This news item continues the reporting on key EU reactions following the Russian invasion of Ukraine on 24 February 2022: the impact on the EU’s internal security policy, on criminal law, and on the protection of the EU’s financial interests. The following overview covers the period from November 2024 to January 2025. For overviews of the previous developments → eucrim 3/2024, 174-176 and →eucrim 2/2024, 91-92, each with further references.

• 22 November 2024: The European Commission releases updated guidelines on the "best efforts" obligation under Art. 8a of Council Regulation (EU) No 833/2014, which governs sanctions against Russia and Belarus as a response to the illegal annexation of Crimea and Sevastopol. These updates clarify EU operators' responsibilities when managing entities outside the Union, ensuring they take all feasible actions to prevent their controlled entities from undermining sanctions. The guidelines emphasise that compliance measures should be tailored to each operator’s size, nature, and level of control over non-EU entities. This includes implementing compliance programmes, monitoring activities, and ensuring due diligence. However, if external factors, such as third-country laws, make control impossible, liability may be mitigated. The update also clarifies the difference between "circumvention" and "undermining" of sanctions, with the latter referring to any activity that enables Russia to obtain restricted goods, technology, or financial resources. EU operators are expected to actively prevent such activities, especially when they control or own entities outside the EU. The new guidelines aim to ensure uniform enforcement of EU sanctions, strengthening efforts to limit Russia’s ability to finance its war against Ukraine while maintaining fair compliance expectations for businesses operating globally.
• 11 December 2024: In Case T‑326/22, the General Court of the European Union (GC) rules against Dmitry Konov, a Russian businessman, confirming the EU’s restrictive measures against him. Konov challenged his inclusion on the sanctions list, which led to the freezing of his assets, arguing that he does not meet the criteria of an "influential businessman" and that the measures violate his fundamental rights. The GC finds that the EU Council provided sufficient evidence to justify the sanctions.
• 16 December 2024: The Council adopts the 15th package of economic and individual restrictive measures against Russia (for the 14th package of sanctions →eucrim 1/2024, 11). It intends to further limit Russia’s ability to continue its war against Ukraine. This latest set of restrictive measures targets individuals, companies, and industries supporting Russia’s military and economic operations. It includes 84 new listings, sanctioning individuals responsible for war crimes, propaganda, and the deportation of Ukrainian children, as well as defense and shipping companies transporting oil and military supplies. In an effort to curb sanctions circumvention, 52 additional vessels have been banned for violating oil price caps or aiding Russia’s war efforts, while 32 entities from third countries, including China, India, Iran, Serbia, and the UAE, now face stricter export controls on technology and dual-use goods. To protect European businesses, the Council blocks the recognition/enforcement of Russian court rulings against EU companies in the EU and extends deadlines for firms seeking to exit the Russian market, which is to ensure an orderly divestment process.
• 18 December 2024: The Commission disburses €4.1 billion to Ukraine under the Ukraine Facility. It is the second regular payment under the Facility, which includes a total of €50 billion in the period 2024-2027. The disbursement follows a positive assessment of Ukraine's reform efforts in certain areas. These are related to business environment, labour market, regional policy, energy market, environmental protection, and the fight against corruption as set out in the Ukraine Plan.
• 18 December 2024: In case T-732/22, the General Court (GC) confirms the legality of Council decisions to impose restrictive measures against Russian oligarch Oleg Vladimirovich Deripaska. Deripaska challenged several EU decisions and regulations putting him on the sanctions list, and he requested compensation for immaterial damage suffered. In its judgment, the GC analyses concepts such as "influential businessman" and "businessman active in economic sectors providing a substantial source of revenue to the Russian government" as defined in Art. 2(1)(a) and (g) of Decision 2014/145/CFSP. The judgment addresses issues related to the obligation to state reasons, the right to effective judicial protection and defense rights, potential errors of assessment, proportionality, the right to property, and the right to be heard.
• 19 December 2024: The European Council adopts conclusions on Ukraine. They condemn Russia’s ongoing aggression and reaffirm the EU's commitment to military, financial, and humanitarian aid for Ukraine. The European Council highlights the following measures in support of Ukraine: accelerating the delivery of air defense systems, ammunition, and training; implementing the Ukraine Facility with €16.2 billion in 2024 and €12.5 billion in 2025, plus disbursement of €18.1 billion in 2025 from the G7-led Extraordinary Revenue Acceleration (ERA) loans initiative for defense and reconstruction; supporting Ukraine’s power grid and intensifying EU energy integration; enforcing the 15th sanctions package (see above) and countering sanctions circumvention. The conclusions also stress that the EU remains committed to Ukraine’s recovery and announce a Ukraine Recovery Conference to be held in July 2025 in Italy.
• 10 January 2025: The Commission disburses the first €3 billion tranche of the G7 ERA loan. The G7 ERA loans initiative will collectively provide approximately €45 billion in financial support to Ukraine in 2025 (of which the EU will contribute €18.1 billion). The loan is designed to support Ukraine's current and future military, budget, and reconstruction needs. It complements the EU's Ukraine Facility. The G7 instrument offers very favourable terms to Ukraine, and repayment will be ensured through the extraordinary profits from immobilised Russian assets collected from the Ukraine Loan Cooperation Mechanism (ULCM). In doing so, the G7 countries send a clear signal to Russia that the burden of reconstructing Ukraine will be borne by those responsible for its destruction.
• 10 January 2025: The Commission publishes a factsheet and a summary that inform about the EU's measures of solidarity with Ukraine. The documents include an overview of the EU's and Member States' funding of Ukraine since the beginning of the war in February 2022. The total support currently amounts to €132 billion. In addition, the key achievements of the solidarity with Ukraine are outlined: maintaining Ukraine's economy, keeping Ukraine open to international trade and ensuring food security, supplying the country with military and technological means, integrating Ukraine into the European family, imposing sanctions on Russia, and holding Russia accountable for its actions and making it pay for the destruction it causes.
• 15 January 2025: The General Court (GC) dismisses an action for annulment brought by a major Russian mobile telephone and telecommunications operator (MegaFon) against the company's inclusion into the list of Russian entities subject to restrictive measures (Case T-193/23). The GC states that the Council did in fact set out the actual and specific reasons why it decided to apply restrictive measures to MegaFon. The Court also rejects MegaFon’s arguments relating to the infringement of its rights of defence. It notes in particular that the Council was under no obligation to hear MegaFon before including it on the aforementioned list. Lastly, the judges in Luxembourg find that there was no error of assessment by including and maintaining the company's name on the list, and there was no violation of the company's freedom to conduct a business.
• 23 January 2025: In a resolution, the European Parliament (EP) condemns Russia's use of disinformation and the Russian regime's historical claims about Ukraine as a means to justify an illegal war. The EP reiterates its call for the establishment of a special tribunal to investigate and prosecute the crime of aggression committed by the leadership of the Russian Federation against Ukraine and calls for the EU to expand its sanctions against Russian media outlets conducting disinformation and information manipulation campaigns. MEPs also voice concern over the decision by some social media companies to relax fact-checking rules.
• 27 January 2025: The Foreign Affairs Council renews the EU restrictive measures against the Russian Federation’s due to the country's continuing actions destabilising the situation in Ukraine for a further six months, until 31 July 2025. The restrictive measures, which above all curb business with Russia, were first introduced in 2014, and then significantly expanded since February 2022 in response to Russia’s military aggression against Ukraine.