EU Sanctions Developments

Russia

On 27 January 2025, the Council of the European Union (the "Council") renewed the EU sanctions in view of the Russian Federation’s continuing actions destabilising the situation in Ukraine for a further 6 months, until 31 July 2025. Council Decision (CFSP) 2025/175 of 27 January 2025 noted, among other things:

As long as the illegal actions by the Russian Federation continue to violate fundamental rules of international law, including, in particular, the prohibition on the use of force enshrined in Article 2(4) of the Charter of the United Nations, or of international humanitarian law, it is appropriate to maintain in force all the measures imposed by the Union and to take additional measures, if necessary. Consequently, Decision 2014/512/CFSP should be renewed for a further 6 month.

On 28 January 2025, the European Commission (the "Commission") proposed tariffs on remaining agricultural products and on fertilisers from Russia and Belarus. The announcement indicates, among other things, that the tariffs are expected to negatively impact Russian export revenues thus impacting Russia's ability to wage its war of aggression against Ukraine.

Cyber Attacks

On 27 January 2025, the Council sanctioned three Russian individuals responsible for a series of cyberattacks carried out against Estonia in 2020. The individuals are officers of the General Staff of the Armed Forces of the Russian Federation (GRU) Unit 29155.

The cyber-attacks granted attackers unauthorized access to classified information and sensitive data stored within several government ministries, —including Economic Affairs and Communications, Social Affairs, and Foreign Affairs—leading to the theft of thousands of confidential documents. These documents included business secrets, health records, and other critical information compromising the security of the affected institutions. Unit 29155 is also responsible for conducting cyber-attacks against other EU member states and partners, notably Ukraine.

With these actions 17 individuals and 4 entities were sanctioned under the EU cyber sanctions regime.

Venezuela

On 10 January 2025, the Council took several actions concerning the situation in Venezuela. The Council prolonged its measures until 10 January 2026, reintroduced travel restrictions on four individuals, and imposed sanctions on an additional 15 individuals.

In a statement on behalf of the EU, the High Representative noted that the "[...] reversal of EU sanctions will depend on tangible progress in human rights and the rule of law in Venezuela, along with meaningful steps towards genuine dialogue and a democratic transition."

Terrorism

On 30 January 2025, the Council renewed the list of persons, groups and entities subject to sanctions with a view to combatting terrorism. The Council delisted one deceased person and maintaining the rest unchanged.

There are currently 14 persons and 22 groups under this program. The Council also decided to extend the duration of the humanitarian exceptions, introduced in February 2024 for an initial period of one year, until 22 February 2027, in order to ensure continued timely delivery of humanitarian assistance and other activities that support basic human needs in line with UN Security Council resolution 2664 (2022).

Other Actions

On 27 January 2025, the Council removed one individual from the EU's Libya sanctions program. It renewed the Tunisia sanctions program until 31 January 2026. Concerning the situation in Georgia, on 27 January 2025, the Council decided to suspend parts of the EU-Georgia visa facilitation agreement.

Syria Update

On 27 January 2025, the Council agreed on a roadmap to ease sanctions on Syria. While the EU aims to move quickly, it indicated that it is ready to reverse the course if the situation worsens. Commenting on the decision, the High Representative noted:

[...] we have grouped the sanctions to make this roadmap for a step-for-step approach really to start with the sanctions that are most hindering the early build-up of the country and to move from there. What we are not relieving, of course, is anything related to arms, and arm dealing. We are still concerned of the radicalisation and what might happen. So, right now we have a political decision, we have the roadmap, we have a step-for-step approach so that if we see some steps going in the right direction, we are also willing to ease the next sanctions. What I must say is that this is a political agreement. There are also technical issues to be solved, but I hope, because the political will is there, that these issues will be solved in the weeks.

Select Developments in EU Courts

In January 2025, several judgements were handed down by EU courts with relevance to compliance. Among them were:

• MegaFon v. Council (T-193/23) delivered on 15 January 2025. The General Court upheld the Annex IV listing of MegaFon.
• Melnichenko v. Council (T‑271/22), delivered on 22 January 2025. The General Court upheld the listing of Andrey Melnichenko, confirming among other things, that a trust does not prevent the applicant beneficiary of the trust from being regarded as the holder of the stakes managed by the trust.
• Vinokurov v. Council (T‑1106/23) delivered on 29 January 2025. The General Court upheld the listing of Alexander Semenovich Vinokurov, confirming, among other things, the types of open source information used to base the designation (including Wikipedia).

Export Controls

Report on the Implementation of the Dual-Use Regulation

On 31 January 2025, the Commission published, for the first time, a report assessing patterns of Member State exports of dual-use items. Providing an overview of data 2022, the report highlights trends from 2023 and 2024. It notes among other things, that both authorisations and denials for the export of those most sensitive goods is on the rise as compared to 2021.

The report includes, for the first time, extensive information on licensing data that will allow for a better understanding of how export controls are applied, and the risks identified relating to exports of sensitive items in the current geopolitical context.  Read the report here.

Dutch Controls on Advanced Semiconductor Manufacturing Equipment

In January 2024, the Dutch government announced amendments to the export controls regime for advanced semiconductor manufacturing equipment (SME). The amendments will be effective as of 1 April 2025 with which additional items will be subject to licencing requirements. The amendments are reflected in the updated annex to the Regulation on Advanced Semiconductor Manufacturing Equipment (Regeling geavanceerde productieapparatuur voor halfgeleiders).

The amendments relate to items such as measurement and testing equipment as well as optimisation software used in the production of advanced semiconductors. The amendments are the latest development reflecting the expansion of national SME measures geared towards machines and software used in further production stages beyond lithography. This is the second revision of the national export control regulation implemented in September 2023, after the initial revision of September 2024.

Outbound Investment Screening

On 15 January 2025, the Commission published a recommendation on reviewing outbound investments in technology areas critical for the economic security of the Union (the "Recommendation").

The Recommendation calls on EU Member States to review outbound investments of their companies into non-EU countries.

The Recommendation applies to three technology areas of strategic importance as well as the highest risk – semiconductors, artificial intelligence and quantum technologies – and calls on Member States to assess risks to economic security potentially arising from such transactions.

Looking Ahead

The EU is reportedly preparing a 16th package of sanctions against Russia.

• Informal EU Leaders' Retreat, 3 February 2025
• Foreign Affairs Council, 24 February 2025
• European Council, 20-21 March 2025

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