Council Regulation (EU) 2025/2033 of 23 October 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) 2025/2032 of 23 October 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) On 23 October 2025, the Council adopted Decision (CFSP) 2025/2032, which amends Decision 2014/512/CFSP.
(4) Decision (CFSP) 2025/2032 adds 45 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. Among the entities Decision (CFSP) 2025/2032 includes on that list are 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 computer numerical controlled machine tools, on microelectronics, unmanned aerial vehicles, and other dual-use and advanced technology items.
(5) Decision (CFSP) 2025/2032 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 electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides and alloys used in the manufacturing of military systems.
(6) Decision (CFSP) 2025/2032 introduces a new targeted derogation from the prohibition on purchasing, importing or transferring certain items -which generate significant revenues for Russia and which are necessary for the operation, maintenance or repair of ultra-violet (UV) lamps used for the disinfection of drinking water. Decision (CFSP) 2025/2032 also amends the derogation from the prohibition on purchasing, importing or transferring certain items which generate significant revenues for Russia, and which are necessary for the operation, maintenance or repair of Budapest metro line 3 cars.
(7) In order to further decrease Russia’s revenues, Decision (CFSP) 2025/2032 extends the prohibition to purchase, import or transfer certain items which generate significant revenues for Russia to all acyclic hydrocarbons.
(8) Decision (CFSP) 2025/2032 imposes further restrictions on exports of goods which might contribute to the enhancement of Russian industrial capacities, such as salts and ores, articles of rubber, tubes, tyres, millstones and construction materials.
(9) Decision (CFSP) 2025/2032 extends the list of partner countries for importation of petroleum products.
(10) In order to decrease further Russia’s revenues from the export of fossil fuels, raise the costs of its illegal actions in Ukraine and put maximum pressure on Russia to cease its war of aggression against Ukraine, Decision (CFSP) 2025/2032 imposes a prohibition on the purchase, import, or transfer, directly or indirectly into the Union of liquified natural gas originating or exported from Russia, as well as on the provision of related technical or financial assistance. To provide the highest degree of legal certainty to Union operators, in particular concerning Union gas importers, and also to provide clarity about the applicable legal provisions under Union law, it is appropriate to stress that this prohibition, which has like any other measure in Regulation (EU) No 833/2014, direct legal effect and provides no discretion for Member States or Union operators, should be complied with and should apply regardless of potential measures under other legal bases covering the import, purchase or transfer of LNG originating or exported from Russia. Until Regulation (EU) No 833/2014 is repealed, the scope of this measure should persist irrespective of other legal acts under different legal bases.
(11) Decision (CFSP) 2025/2032 introduces additional designations of vessels, amends one of the designation criteria and amends related provisions on prohibited services for designated vessels. Regarding the prohibition on Union operators to provide insurance and reinsurance to designated vessels, the designation of a vessel is without prejudice to the payment of pay-outs from the relevant insurer of the vessel to persons and entities having suffered damage caused by the vessel in respect of claims arising from events before the vessel was designated.
(12) Decision (CFSP) 2025/2032 removes certain energy-related exemptions from the transaction ban for two specific state-owned enterprises.
(13) Decision (CSFP) 2025/2032 expands the transaction ban that applies to legal persons, entities or bodies that are connecting to the system for transfer of financial messages (‘SPFS’) of the Central Bank of the Russian Federation (‘Central Bank of Russia’) or equivalent specialised financial messaging services set up by the Central Bank of Russia, to other payment services, such as the Russian National Payment Card System (in Russian, ‘Mir’) or the Fast Payments System (‘SBP’), set up by the Central Bank of Russia or by other Russian entities. It also adds exemptions for transactions that are necessary for the functioning of diplomatic and consular representations of the Union and of the Member States in third countries and for transactions made by nationals of a Member State who are residents of a third country, for transactions that are necessary for existing contracts and the reception of payments, and for Member States’ ethnic minorities in Russia.
(14) Decision (CFSP) 2025/2032 expands the transaction ban on third-country credit and financial institutions and crypto-asset service providers to also include entities that provide payment services, and in particular entities that provide crypto-asset and payment services to listed entities. In order to fight against the proliferation of new entities that succeed the listed ones, it also expands the transaction ban to cover equivalent entities if certain criteria are met. In addition, Decision (CFSP) 2025/2032 adds 8 new entities to the list in Annex XIX to that Decision. That addition should be reflected by also adding those entities to the list in Annex XLV to Regulation (EU) No 833/2014. Finally, it also adds exemptions for transactions that are necessary for existing contracts and the reception of payments.
(15) Decision (CFSP) 2025/2032 further extends the transaction ban to any ports and locks in third countries other than Russia that are used for the transfer of unmanned arial vehicles (UAVs) or missiles or related technology or components thereof to Russia, or for the circumvention of the Oil Price Cap by vessels practicing irregular and high-risk shipping practices, or for the circumvention of other restrictive measures.
(16) Special economic, innovation and preferential zones are a core element of the economic development strategy of the Russian Federation. They are designed to attract direct investment and promote industrial, technological and innovative capacity by providing preferential tax, customs and regulatory regimes in regard to industrial parks, technology clusters, logistics hubs and port areas across the Russian Federation.
(17) Those zones include the Special Economic Zones (SEZ), innovation regimes and the Far Eastern and Arctic preferential regimes, as defined in Russian laws such as Federal Law No. 116-FZ of 22 July 2005, Federal Law No. 244-FZ of 28 September 2010, Federal Law No. 212-FZ of 13 July 2015 and Federal Law No. 193-FZ of 13 July 2020. Certain SEZ and innovation regimes are central to Russia’s industrial and technological capacity, hosting enterprises engaged in the production or development of dual-use goods, advanced electronics, robotics, software, vehicles, aviation components, unmanned aerial systems and other goods and technology contributing to the Russian war effort. Preferential regimes in the Far Eastern Federal District and the Arctic Zone support maritime logistics, shipbuilding, the mining and petrochemicals sectors and energy export routes that are central to Russia’s economic reorientation towards Asia, as well as to the circumvention of restrictive measures.
(18) In order to deprive Russia further of the means to sustain its aggression against Ukraine, Decision (CFSP) 2025/2032 prohibits any new participation in, the creation of joint ventures with, and the provision of financing to, any enterprise established in or operating through certain special economic, innovation or preferential zones, as well as prohibiting entering into new contracts with such enterprises. Moreover, Decision (CFSP) 2025/2032 prohibits the maintaining of any participation in, or of joint ventures or contracts with, any enterprise established in or operating through certain special economic, innovation or preferential zones. Finally, appropriate exemptions and derogations are provided to prevent undesirable effects of those prohibitions.
(19) Decision (CFSP) 2025/2032 imposes restrictions on the provision of crypto-asset services, on the provision of the payment services referred to in points 5 and 7 of Annex I to Directive (EU) 2015/2366 of the European Parliament and of the Council (4), and on the issuing of electronic money to Russian nationals, natural persons residing in Russia, and legal persons, entities or bodies established in Russia, in view of the importance of those services to the development of Russia’s financial technology and e-commerce sectors and the potential use of crypto-asset services to circumvent restrictive measures. Those restrictions do not extend to the execution of payment transactions as referred to in points 3 and 4 of Annex I to Directive (EU) 2015/2366. The restrictions on the provision of payment services should not be understood as imposing obligations on payment initiation service providers to determine the nationality, residence or place of establishment of payment service users on a transaction-by-transaction basis, nor on acquirers of payment transactions to conduct sanctions screening of individual payment card transactions. Primary responsibility for sanctions compliance in relation to the execution of payment transactions rests with the account-servicing payment service provider. The restrictions on the provision of crypto-asset services are also binding on crypto-asset service providers operating under the transitional regime set out in Article 143(3) of Regulation (EU) 2023/1114 of the European Parliament and of the Council (5).
(20) The use of certain crypto-assets can pose a significant risk of circumventing the prohibitions laid down in Regulation (EU) No 833/2014 and Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (6), in particular transaction bans and asset freezes. A prohibition on transactions involving those crypto-assets is a necessary measure to prevent that outcome, while also allowing for a limited period of time to enable the orderly termination of existing contracts.
(21) Decision (CFSP) 2025/2032 adds five credit or financial institutions to the list of legal persons, entities or bodies subject to a transaction ban. The transaction ban applies 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 or 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’s territorial integrity by operating in the occupied territories of Ukraine, or banks which are already the subject of restrictive measures imposed by the Union or by partner countries. In parallel, Decision (CFSP) 2025/2032 adds exemptions necessary for humanitarian purposes, for the export, sale, supply, transfer or transport of pharmaceutical, medical or agricultural and food products, to ensure access to judicial, administrative or arbitral proceedings in a Member State, as well as for the recognition or enforcement of a judgment or an arbitration award rendered in a Member State, for the reception of payments due by the legal persons, entities or bodies controlled by the Russian Government pursuant to contracts performed before 15 May 2022, and for the implementation of certain authorisations granted pursuant to Regulation (EU) No 269/2014 and for Member States’ ethnic minorities in Russia. Those exemptions and derogation are without prejudice to the prohibition on operators in the Union to provide financial messaging services to the entities listed in Annex XIV to Regulation (EU) No 833/2014.
(22) Decision (CFSP) 2025/2032 imposes further restrictions on the provision, to the Government of Russia or to legal persons, entities or bodies established in Russia, of services that contribute to enhancing Russia’s technological capabilities, namely the provision of certain commercial space-based services, certain artificial intelligence services, and high-performance computing and quantum computing services. Moreover, Decision (CFSP) 2025/2032 expands the scope of current restrictions to cover not only technical testing and analysis, as classified in class 8676 of the Central Products Classification as set out in Statistical Office of the United Nations, Statistical Papers, Series M, No 77, CPC prov., 1991, but also other services which form group 867 of the Central Products Classification. These services notably include, as classified in class 8675, the following engineering-related scientific and technical consulting services: geological, geophysical and other scientific prospecting, subsurface surveying, surface surveying and map-making services.
(23) Moreover, Decision (CFSP) 2025/2032 restricts the provision of services directly related to tourism activities in Russia, in particular those classified in classes 7471 and 7472 of the Central Products Classification as set out in Statistical Office of the United Nations, Statistical Papers, Series M, No 77, CPC prov., 1991. This is done in order to reduce the revenues that Russia derives from such services and to deter the promotion of non-essential travel and leisure activities to Russia, especially in a context where Union nationals face a heightened risk of arbitrary arrests and detention, and where consular protection for persons having dual nationality is limited.
(24) In view of Russia’s continued war of aggression against Ukraine, any further provision of services to the Government of Russia should be assessed ex ante by a competent authority, in order to mitigate the risk of a service contributing to Russia’s military, technological or industrial capacity. Decision (CFSP) 2025/2032 therefore introduces a requirement for prior authorisation by the competent authority for any services provided to the Government of Russia which are not already subject to the restrictive measures set out in Regulation No (EU) 833/2014.
(25) In order to limit the ability of the Russian state to obtain revenues from old, under-maintained aircraft and vessels, Decision (CFSP) 2025/2032 prohibits providing reinsurance for Russian used aircraft or vessels during a period of five years following the sale or lease arrangement of those aircraft or vessels made after the entry into force of this Regulation.
(26) Within the Schengen area and when traveling to a Member State other than that of their accreditation, Decision (CFSP) 2025/2032 establishes a prior notification mechanism for Russian diplomats and consular officers, as well as for members of the administrative and technical staff or of the service staff of diplomatic missions or consular posts of Russia, and for their family members. That prior notification mechanism aims at ensuring the awareness of Member States of related movements, against a backdrop of increasing hostile intelligence activities that support Russia’s aggression against Ukraine. Decision (CFSP) 2025/2032 also provides that Member States willing to do so, may impose an authorisation requirement for travel to their territories of such individuals, based on visas or residence permits issued by another State.
(27) Decision (CFSP) 2025/2032 makes certain technical amendments to Regulation (EU) No 833/2014, including extending the deadlines applicable to certain derogations needed for divestments from Russia. Operators should be aware that Russia is a country where the rule of law is no longer applied, and that the Russian Federation has adopted several pieces of legislation targeting assets of companies from so-called ‘unfriendly countries’, including Member States. That situation could lead to Union assets being stranded in Russia without the possibility for orderly withdrawal. Against this background, given that undertakings in the Union are strongly advised to take any possible steps to wind-down businesses in Russia and not to start new businesses there, it is appropriate to extend divestment derogations to enable Union undertakings to exit as swiftly as possible from the Russian market. The extended derogations are granted on a case-by-case basis by Member States and focused on allowing an orderly divestment process, which would not be possible without the extension of those deadlines.
(28) These measures fall within the scope of the Treaty on the Functioning of the European Union and therefore, in particular with a view to ensuring their uniform application in all Member States, regulatory action at the level of the Union is necessary.
(29) Regulation (EU) No 833/2014 should therefore be amended accordingly,
HAS ADOPTED THIS REGULATION:
Article 1
Regulation (EU) No 833/2014 is amended as follows:
(9) in Article 5ae, the introductory wording of paragraph 1 is replaced by the following: ‘1. It shall be prohibited to engage in any transaction, directly or indirectly, with ports and locks listed in Part A and Part C of Annex XLVII. Part A of Annex XLVII shall include ports and locks in Russia, and Part C of Annex XLVII shall include ports and locks in third countries other than Russia, that are used:’
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