New changes to the EU sanctions regime against Russia: strengthening measures and preventing circumvention of sanctions

published on 20 May 2025 | reading time approx. 2 minutes

On 13 May 2025, the Council of the European Union adopted Decision (CFSP) 2025/904, which amends the sanctions regime as set out in Decision 2014/145/CFSP. The amendments concern restrictive measures against Russia in response to actions that threaten or undermine the territorial integrity, sovereignty, or independence of Ukraine.

The main points of the amendments are as follows:

New measures against companies linked to Russian oligarchs

Under the amendments, sanctions have been extended to individuals and legal entities involved in transferring ownership, control, or the economic exploitation of the business interests of leading Russian entrepreneurs who are already on the sanctions lists. The aim is to prevent the circumvention of sanctions through covert transactions and changes to ownership structures.

Making it more difficult to circumvent sanctions

In response to legislative changes introduced by the Russian government to disguise ownership and assets, and restrict access to business registers, the Council has clarified that information collected before 24 February 2022 will continue to apply, unless more recent and reliable data is available.

Long-term sanctions based on changes in corporate structure

Despite possible changes in the ownership structure or positions of Russian entrepreneurs included in the sanctions lists, their status will remain in place as long as there is no convincing evidence that their economic importance or influence has significantly decreased.

Tightening of sanctions to prevent circumvention

It was also decided that individuals manipulating business interests should be included in the sanctions lists to increase pressure on the Russian leadership and urge an end to the military aggression against Ukraine.

The important thing about this new regulation is that it broadens the scope of individuals and entities subject to EU sanctions. This means that participation in the alteration of ownership structures to avoid EU sanctions is also considered a sanctioned activity. Modifications to the ownership structures or positions of individuals added to the list after 24 February 2022 are deemed an attempt to conceal ownership interests or control, thus undermining EU restrictive measures.

Therefore, continuous monitoring of the EU's sanctions list (sanctions screening) is essential in order to detect and prevent transactions involving individuals or entities that have been newly listed under the expanded sanctions criteria. One of the key compliance goals is to prevent such transactions.

Additionally, businesses must exercise enhanced due diligence to ensure they are not engaging with individuals or entities that have attempted to circumvent EU sanctions by restructuring or transferring ownership. This includes verifying the authenticity and transparency of ownership structures, particularly in jurisdictions where public registries may be unreliable or intentionally opaque.

Businesses should also be aware that engaging with entities or individuals that have facilitated the circumvention of EU sanctions may expose them to secondary sanctions or reputational damage; therefore, assessing the risk of indirect involvement in sanctionable activities is strongly recommended.