On 20 May 2025, the Council of the European Union adopted its 17th package of sanctions against Russia, reinforcing the EU’s ongoing response to Russia’s war of aggression against Ukraine. The new package is relatively targeted in scope, introducing new asset freezing designations and limited additional trade controls restrictions.
The EU has emphasized that it is poised to adopt further restrictive measures if (as seems likely) ceasefire negotiations with Russia fail to deliver tangible progress, although the scope and timing of those measures remain unclear.
The EU’s action regarding Russia forms part of a broader, coordinated effort with international partners. On the same day, the UK government also announced 100 new asset freezing designations against individuals, companies and ships.
The EU’s 17th Package of Sanctions Targeting Russia
Asset-Freezing Sanctions
The EU’s 17th sanctions package primarily consists of new asset freezing designations, adopted under multiple EU sanctions regulations within the EU Russia sanctions framework, including three individual EU Russia asset-freezing regulations, and a separate EU sanctions regulations focused on the proliferation of chemical weapons. These designations target a wide range of individuals and entities across different sectors of the Russian economy, as well as actors in third countries involved in sanctions circumvention or contributing to the war effort. Of particular note, the new designations include JSC Volga Shipping (one of Russia’s largest shipping companies), Atlas Mining LLC (a major entity in the Russian mining sector), PJSC Surgutneftegaz (a large Russian energy company), JSC VSK (which provides insurance for the Russian energy sector), and Voice of Europe (a significant Russian media content provider).
The new designations were implemented pursuant to the following amending regulations:
New EU Sectoral Restrictions
The new EU sanctions package also includes a limited set of new trade restrictions concerning Russia. These are set out in Council Regulation (EU) 2025/932, which amends Regulation (EU) No 833/2014 (“Regulation 833”) – the EU’s primary regulation governing sectoral sanctions against Russia. The new measures include the following:
- Port Ban & Maritime Service Restrictions: The EU has expanded the list of vessels (Annex XLII) subject to the port ban and related service prohibitions set out in Article 3s of Regulation 833. 189 additional vessels associated with Russia’s so-called “shadow fleet” have been designated;
- Export Restrictions on Dual-Use and Advanced Technology Items: 31 new entities have been added to Annex IV – subjecting them to enhanced export restrictions on dual-use and advanced technology items listed in Annex VII to Regulation 833. This includes 18 entities in Russia, and 13 entities in third countries, including Serbia, Türkiye, the UAE, Uzbekistan, and Vietnam; and
- Export restrictions: Annex VII has been updated to subject further advanced technology items to trade controls under Article 2a of Regulation 833, such as chemical precursors for energetic materials, and components and spare parts for machine tools.
Moreover, Council Regulation (EU) 2025/964 amends the EU’s Russia hybrid threats sanctions regime (Council Regulation (EU) 2024/2642), to include a framework for imposing further trade sanctions, as follows:
- Restrictions on dealings in certain designated tangible Russian assets.These assets will be identified in a new Annex III to Regulation 2024/2642;
- A transaction ban targeting dealings with entities, entities who are designated in the future for providing crypto-asset services for the benefit of parties designated under Annex IV to Regulation 2024/2642; and
- A prohibition on providing broadcasting-related services concerning media content of entities to be designated in Annex V to Regulation 2024/2642.
The regulation establishes only the legal basis for applying these restrictions — no parties or assets have thus far been designated under these new measures.
New UK Sanctions
New asset freezing designations
On 20 May 2025, the UK government announced 100 new asset freezing designations against individuals, companies and ships.
Of the 62 newly designated entities, 42 are financial institutions the UK government understands to have assisted in the evasion of sanctions, including the Russian Deposit Insurance Agency, the St. Petersburg Currency Exchange, and the Non-bank Credit Organization Joint-Stock Company Petersburg Settlement Centre. The Office of Financial Sanctions Implementation (OFSI) has issued two new general licences: the first to permit insurance premium payments to the Russian Deposit Insurance Agency, and the second to enable wind-down transactions involving the St. Petersburg Currency Exchange and the Non-bank Credit Organization Joint-Stock Company Petersburg Settlement Centre.
As part of its continuing efforts to curtail the “shadow fleet” of tankers involved in the trade of Russian oil, the UK also has designated 18 new ships and added individuals believed to be supporting the “shadow fleet” to the UK sanctions list, such as British national John Michael Ormerod. This follows the addition of around 100 ships to the UK sanctions list on 9 May 2025.
Also among the newly designated individuals are 14 members of the Social Design Agency (SDA), a Kremlin-funded body that is believed to carry out worldwide information operations seeking to undermine democracies.
UK to expand whistleblower law to cover sanctions-related matters
On 21 May 2025, the UK government laid the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 before Parliament, aiming to “strengthen the implementation and enforcement of UK sanctions”. This amendment will extend whistleblower protections to individuals who make disclosures to UK sanctions authorities about individuals or businesses they suspect of breaching certain UK financial, trade, and transport sanctions. The amendment will enter into force on 26 June 2025.
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We are closely monitoring developments concerning the U.S., UK, and EU sanctions against Russia, and will issue further updates in the event of material developments. In the meantime, we would be happy to address any questions you may have.
Covington’s International Trade Controls team—which includes lawyers in the firm’s offices in the United States, London, Brussels, and Frankfurt—regularly advises clients across business sectors, and is well-placed to provide support in connection with the evolving Russia sanctions and export controls. Our trade controls lawyers also work regularly with Covington's Global Public Policy team—consisting of over 120 former diplomats and policymakers in the United States, Europe, the Middle East, Latin America, Africa, and Asia—many of whom have had substantial government experience in sanctions and export controls matters, and who regularly advise our clients on emerging sanctions policy matters and related engagements with government stakeholders. Moreover, as the Ukraine crisis continues to unfold, Covington is exceptionally well-positioned to assist clients in navigating their most complex challenges, drawing on the multidisciplinary capabilities of additional practices in areas such as international arbitration and disputes, cybersecurity, anti-money laundering, insurance, and corporate restructuring.
If you have any questions concerning the material discussed in this client alert, please contact the members of our International Trade Controls or International Dispute Resolution practice.
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