Council Decision (CFSP) 2025/394 of 24 February 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

‘1 It shall be prohibited to directly or indirectly engage in any transaction with a legal person, entity or body referred to in point (a), (b) or (c) of Article 7(1) of this Decision that lodged a claim before a Russian court against a natural or a legal person, entity or body referred to in point (c) or (d) of Article 13 of Regulation (EU) No 833/2014 to obtain an injunction, order, relief, judgment or other Court decision pursuant to or derived from Article 248.1 or Article 248.2 of the Arbitration Procedure Code of the Russian Federation or equivalent Russian legislation, in connection with any contract or transaction the performance of which has been affected, directly or indirectly, in whole or in part, by the measures imposed under this Decision or Decision 2014/145/CFSP, or under Regulations (EU) No 833/2014 or (EU) No 269/2014, as listed in Annex XVII to this Decision.’

‘7 By way of derogation from paragraph 2, the competent authorities of a Member State may authorise the execution of transactions with entry number 1 in Annex XVIII, under such conditions as they deem appropriate and after having determined that the execution of such transactions is necessary for (a) the repayment of export credits guaranteed; (b) transactions which are strictly necessary for divestment from Russia or the wind-down of business activities in Russia by 26 August 2025 which were covered by export credits guarantees by a Member State; or (c) the execution of contracts concluded before 25 February 2025 until 26 August 2025 or until their expiry date, whichever is earlier, for beneficiaries located in the European Union’

1 It shall be prohibited to directly or indirectly engage in any transaction with a legal person, entity or body established outside of the Union that is a credit or financial institution or an entity providing crypto assets services that: (a) are involved in transactions that facilitate, directly or indirectly the export, sale, supply, transfer or transport to Russia of dual-use goods and technology, goods or technology as listed in Annexes VII, XI, XX and XXXV to Regulation (EU) No 833/2014, common high priority items as listed in Annex XL to Regulation (EU) No 833/2014, and firearms and ammunition as listed in Annex I to Regulation (EU) No 258/2012, as listed in Part A of Annex XIX to this Decision; (b) are involved in frustrating the prohibition set out in Article 4x through transactions in relation to any vessel listed in Annex XVI, as listed in Part B of Annex XIX to this Decision; or (c) circumvent the prohibition set out in Article 4p, as listed in Part C of Annex XIX to this Decision.

2 The prohibition in paragraph 1 shall apply to a legal person, entity or body acting on behalf or at the direction of an entity referred to in points (a), (b) and (c) of paragraph 1.

3 The prohibition in paragraph 1 shall not apply to transactions that are: (a) necessary for the export, sale, supply, transfer or transport of pharmaceutical, medical or agricultural and food products, including wheat and fertilisers, whose export, sale, supply, transfer or transport to Russia is allowed under this Decision and Regulation (EU) No 833/2014; (b) strictly necessary 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, provided that such transactions are consistent with the objectives of this Decision or Decision 2014/145/CFSP, or of Regulations (EU) No 833/2014 or (EU) No 269/2014; or (c) necessary for humanitarian purposes, such as delivering or facilitating the delivery of assistance, including medical supplies, food, or the transfer of humanitarian workers and related assistance or for evacuations.’

1 It shall be prohibited to engage in any transaction, directly or indirectly, with ports and locks listed in Part A of Annex XXI. Part A of Annex XXI shall include ports and locks in Russia that are used: (a) for the transfer of unmanned aerial vehicles (UAVs) or missiles, related technologies or components thereof in support of Russia’s war of aggression against Ukraine; (b) for the transport of goods and technology used in the defence and security sector, from or to Russia, for use in Russia or for Russia’s warfare in Ukraine; (c) for the maritime transport of crude oil or petroleum products, as listed in Annex XIII, that originate in Russia or are exported from Russia by vessels practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33); (d) for the transport of goods originating in or exported from the Union as listed in Annexes XI, XX and XXIII to Regulation (EU) No 833/2014, or goods originating in Russia or exported from Russia and imported into the Union, as listed in Annex XXI to Regulation (EU) No 833/2014, and thereby enabling Russia’s actions destabilising the situation in Ukraine; (e) in such a way as to facilitate or engage in the violation or circumvention or otherwise significantly frustrate the provisions of this Decision or of Decisions 2014/145/CFSP, 2014/386/CFSP or (CFSP) 2022/266, or of Regulations (EU) No 833/2014, (EU) No 269/2014, (EU) No 692/2014 or (EU) 2022/263.

2 It shall be prohibited to engage in any transaction, directly or indirectly, with airports listed in Part B of Annex XXI. Part B of Annex XXI shall include airports in Russia that are used: (a) for the transfer of UAVs or missiles, related technologies or components thereof in support of Russia’s war of aggression against Ukraine; (b) for the transport of goods and technology used in the defence and security sector, from or to Russia, for use in Russia or for Russia’s warfare in Ukraine; (c) for the transport of goods originating in or exported from the Union listed in Annexes XI, XX and XXIII to Regulation (EU) No 833/2014, or goods originating in Russia or exported from Russia and imported into the Union, as listed in Annex XXI to Regulation (EU) No 833/2014, and thereby enabling Russia’s actions destabilising the situation in Ukraine; (d) in such a way as to facilitate or engage in the violation or circumvention or otherwise significantly frustrate the provisions of this Decision or of Decisions 2014/145/CFSP, 2014/386/CFSP or (CFSP) 2022/266, or of Regulations (EU) No 833/2014, (EU) No 269/2014, (EU) No 692/2014 or (EU) 2022/263.

3 Paragraph 1 shall not apply: (a) in the case of a vessel in need of assistance seeking a place of refuge, of an emergency port call for reasons of maritime safety, or for saving life at sea, or for humanitarian purposes, or for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters; (b) to transactions which are strictly necessary for the direct or indirect purchase, import or transport of natural gas, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the Union, a country member of the European Economic Area, Switzerland, or the Western Balkans; (c) unless prohibited under Article 4o or 4p, to transactions which are strictly necessary for the direct or indirect purchase, import or transport of oil, including refined petroleum products, from or through Russia; (d) to transactions which are necessary for the purchase, import or transport of pharmaceutical, medical, agricultural and food products, including wheat and fertilisers whose import, purchase and transport is allowed under this Decision; (e) to transactions for the purchase, import or transfer of seaborne crude oil and of petroleum products listed in Annex XIII where those goods originate in a third country and are only being loaded in, departing from or transiting through Russia, provided that both the origin and the owner of those goods are non-Russian; (f) to transactions necessary for the establishment, operation, maintenance, fuel supply and retreatment and safety of civil nuclear capabilities, and the continuation of design, construction and commissioning required for the completion of civil nuclear facilities.

4 Paragraph 2 shall not apply to transactions which are strictly necessary for: (a) humanitarian purposes, the evacuation or repatriation of persons, or initiatives providing support to victims of natural, nuclear or chemical disasters; (b) the operation of flights required for attending meetings with the objective of seeking a solution to Russia’s war of aggression against Ukraine or of promoting the policy objectives of the restrictive measures; (c) an emergency landing, take-off or overflight; (d) travel for official purposes of members of diplomatic or consular missions of Member States or partner countries in Russia or of international organisations enjoying immunities in accordance with international law; (e) travel, for personal reasons, of natural persons to and from Russia or of members of their immediate families travelling with them; (f) the purchase, import or transport of pharmaceutical, medical, agricultural and food products whose import, purchase and transport is allowed under this Decision.

5 Operators shall inform the competent authority of the Member State where they are incorporated or under whose law they are constituted of any transaction concluded pursuant to paragraph 3 or 4 within 2 weeks of its conclusion. The Member State concerned shall inform the other Member States and the Commission of any information received pursuant to this paragraph within 2 weeks of its receipt.’

1 The temporary storage, as defined in Article 5, point 17, of Regulation (EU) No 952/2013 of the European Parliament and of the Council , and the placement under the free zone procedure pursuant to Article 245(3) of Regulation (EU) No 952/2013, of crude oil or petroleum products as listed in Annex XIII to this Decision in Union territory is prohibited, if the goods originate in Russia or are exported from Russia.

2 The prohibition in paragraph 1 shall not apply to goods already in the Union on 25 February 2025 until 26 May 2025.

3 The prohibition in paragraph 1 of this Article shall not apply to Member States that benefit from the exemptions in Article 4o(3), point (d), and in Article 4o(4).

4 The prohibition in paragraph 1 shall not apply to seaborne crude oil and petroleum products listed in Annex XIII where those goods originate in a third country and are only being loaded in, departing from or transiting through Russia, provided that both the origin and the owner of those goods are non-Russian.

1 It shall be prohibited to sell, supply, transfer, or export, directly or indirectly, goods and technology and to provide, directly or indirectly, services to any natural or legal person, entity or body in Russia when such goods, technology and services are for the completion of liquefied natural gas projects such as terminals and plants or for the completion of crude oil projects in Russia, such as exploration and production projects.

2 It shall be prohibited to: (a) provide, directly or indirectly, technical assistance or brokering services related to goods, technology and services in Russia when such goods, technology and services are intended for the completion of liquefied natural gas projects or crude oil projects as referred to in paragraph 1; (b) provide, directly or indirectly, financing or financial assistance related to goods, technology and services in Russia when such goods, technology and services are intended for the completion of liquefied natural gas projects or crude oil projects as referred to in paragraph 1.

3 The prohibitions in paragraphs 1 and 2 relating to crude oil projects shall be without prejudice to the execution until 26 May 2025 of contracts concluded before 25 February 2025, or of ancillary contracts necessary for the execution of such contracts.

4 The prohibition in paragraphs 1 and 2 shall not apply to oil production projects where regular commercial production was established prior to 25 February 2025.’

1 Natural and legal persons, entities and bodies that sell, supply, transfer or export common high priority items as listed in Annex XL to Regulation (EU) No 833/2014 or other sensitive goods shall: (a) take appropriate steps, proportionately to their nature and size, to identify and assess the risks of exportation to Russia and exportation for use in Russia for such goods or technology, and ensure that those risk assessments are documented and kept up-to-date; (b) implement appropriate policies, controls and procedures, proportionately to their nature and size, to mitigate and manage effectively the risks of exportation to Russia and exportation for use in Russia for such goods or technology, whether those risks were identified at their level or at the level of the Member State or of the Union.

1a Paragraph 1 shall apply as of 26 December 2024 with regard to Annex XL to Regulation (EU) No 833/2014 and as of 26 May 2025 with regard to other sensitive goods.

2 Paragraph 1 shall not apply to natural and legal persons, entities and bodies that sell, supply or transfer common high priority items as listed in Annex XL to Regulation (EU) No 833/2014 or other sensitive goods only within the Union or to partner countries listed in Annex VII.

3 Natural and legal persons, entities and bodies shall ensure that any legal person, entity or body established outside the Union that they own or control and that sells, supplies, transfers or exports common high priority items as listed in Annex XL to Regulation (EU) No 833/2014 or other sensitive goods implements the requirements in points (a) and (b) of paragraph 1.

3a Paragraph 3 shall apply as of 26 December 2024 with regard to Annex XL to Regulation (EU) No 833/2014 and as of 26 May 2025 with regard to other sensitive goods.

4 Paragraph 3 shall not apply where, due to reasons that it did not cause itself, a natural or legal person, entity or body is not able to exercise control over the legal person, entity or body that it owns.

5 The Union shall take the necessary measures in order to determine the relevant items to be covered by this Article.’

The Council, acting by unanimity on the basis of Articles 29 and 30 of the Treaty on European Union, shall amend Annexes I, II, III, IV, V, VI, VIII, IX, X, XIV, XVI, XVII, XVIII, XIX, XX and XXI.’

This Decision shall enter into force on the day following that of its publication in the Official Journal of the European Union.