Council Regulation (EU) 2025/1494 of 18 July 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty on the Functioning of the European Union, and in particular Article 215 thereof,

Having regard to Council Decision (CFSP) 2025/1495 of 18 July 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (1),

Having regard to the joint proposal from the High Representative of the Union for Foreign Affairs and Security Policy and the European Commission,

Whereas:

(1) On 31 July 2014, the Council adopted Regulation (EU) No 833/2014 (2).

(2) Regulation (EU) No 833/2014 gives effect to certain measures provided for in Council Decision 2014/512/CFSP (3).

(3) Decision 2014/512/CFSP prohibits the sale, supply, transfer or export to Russia of arms and related materiel of all types, and the procurement from Russia of arms and related materiel of all types.

(4) On 18 July 2025, the Council adopted Decision (CFSP) 2025/1495, which amends Decision 2014/512/CFSP.

(5) Decision (CFSP) 2025/1495 adds 26 entities to the list of legal persons, entities or bodies set out in Annex IV to Decision 2014/512/CFSP, namely the list of persons, entities and bodies supporting Russia’s military and industrial complex in its war of aggression against Ukraine, on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector, are imposed. Decision (CFSP) 2025/1495 also includes on that list certain entities in third countries other than Russia that indirectly contribute to Russia’s military and technological enhancement thereby enabling the circumvention of export restrictions, including on unmanned aerial vehicles.

(6) Decision (CFSP) 2025/1495 expands the list of items which might contribute to Russia’s military and technological enhancement or to the development of its defence and security sector by listing items which have been used by Russia in its war of aggression against Ukraine and items which contribute to the development or production of its military systems, including additional computer numerical control machines and constituent chemicals for propellants.

(7) In order to strengthen the effectiveness of the restrictive measures imposed in response to Russia’s war of aggression against Ukraine, it is necessary to address the risk of circumvention of those measures through indirect exports via third countries. Goods and technology listed in Annex VII to Regulation (EU) No 833/2014 might contribute to Russia’s military and technological enhancement or to the development of its defence and security sector, including when exported under the guise of being intended for civilian end-use. The prohibition on indirect exports covers the export of items that are listed in the Annexes to Regulation (EU) No 833/2014, including via a third country. Competent authorities should take timely preventive action where there is a credible risk that such items exported to third countries might ultimately be diverted to Russia. Therefore, Decision (CFSP) 2025/1495 provides Member States with an optional administrative mechanism that enables national competent authorities to require prior authorisation for exports of items listed in Annex VII to Regulation (EU) No 833/2014 to any third country, where the exporter has been informed that there is sufficient reason to suspect that the end destination of the items may be in Russia or that the end-use of the items may be for Russian entities. That measure is not intended to impose a new blanket restriction but to equip Member States with an effective and proportionate tool to investigate and prevent possible circumvention of restrictive measures, while ensuring a harmonised interpretation and legal clarity for exporters. The scope of the indirect export prohibition clause should not be affected by that measure. It is at the discretion of Member States to decide whether that measure or the indirect export prohibition clause is to be applied as a mechanism of enforcement in cases in which the end destination of the items may be in Russia or the end-use of the items may be for Russian entities.

(8) Decision (CFSP) 2025/1495 imposes further restrictions on exports of goods which might contribute to the enhancement of Russian industrial capacities, such as machinery, chemicals, some metals and plastics. In order to minimise the risk of circumvention of restrictive measures, Decision (CFSP) 2025/1495 further extends the list of goods and technology subject to the prohibition on transit via the territory of Russia.

(9) Council Decision (CFSP) 2022/884 (4) and Council Regulation (EU) 2022/879 (5) provide that Member States are to take all necessary measures to obtain supplies which are alternative to imports by pipeline of crude oil from Russia, so that those imports are made subject to the prohibitions as soon as possible. In line with that objective, the temporary derogation granted to Czechia for the supply of crude oil by pipeline from Russia should end.

(10) Decision (CFSP) 2025/1495 imposes a prohibition on the purchase, import, or transfer, directly or indirectly into the Union, of petroleum products obtained in a third country from Russian crude oil, as well as on the provision of related technical or financial assistance. That Decision also introduces a list of partner countries which have a set of restrictive measures that are substantially equivalent to those imposed by the Union on imports of Russian oil and petroleum products. Petroleum products imported from net exporters of crude oil should be considered to have been obtained from domestic crude oil and not from crude oil originating in Russia. The Commission should issue guidance on the implementation of this prohibition, in particular as regards the evidence which should be provided by operators engaged in the import of refined petroleum products.

(11) It is prohibited to import Russian LNG through Union LNG terminals that are not connected to the interconnected natural gas system. Decision (CFSP) 2025/1495 introduces a derogation from the prohibition that can be granted by a Member State that is not directly connected to the interconnected natural gas system of any other Member State and which receives the first commercial supply of its first long-term natural gas supply contract after 20 July 2025 in order to ensure its energy supply. This is without prejudice to any legislative measure impacting energy imports into the Union from Russia.

(12) The scope of the transaction ban set out in Article 5aa(1) of Regulation (EU) No 833/2014 should be interpreted in a broad sense, and should encompass all kinds of transactions. In this context, with regard to the relationship between a Union subsidiary and a Russian parent company listed in Annex XIX to Regulation (EU) No 833/2014, the transaction ban should to a large extent result, in practice, in the de-coupling of the subsidiary from its Russian parent company. Consequently, directly or indirectly obtaining approvals that, under the terms of an intra-corporation agreement or pursuant to another legal requirement, subsidiaries may have to obtain from a listed parent company, or executing instructions given directly or indirectly by a listed parent company, could lead to a subsidiary qualifying as acting on behalf of or at the direction of an entity referred to in Article 5aa(1), point (a) or (b), of Regulation (EU) No 833/2014, and in accordance with point (c) of that paragraph. Consequently, that subsidiary, depending on the specific circumstances, may fall within the scope of the transaction ban. Actions which demonstrate that the subsidiary acts on behalf of or at the direction of a Russian entity include the appointment or dismissal of any authorised representatives of the Union subsidiary, or the receipt of instructions from, or approvals by, an intermediary entity not engaged in operational business activities. As a result of those consequences, a need may arise for measures to safeguard the continuance of a subsidiary acting on behalf of or at the direction of entities referred to in Article 5aa(1), point (a) or (b), of Regulation (EU) No 833/2014, for example by imposing a public trusteeship or a similar firewall measure on such a subsidiary. Such measures may, subject to national law, be imposed or authorised also by the national competent authorities in charge of the relevant sector or area in which the subsidiary operates. Given the importance of the transaction ban in Article 5aa(1) of, and the legal persons, entities and bodies listed in Annex XIX to, Regulation (EU) No 833/2014, it is necessary to apply strict criteria when a public trusteeship or a similar firewall measure is imposed. To ensure the continued functioning of, and compliance with restrictive measures by, subsidiaries acting on behalf of or at the direction of entities referred to in Article 5aa(1), point (a) or (b), of Regulation (EU) No 833/2014, Decision (CFSP) 2025/1495 introduces an exemption from the transaction ban, provided that a competent authority has imposed a public trusteeship or similar public firewall measure or the competent authority has authorised a similar firewall measure. This should be without prejudice to other restrictive measures.

(13) Decision (CFSP) 2025/1495 amends the conditions for imposing a transaction ban on persons, entities or bodies established outside Russia that use the System for Transfer of Financial Messages (SPFS) of the Central Bank of Russia or equivalent specialised financial messaging services set up by the Central Bank of Russia. This is due to the fact that SPFS was set up by Russia as an alternative to a specialised financial messaging service established in the Union and to shield its banks from the impact of restrictive measures that the Union and its allies have adopted since 2014 in response to Russian actions undermining the territorial integrity of Ukraine. The Council considers that, by expanding the use of SPFS outside its territory, Russia seeks to further pursue that strategy and to protect its international trade from the impact of Union restrictive measures, thereby increasing its financial resilience and providing opportunities to facilitate the circumvention of the prohibitions in Regulation (EU) No 833/2014 and Council Regulation (EU) No 269/2014 (6).

(14) In order to clarify certain provisions, Decision (CFSP) 2025/1495 provides for an exemption from the transaction ban on certain ports for Kazakh coal based on the Union’s commitment to prevent negative impacts on energy security of third countries around the globe. Decision (CFSP) 2025/1495 also provides for an exemption from the transaction ban on certain airports with regard to civil nuclear capabilities and facilities.

(15) The pipelines Nord Stream and Nord Stream 2 have been designed to transmit natural gas from Russia to the Union. They are controlled by the Russian Government via state-owned enterprises. Both pipelines were damaged in September 2022 and are currently non-operational. Nord Stream had supplied Russian natural gas to Europe, while Nord Stream 2 never started operations. Russia has repeatedly, unilaterally and, by the end of August 2022, completely disrupted supplies of natural gas through Nord Stream, in order to coerce the Union and its Member States and undermine their support for Ukraine. Moreover, supplying natural gas through those pipelines in the future could generate revenues for Russia, thereby enabling the continuation of its war of aggression against Ukraine. In order to prevent the resumption or the establishment of natural gas supplies through those pipelines, Decision (CFSP) 2025/1495 introduces restrictive measures banning any transaction that is directly or indirectly connected to the natural gas pipelines Nord Stream and Nord Stream 2 and that concerns the completion, operation, maintenance or use of the pipelines or parts of the pipelines. The transaction ban should also cover the purchase of natural gas transported via either pipeline. Targeted exemptions and derogations should apply to ensure that existing control mechanisms over the pipelines via restructuring mechanisms, in particular in connection with Nord Stream AG and Nord Stream 2 AG, remain in place, in order to ensure that the pipelines will not be used.

(16) Decision (CFSP) 2025/1495 expands the transaction ban on third-country credit and financial institutions and crypto assets services providers to include entities that are significantly frustrating the purpose of the prohibitions in Regulation (EU) No 833/2014 and Regulation (EU) No 269/2014. The expansion of the transaction ban also covers third-country financial institutions and crypto assets services providers that support Russia’s war of aggression against Ukraine, including by processing transactions or providing export financing for trade operations that frustrate the purposes of Regulation (EU) No 833/2014. Decision (CFSP) 2025/1495 adds 2 entities to the list of third country financial institutions subject to that ban. Finally, the transaction ban also covers any third-country legal person, entity or body that is not a credit or financial institution or an entity providing crypto assets services, including oil traders, that is significantly frustrating the purpose of the prohibitions set out in Articles 3m, 3n and 3s of Regulation (EU) No 833/2014.

(17) Decision (CFSP) 2025/1495 expands into a transaction ban the existing prohibition on the provision of specialised financial messaging services to certain Russian credit or financial institutions or other entities subscribing to financial messaging services or to Russian subsidiaries of third-country credit or financial institutions, which are relevant for the Russian financial and banking system, and are either large and important regional banks, which consequently facilitate regional and federal finances and business, or banks which facilitate significant cross-border payments, thereby bolstering the Russian economy and its industry, banks which undermine Ukraine territorial integrity by operating in the occupied territories, or banks which are already the subject of restrictive measures imposed by the Union or by partner countries. Decision (CFSP) 2025/1495 also adds 22 credit or financial institutions and other entities to the list of legal persons, entities or bodies subject to that transaction ban. Finally, Decision (CFSP) 2025/1495 adds exemptions related to the functioning of diplomatic and consular representations of the Union and of the Member States or of partner countries in Russia and to transactions made by nationals of a Member State who are residents in Russia. It also adds a derogation for transactions which are strictly necessary for divestment from Russia or for the wind-down of business activities in Russia. It is recalled that Union restrictive measures do not have extra-territorial effect and do not bind operators incorporated under the laws of third countries, including those of Russia. Therefore, without prejudice to Article 8a of Regulation (EU) No 833/2014, transactions between legal persons, entities or bodies incorporated or constituted under the law of a Member State and their subsidiaries in third countries do not qualify as a violation of that prohibition, including if credit or financial institutions subject to the ban are involved in such transactions. The exemptions and the derogation in Article 5h of Regulation (EU) No 833/2014 are without prejudice to the prohibition on operators in the Union to provide financial messaging services to the entities listed in Annex XIV to that Regulation.

(18) Decision (CFSP) 2025/1495 provides for a dynamic automatic procedure to modify the price cap for Russian crude oil depending on the average market price of Russian crude oil. Such a procedure should ensure that the price cap is sufficiently low at all times to reduce Russia’s revenues from oil exports, taking into account previous price fluctuations. The implementing powers conferred to the Commission in order to amend the price cap for Russian crude oil based on such a procedure do not in any way create a precedent for the implementation of restrictive measures adopted by the Council unanimously. In view of the current global oil prices, a lower cap on the price of Russian crude oil should already be adopted in order to bring the price cap closer to the production costs of oil and thus further reduce Russia’s revenues from oil exports. Each time the price cap is amended, prior contracts that are compliant with the existing price cap should benefit from a transition period of 90 days for maritime transport and for the provision, direct or indirect, of technical assistance, brokering services or financing or financial assistance related to the maritime transport of Russian crude oil to third countries. That transition period is necessary to ensure consistent implementation of the price cap by all operators. In addition, the existing review mechanism should be strengthened, and the Commission should monitor the functioning of the price cap, report to the Council every six months and propose amendments as appropriate. On the basis of such a report, the Council should review the functioning of the price cap mechanism, including the conferral of implementing powers, Annex XXVIII and the prohibitions in paragraphs 1 and 4 of Article 3n of Regulation (EU) No 833/2014.

(19) The Russian Direct Investment Fund (RDIF) remains an instrument used by Russia to channel foreign currencies into its jurisdiction, to seek access to funds in order to sustain its war effort and to increase the resilience of its economy. The RDIF uses complex investment structures to hide its activities and co-financed projects and insulate them from the consequences of Russia’s war of aggression against Ukraine. Decision (CFSP) 2025/1495 therefore introduces a transaction ban targeting the RDIF, its subsidiaries, its significant investments and anyone providing those entities with investment services or other financial services. An investment is to be considered as ‘significant’ if it appears to be underpinned by a governmental economic policy or strategy or if it concerns a sector that is relevant for Russia’s long-term geopolitical manoeuvrability, in particular finance and banking, transport, telecommunications, defence, industrial manufacturing, advanced technology, energy, or the prospection, exploration and production of oil, gas and mineral resources, including related intellectual property or research and development. Decision (CFSP) 2025/1495 also adds 4 entities to the list of legal persons, entities and bodies, in which RDIF has made significant investments, that are subject to the transaction ban.