Written by Martin Poelman
Published on 13 July 2026
‘War has returned to Europe’
With the war of aggression launched by Russia against Ukraine on 24 February 2022, war has returned to Europe, as Mrs Ursula von der Leyen, the President of the European Commission, noted during her speech in Brussels on 1 March 2022. Her speech was so powerful that it is worth quoting part of it:
‘This is a clash between the rule of law and the rule of the gun; between democracies and autocracies; between a rules-based order and a world of naked aggression. How we respond today to what Russia is doing will determine the future of the international system. The destiny of Ukraine is at stake, but our own fate also lies in the balance. We must show the power that lies in our democracies; we must show the power of people that choose their independent paths, freely and democratically. This is our show of force.’
EU sanctions
One of the ways the EU responded was by imposing very heavy sanctions on Russia, individuals and entities. The sanctions are in response to the war of aggression and illegal annexation of the Ukrainian regions of Donetsk, Luhansk, Zaporizhia and Kherson. These sanctions are in addition to measures imposed against Russia in 2014 for annexing Crimea and failing to implement the Minsk agreements. They include individual sanctions aimed at individuals responsible for supporting, financing or carrying out actions that undermine Ukraine’s territorial integrity, sovereignty and independence or who benefit from these actions. They also include economic sanctions and visa measures. The economic sanctions are designed to punish Russia for military action against Ukraine and to thwart the war of aggression. For more useful information on the sanctions, see for example the website of the European Council and the Council of the European Union.
Those sanctioned include senior politicians, oligarchs, military officers, propagandists, Russian-backed authorities in the occupied territories and key figures in the abduction of Ukrainian children to Russia. The sanctions criteria are adjusted from time to time with the aim of effectively targeting members of the Russian government and their family members, oligarchs, businessmen, propagandists and disseminators of disinformation, and persons active in key sectors of the Russian economy that support military aggression.
Regulation (EU) No 269/2014
An important regulation in this context is Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in relation to actions that undermine or threaten the territorial integrity, sovereignty and independence of Ukraine. According to Article 2(1) of this regulation, all funds and economic resources belonging to, owned, held or controlled by all natural or legal persons, entities or bodies listed in Annex I to the regulation, or natural or legal persons, entities or bodies associated with them, shall be ‘frozen’. According to Article 2(2), no funds or economic resources shall be made available, directly or indirectly, to or for the benefit of such natural or legal persons, entities or bodies.
Sanctions list
Annex I to this Regulation comprises a list of sanctioned natural or legal persons, entities or bodies (and natural or legal persons, entities or bodies associated with them). Annex I also sets out the grounds for listing of listed natural or legal persons, entities or bodies concerned. For example, Mr V.V. Putin is listed as number 669 on the list of natural persons (which had 1412 persons at the time of consultation). Under the heading ‘reasons’ (for inclusion in the list), it is stated about him:
‘Vladimir Putin is the president of the Russian Federation. On 22 February 2022, he signed a decree recognising the “independence and sovereignty” of the non-government-controlled areas of the Donetsk and Luhansk oblasts in Ukraine and ordered the Russian armed forces into those areas.
On 24 February 2022, he ordered a military operation in Ukraine and Russian armed forces began an attack on Ukraine. This attack is a blatant violation of the territorial integrity, sovereignty and independence of Ukraine.’
Also on the list, for example, is Mr S. Lavrov, Foreign Minister of the Russian Federation (‘As a member of the Russian Security Council, supported Russia’s immediate recognition of the two self-proclaimed republics. Sergey Lavrov is responsible for and actively supports actions that undermine the territorial integrity, sovereignty and independence of Ukraine, as well as stability and security in Ukraine.’) Besides several members of the Duma, former prime minister and president D. Medvedev is also on the list (‘Deputy Chairman of the National Security Council. As a member of the National Security Council, supported Russia’s immediate recognition of the two self-proclaimed republics.’). The list further includes (at the time of writing this publication) 175 entities, including Sberbank, a major Russian financial institution. According to the list, the Russian Central Bank is Sberbank’s majority shareholder and is Russia’s largest bank. Those who want to check for themselves which individuals and/or entities are on the sanctions list can go here.
In this publication, we discuss some court cases related to the sanctions measures.
