On 20 May 2025, the European Union adopted its 17th sanctions package in response to Russia’s ongoing war against Ukraine. Building on the extensive measures already in place, this package signals a further tightening of economic and legal pressure points, with over 2,400 individuals and entities now sanctioned. Notably, the package reflects a growing willingness by the EU to extend its sanctions regime not only in scope but in geographic and sectoral reach. This blog post provides a comprehensive overview of the specifics of the 17th sanctions package, as well as what to expect in regard to the 18th sanctions package, which is already being drafted.
1. Targeting the Shadow Fleet
A main element of this package is the designation of 189 vessels, primarily oil tankers, to the EU’s sanctions list. These vessels are part of Russia’s so-called ‘shadow fleet’ – a loosely affiliated network of ships accused of circumventing the oil price cap and other transport restrictions. These tankers often operate under opaque ownership structures, use flags of convenience, and obscure their location data. The inclusion of these vessels brings the total number of ships designated under EU sanctions to 342.
Importantly, these sanctions are not limited to direct asset freezes. In addition, the EU has prohibited the provision of a broad range of services to these vessels, from insurance to port access. These additions show that the EU is willing to extend sanctions to the operational enablers of illicit trade where necessary, with the goal being not only to restrict Russia’s oil revenues but also to dismantle the logistical and financial support structures that underpin the shadow fleet’s activities.
2. Energy Sector
Energy continues to be a strategic pressure point for the EU. With the 17th package, the EU has sanctioned major Russian energy actors including Surgutneftegaz and Litasco’s Dubai-based shipping subsidiary, Eiger Shipping DMCC. [see our previous blog post on US and UK designating Surgutneftegas in January] These companies play a crucial role in sustaining Russia’s oil exports and associated revenues. By targeting them, the EU aims to cut off capital streams that fund military operations.
What is particularly notable is the deliberate expansion of designations beyond Russian borders. Designating a third-country subsidiary such as Eiger demonstrates the EU’s readiness to take action where corporate structures may be used to circumvent restrictions and marks a step toward a more extraterritorial approach – something previously approached with caution by EU institutions.
3. Military-Industrial Complex
The 17th package also includes new restrictions on more than 45 entities and individuals involved in Russia’s military-industrial complex. These include producers of weapons, ammunition, and dual-use technologies, as well as entities that provide critical components, logistical support, and technological know-how. In addition, the EU imposed tighter export restrictions concerning dual-use goods and technologies on 31 entities involved in Russia’s military-industrial complex. Notably, several of these newly sanctioned actors are based in third countries, such as Israel, Turkey, Uzbekistan, the UAE, and Vietnam. Where past sanctions often stopped short of targeting non-Russian enablers, the 17th package extends to entities believed to facilitate Russia’s war economy, regardless of nationality.
The EU has also implemented additional export restrictions targeting goods that contribute to the enhancement of Russia’s military and technological capabilities, the development of its defense and security sector, and the production of its military systems. These restrictions include controls on chemical precursors used in energetic materials, as well as spare parts for machine tools essential to military manufacturing.
4. Hybrid Warfare and Human Rights
The package also contains a hybrid threat component that addresses both human rights violations and information warfare. In addition to individuals involved in domestic repression – such as judges involved in
the persecution of the late opposition leader Alexei Navalny and his associates – the EU also sanctioned more than 20 entities linked to cyber operations and destabilizing activities across Europe. These entities include cyber actors responsible for attacks on European institutions and state-linked organizations involved in the coordination of disinformation campaigns. The addition of these actors illustrates the EU’s increasingly integrated approach to security – treating cyber operations and influence campaigns as threats on par with conventional warfare.
5. Outlook: Toward a Broader Sanctions Architecture
The 17th sanctions package comes amid growing speculation about the scope and timing of an 18th package. EU sanctions regimes typically follow a three- to six-month review cycle, but political developments – including stalled ceasefire negotiations and US pressure – may accelerate this timeline. German Chancellor Merz has publicly confirmed that preparatory work for the next package is already underway.
The 18th package is expected to include both symbolic and substantive measures, such as the potential designation of the Nord Stream pipelines, as well as financial sanctions coordinated with the United States. For example, proposed US legislation would impose tariffs of up to 500% on countries that continue to import Russian energy products. The EU may follow with complementary restrictions, specifically targeting financial institutions that support such trade.
Of particular significance to a potential 18th package is the structure of Regulation (EU) 2025/964, which introduces novel enforcement tools. First, it is legally configured to target specific assets rather than imposing general asset freezes on listed persons. In regard to the potential imposition of sanctions on financial institutions, it does not make any reference to the institutions having to be Russian, which suggests a deliberate openness to listing entities based in third countries. At the moment however, the relevant annexes remain empty, making this a potential addition in the 18th sanctions package.
