On the 16 December 2024, the European Council adopted the 15th package of sanctions against Russia, through which various restrictive measures were imposed. These measures are designed to address the circumvention of EU sanctions through targeting of Putin’s shadow fleet and weaken Russia’s military and industrial sectors. The key provisions of the 15th package are as follows:

84 new designations, comprising of 54 individuals and 30 legal entities

  • The individuals and entities designated under the 15th package are responsible for actions undermining the territorial integrity, sovereignty, and independence of Ukraine.
  • Restrictive measures include asset freezes, and travel bans for individuals.
  • Targets of the designations include Russian military companies producing aircraft parts, drones, electronics, engines, and high-tech weapon components, along with senior managers in the energy and shipping sectors.
  • Additionally, designations include the military unit behind the Okhmadyt children’s hospital strike in Kyiv and individuals involved in child deportation and propaganda.
  • The EU has, for the first time, imposed fully-fledged sanctions (travel ban, asset freeze, prohibition to make economic resources available) on Chinese actors supplying drone components and microelectronic components to Russia for use in its invasion of Ukraine.

Anti-Circumvention Measures

  • The Council has listed 52 vessels which are now subject to port access restrictions and a wide range of service bans related to maritime transport, therefore bringing the total number of listed vessels to 79.
  • This measure targets non-EU tankers involved in circumventing the oil price cap, supporting Russia’s energy sector, transporting military equipment for Russia, or carrying stolen Ukrainian grain as part of Putin’s shadow fleet.

Trade Measures

  • The Council has added 32 legal entities to the list of entities actively supporting Russia’s military, as it continues its war against Ukraine.
  • These entities will face stricter export controls on dual-use goods and technologies, as well as items that could enhance Russia’s defence and security capabilities.

Protection of EU Companies

  • To safeguard European companies from litigation with Russian counterparts, the Council has prohibited the recognition or enforcement within the EU of rulings issued by Russian courts under Article 248 of the Russian Arbitration Procedure Code.
  • These rulings, often imposing disproportionately high financial penalties on European businesses, have blocked parties from pursuing or continuing proceedings outside Russia (anti-suit injunctions), violating established international norms. This measure ensures such penalties cannot be executed against EU operators in Europe.

Derogation for Central Securities Depositories (CSDs)

  • The Council also introduced a derogation permitting the release of cash balances held by EU central securities depositories (CSDs). This is in response to increasing litigation and retaliatory actions in Russia, which have led to asset seizures involving EU-based CSDs. Under this derogation, CSDs can seek approval from Member States to unfreeze cash balances and use them to fulfill their legal obligations to clients.

Extended Deadlines for Divestments

  • The EU has extended deadlines for certain derogations related to divestments from Russia, emphasizing the need for EU operators to wind down existing businesses or avoid initiating new ones in Russia due to rising risks. The extended derogations allow for an orderly exit from the Russian market and are granted by Member States on a case-by-case basis, enabling EU operators to complete divestments as efficiently as possible.

The relevant legal acts are:

For guidance on implementation, clarifications, or any other information, please contact us at info@compliancemk.com.