are now:
A total of 342 vessels are now subject to sanctions.
The EU sanctions list has also been expanded to include 17 individuals and 58 legal entities that actively support Russia’s war efforts. Notable additions include:
These entities are now subject to the following measures:
To further cut Russia off from military and technological support, the EU is extending its export ban on strategically sensitive goods and technologies. Newly added items include:
Additionally, 31 new entities have been added to the list of parties subject to tighter export controls on dual-use goods and technologies, due to their support for the Russian military-industrial complex in its war against Ukraine. Some of these entities are based in third countries, such as Turkey, Vietnam, and the United Arab Emirates.
Lastly, the sanctions package extends an existing exemption: the transport of crude oil from the Sakhalin-2 project in Russia to Japan remains permitted – for now, until 28 June 2026.
As outlined above, the new sanctions package significantly expands the existing regime. This increases the likelihood that your organisation – directly or indirectly – may be affected. Would you like to understand what these new rules mean in concrete terms for your business? And whether you remain fully compliant under the revised sanctions framework? If so, please contact Jikke Biermasz or Zoë Poortvliet.
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