EU Sanctions a Further 41 Vessels Thought to Be Part of Russia’s “Shadow Fleet” and Targets Hybrid Threat Actors

On 18 December 18, 2025, the European Union (EU) added 41 vessels to its sanctions list, targeting Russia’s so-called “shadow fleet,” an opaque network of tankers used to circumvent restrictions on Russian oil exports. The measure forms part of the EU’s broader effort to degrade the Kremlin’s war financing and address persistent enforcement challenges at sea.

The shadow fleet comprises vessels operating under complex ownership structures, often using deceptive practices such as reflagging, disabling tracking systems or obfuscating cargo origins. These ships have become instrumental in sustaining Russian oil exports despite sanctions.

Affected vessels are now banned from EU ports and denied access to essential maritime services. Nearly 600 vessels are now under EU sanctions for their role in transporting crude, arms or stolen Ukrainian goods from occupied territories, and the EU will continue to target further “shadow fleet” vessels on a rolling monthly basis.

The latest move closely follows the designation on December 15, 2025, of five individuals and four entities involved in the shadow fleet’s operations, including shipping companies based in the UAE and Vietnam and individuals associated with Russian oil and gas companies Rosneft and Lukoil. These measures are linked to an EU declaration committing to make fuller use of international law of the sea tools to address shadow fleet risks and strengthen the protection of critical undersea infrastructure, concerns likely brought into sharp focus by recent damage to power and telecommunications cables in the Baltic Sea investigated by Finnish authorities.

Hybrid Threat Actors
Also on December 15, 2025, the EU designated 12 individuals and two entities for their connection to Russia’s misinformation campaigns and cyberattacks. These designations are being made under the EU’s sanction regime targeting Russia’s “destabilising activities” and include foreign-policy analysts, pro-Russian influencers, members of the Russian Military Intelligence Agency (GRU), and the 142nd Separate Electronic Warfare Battalion, responsible for using technology to disorganize shortwave communication systems linked to the recent cases of GPS signal failures experienced by several EU member states. The newly designated targets are now subject to asset freezes and travel bans.

Statement by European Commission President on Financing for Ukraine
The EU has been discussing using frozen Russian assets to support Ukraine but has been unable to reach consensus on how to do so, with Belgium objecting due to legal and financial concerns— e.g., that it could subsequently be held liable if successful lawsuits are brought (many of the frozen assets are located in Belgium).

Instead, for now, the EU agreed at a summit in mid-December that it would provide a €90 billion interest-free loan to Ukraine for 2026–2027. This will be funded through joint EU borrowing and will not draw from any frozen Russian assets at this stage. Ukraine will only need to repay after Russia pays war reparations.

This means that approximately €210 billion worth of Russian assets will remain frozen under current EU sanctions while discussions on their eventual fate continue.