EU Adds 189 Ships to Sanctions List – Legal Remedies Available

As part of its 17th sanctions package, the EU has adopted Regulation (EU) 2025/932, which entered into force on 21 May 2025. The regulation adds a further 189 ships/vessels to the sanctions list set out in Annex XLII of Regulation (EU) 833/2014.

The EU Council states in its Decision (CFSP) 2025/931 that the measure is appropriate in order to further constrain the activity of vessels that are part of the shadow fleet of oil tankers or that contribute to Russia’s energy revenues. According to the Council, Russia is becoming increasingly reliant on energy revenues to fund its "illegal war of aggression" against Ukraine.

Legal basis for this list enlargement is Article 3s(2)(b) of Regulation (EU) 833/2014. According to this rule, Annex XLII shall include vessels that transport crude oil or petroleum products, as listed in Annex XXV, that originate in Russia or are exported from Russia while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33).

Pursuant to Article 3s(1) of Regulation (EU) 833/2014, EU persons (as defined in Article 13) are prohibited, directly or indirectly, from engaging in any of the following activities in relation to vessels listed in Annex XLII:

(a) provide access to ports, anchorage zones and locks in the territory of the Union, and for such a vessel to access them;

(b) import into the Union, purchase or transfer such a vessel;

(c) sell, supply, including charter, or export such a vessel;

(d) operate or crew such a vessel;

(e) provide flag registration for the benefit of such a vessel;

(f) provide financing and financial assistance, including insurance, as well as brokering services, including ship brokering;

(g) provide technical assistance and other services including bunkering, ship supply services, crew changes services, cargo loading and discharge services, fendering and tug services to the benefit of such a vessel; and

(h) engage in ship-to-ship transfers or any other transfer of cargo with, or procure any services from, such a vessel.

Legal Remedies

In many cases it makes sense to seek removal from the EU sanctions list by submitting a formal request for reconsideration to the Council. This administrative procedure allows the sanctioned party to present arguments and evidence demonstrating that their listing is unjustified or no longer necessary.

With or without a prior de-listing application at the Council, the affected individual or entity can challenge the Council’s listing decision before the General Court of the European Union (EGC). This process provides an independent judicial examination of the legality of the listing decision.

If you intend to seek the removal (delisting) of the ships/vessels from the EU sanctions list and require legal advice regarding available remedies, please contact attorney Dr Hendrik Müller-Lankow.