The EU's 15th Sanctions Package - Renewed Focus on Sanctions Evasion

With Regulation (EU) 2024/3192 of 16 December 2024, the EU has once again extended the sanctions against Russia. The 15th sanctions package again focuses on measures aimed at pre-venting the circumvention of sanctions - in particular by the Russian shadow fleet.

The EU is also imposing comprehensive sanctions against Chinese individuals and entities for the first time. They are alleged to have supplied Russia with military and civilian goods from the European Union and thereby been involved in circumventing trade restrictions.

Measures against the circumvention of sanctions

The unusually high increase in trade with certain products and countries suggests that Russia is deliberately trying to circumvent sanctions. In the past, Russia has managed to do this in particular with the help of its so-called shadow fleet. The shadow fleet includes ships that have been proven to be involved in the transportation of Russian crude oil or Russian crude oil products, arms deliveries, grain theft or support for the Russian energy sector

The 15th sanctions package imposes sanctions on over 52 more ships belonging to the shadow fleet. The sanctioned ships are subject to a ban on access to EU ports and services. This is intended to reduce transportation options and increase the associated costs for Russia

Extension of the sanctions list – listing of actors from China

The 15th sanctions package also includes 84 additional listings: 54 individuals and 30 entities responsible for actions that undermine the territorial integrity, sovereignty and independence of Ukraine.

The listings primarily concern Russian military companies. For the first time since the beginning of the war, the EU has included Chinese individuals and entities in the sanction’s lists. This affects one individual and two entities that enabled the circumvention of EU sanctions, as well as four entities that provided sensitive drone components and microelectronic components to the Russian military industry, thereby supporting Russia's war against Ukraine.

Protection of the interests of economic operators in the EU

The 15th sanctions package also includes a ban on recognizing or enforcing certain decisions of Russian courts (based on Article 248 of the Arbitration Code of the Russian Federation) in the EU. This is intended to protect EU companies from the negative effects of (unlawful) decisions made in Russia.

Outlook

The topic of sanctions will continue to be of interest in 2025. By including Chinese individuals and entities, the EU is consistently continuing the trend towards ever more far-reaching sanctions against Russia. This is supplemented by the provisions of EU Directive 2024/1226, which entered into force last year, defining and tightening criminal offenses and sanctions for violations of restrictive measures. The member states must implement the Directive into national law by 20 May 2025.