Newsflash: EU adopts 15th package of restrictive measures against Russia – Companies may benefit from wind-down derogations and extended deadlines

On December 16, 2024 the Council adopted a 15th package of restrictive measures with the objective of further limiting Russia’s ability to wage its war of aggression against Ukraine. The new measures entered into force on December 16, 2024 respectively December 17, 2024.

Wind-down derogations

One important aspect of the newly adopted measures is the introduction of additional derogations and extension of deadlines for existing exemptions required for divestments from Russia. In particular, the deadline for applying for an authorization to fulfill claims of Russian persons under Article 11 (4) of the Regulation 833/2014 was extended until December 31, 2025. The exceptional extension of the divestment derogations is necessary to allow EU companies to fully withdraw from the Russian market. Derogations will be granted by Member States on a case-by-case basis and are aimed at allowing an orderly divestment process that would not be possible without the extension of these deadlines. While the sanctions still continue to permit certain business in Russia, the new stipulations clearly emphasize the EU’s recommendation for EU companies to wind-down their business there: “Operators should be aware that Russia is a country where the rule of law is not applied anymore, and that the Russian Federation has adopted several pieces of legislation targeting assets of companies from ‘unfriendly countries’, including Member States. That could lead to Union assets being stranded in Russia without the possibility for orderly withdrawal. Because of the risks of maintaining business activities in Russia, Union operators should consider winding down businesses in Russia and/or not to start new businesses there.” (Recital 9 of Regulation 2024/3192).

Stricter Dual-use export controls to fight circumvention

whether the recipient is listed on an EU sanctions list. A total of 32 new companies have been added to the list of those that support Russia's military and industrial complex. They are subject to stricter export restrictions on dual-use goods and technologies, as well as on goods and technologies that could contribute to the technological improvement of the Russian defence and security sector. Some of these companies are based in third countries (China, India, Iran, Serbia and the United Arab Emirates) and have been involved in circumventing trade restrictions or procuring sensitive goods for Russian military operations, such as drones and missiles.

Russia's circumvention of the sanctions remains a persistent problem. The Council is therefore also increasingly targeting the so-called Russian shadow fleet. These are tankers flying foreign flags that Russia uses to circumvent the oil embargo imposed two years ago. The EU imposed a docking ban on 52 vessels in European ports. This means that a total of 79 tankers are now on a corresponding sanctions list.

Additional financial sanctions

Lastly, the EU added 84 additional listings on the financial sanctions list. These 54 individuals and 30 entities are now subject to asset freezes, and – in the case of individuals – travel bans.

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