On December 16, 2024, the European Union (EU) introduced its 15th sanctions package targeting Russia, marking an update to Regulations (EU) 833/2014 and (EU) 269/2014. This package also includes the first designations under the EU’s “hybrid threats” sanctions framework, launched in October 2024, as well as further designations related to Belarus under Regulation (EC) No 765/2006. These measures came into effect on December 17, 2024.
The sanctions package, while narrower in scope compared to previous measures, introduces several new provisions, including:
- Extension of Divestment Deadlines: The EU has extended the deadline for certain derogations related to the divestment of business activities in Russia from December 31, 2024, to December 31, 2025. This extension is intended to facilitate an orderly exit for EU businesses.
- CSD Derogation and “No Liability” Clause: New provisions allow for the release of certain cash balances held by EU central securities depositories (CSDs) to meet legal obligations to non-sanctioned clients. A “no liability” clause has also been introduced to protect CSDs from legal liability when fulfilling their obligations in good faith under sanctions.
- Prohibition on Recognition of Russian Court Rulings: The EU has banned the recognition and enforcement of rulings from Russian courts based on Article 248 of Russia’s Arbitration Procedure Code. These rulings have previously been used to impose high penalties on Western companies.
- Anti-Circumvention Measures: The EU has expanded its list of vessels banned from entering EU ports. The latest sanctions target 52 additional non-EU tankers linked to circumventing the oil price cap or transporting military equipment and Ukrainian grain. A total of 79 vessels are now subject to these measures.
- Additional Sanctions Listings: 54 individuals and 30 entities have been added to the EU sanctions list, including military personnel, energy sector executives, and companies linked to Russia’s military-industrial complex. New sanctions also target individuals and entities accused of supporting the Russian regime, including those supplying drone components and microelectronics to Russia.
- Hybrid Threats Designations: The EU has sanctioned 16 individuals and three entities involved in activities such as disinformation campaigns, cyber-attacks, and covert influence operations aimed at destabilizing Ukraine, Western Europe, and Africa.
- Sanctions on Belarus: The EU has imposed asset freezes and travel bans on 26 Belarusian and Russian individuals, including judges and prison officials accused of human rights violations, as well as two Belarusian entities linked to the repression of political dissent.
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