On 10 October 2024, the new EU sanctions framework against Russia will come into force. Council Regulation (EU) 2024/2642 (“EU Russia Destabilisation Sanctions”) introduces new restrictive measures against Russia in response to its destabilising activities against the EU and EU Member States. The regime is designed to respond to Russia’s campaign of hybrid activities against the EU and its Member States.

The new regime allows the EU to impose asset freezing measures on legal and natural persons who are responsible for, implement, support or benefit from Russia’s destabilising actions worldwide, as well as their associates and supporters. All funds and economic resources of the designated persons will be frozen and no funds or economic resources will be made available to the designated persons.

The EU Russia Destabilisation Sanctions target persons who are responsible for, implement, support or benefit from actions or policies of the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the EU, its Member States, international organisations or in third countries, or which undermine or threaten the sovereignty or independence of one or more EU Member States through:

• Undermining of the democratic political process, including by obstructing or undermining the holding of elections or attempting to destabilise or overthrow the constitutional order

• Supporting or otherwise facilitating violent demonstrations

• Supporting or otherwise facilitating acts of violence, including activities to silence, intimidate, coerce, or exact reprisals against persons critical of the actions or policies of the Russian Federation

• Supporting or otherwise facilitating the use of coordinated information manipulation and interference

• Supporting or otherwise facilitating any actions targeted at the functioning of democratic institutions, economic activities or services of public interest, including by unauthorised entry into the territory of a Member State, including its airspace, or aimed at interfering with, damaging or destroying, including through sabotage or malicious cyber activities as part of hybrid activities, critical infrastructure, including submarine infrastructure

• Supporting or otherwise facilitating the instrumentalisation of migrants

• Exploiting an armed conflict, instability or insecurity, including through the illicit exploitation or trade of natural resources and wildlife in a third country

• Instigating or facilitating an armed conflict in a third country

The new sanctions regime is a potentially powerful tool for the EU to address a dimension of Russia's global destabilising activities over which it previously had only limited powers. As the new regime is not limited to Russian activities targeting the EU or its Member States, but also covers actions affecting third countries or international organisations, the EU's Russia Destabilisation Sanctions can be used in response to a wide range of Russian activities around the world and to further constrain Russia's ongoing hybrid activities worldwide.

No individuals or entities have yet been listed under the EU Russia Destabilisation Sanctions, but we expect the EU to make the first designations under the new regime in the coming days or weeks.

Please contact the Brussels Trade Team if you have any questions.

Authored by Lourdes Catrain, Kacper Maksymczuk.