Sixteen hundred names on the blacklist: what does the EU's largest-ever sanctions decision against Russia contain?

On October 12, in Luxembourg, the foreign ministers of the European Union's member states added nearly 1,600 Russian individuals and companies to the sanctions list. This is the largest single expansion since the war began, and it targets participants in Russia's military industry, particularly the production chains for drones and ballistic missiles. Kaja Kallas, the EU's High Representative for Foreign Affairs and Security Policy, said that the current decision is the largest expansion since the start of the war, and that more than half of the listed entities are linked to the production chain of the ballistic missiles that Russia uses to kill Ukrainian civilians day after day.

According to the High Representative, this will make it significantly harder, slower and more expensive for Russia to produce weapons for use against Ukrainians, and now is the time to increase pressure on Moscow, not to ease it. On the same day, the ministers also adopted a second, smaller list of 77 people who either ran in or organized Russia's sham parliamentary elections held in the occupied Ukrainian territories. With these two decisions, the number of individuals and entities sanctioned against Russia has risen from around three thousand to more than four thousand five hundred. The list includes President Vladimir Putin, oligarchs who support the regime, numerous State Duma deputies, banks, as well as numerous vessels from the shadow fleet that transports Russian oil in violation of sanctions.

The Kyiv Independent had already reported on September 21 that the list was being prepared, and that it covers almost the entire structure of Russia's military industry, from shipyards and aerospace companies to electronics manufacturers, armored vehicle repair plants, and aviation and space firms. According to a report by the AP, the basis for selection is particularly telling: these companies appear on a list compiled by the Russian government itself, which classifies them as part of the military-industrial complex and therefore eligible for state support. The EU has thus essentially turned the Russian state's own register against Moscow, which is an elegant solution, since it is hard for a company to claim it has nothing to do with the military industry if the Kremlin itself placed it in that category, and Brussels also considers the executives running these companies to be supporters of the military-industrial complex. The explicit aim of the decision is to target the mid-level suppliers that, in the EU's wording, form the "core" of Russia's military industry, because these companies produce electronic components, communications equipment, radar and navigation systems, satellite and missile systems, as well as explosives and ammunition — in other words, exactly the elements without which an Iskander or a Shahed would not be able to fly as far as Kyiv or Kharkiv.

EU sanctions mean that the assets held within the Union by the listed entities are frozen, and EU actors are barred from doing business with them; however, it is not yet clear how many of these companies even had business ties with EU countries or assets within the Union, since many of them probably never even tried to enter the European market directly. The real effect of the sanctions therefore cannot primarily be measured in frozen assets, though a senior EU official told the paper that the decision's impact on third countries should not be underestimated — Southeast Asian states in particular do not want to risk their relations with the EU by doing business with companies on the EU list, so in practice the sanctions make it harder for these companies to operate across much of the world. Ultimately, the goal is to make running the Russian war machine harder and more expensive, and according to Brussels, anything that makes it more difficult to obtain Western components is a step forward.

An important distinction must be made: this decision is not a classic sanctions package introducing new sectoral bans, such as an oil, gas or technology embargo, but rather an extremely extensive expansion of the list that designates new targets within existing legal frameworks. Its impact therefore depends on how consistently it is enforced and how successfully the loopholes through which Russia's military industry has so far obtained Western components can be closed. How large these loopholes are is clearly shown by the case of the financial network known as A7, which the US Treasury Department designated a criminal organization in early October. The network, which serves Moscow and Tehran, handled around 13 percent of Russia's foreign trade in 2025 through shell companies and crypto tokens.

The second list, covering 77 people, was adopted unanimously by the member states, as the Irish EU presidency confirmed to the Kyiv Independent. Of those sanctioned, 74 ran as candidates in Russia's parliamentary election held between September 18 and 20 — which had already begun in the occupied Ukrainian territories by the end of August — while the other three are a newly elected member of Russia's Central Election Commission and election organizers; most of the organizers and 24 candidates were already under EU sanctions. On September 26, Ukraine itself sanctioned more than forty people involved in the elections, and the EU had already taken election-related measures earlier after Moscow excluded the last anti-war party, Yabloko, from the race. This was the first Russian parliamentary election also held in the occupied Ukrainian territories, after Russia had forced Russian passports on the local population en masse and made them renounce Ukrainian citizenship — though this was merely another step in a longer series: in September 2022, the occupying authorities held sham referendums in the occupied parts of the Donetsk, Luhansk, Zaporizhzhia and Kherson regions, so-called regional elections in 2023, and a presidential election in 2024, in which Putin was again declared the winner.

The mood at the Luxembourg meeting was not entirely celebratory. When asked about Donald Trump's diesel deal with Russia, Latvian Foreign Minister Baiba Braže said the EU should look in the mirror before criticizing others: on September 21, Brussels removed from the sanctions list Alisher Usmanov and Mikhail Fridman, two of the biggest supporters of the Putin regime, under pressure from Slovakia, Luxembourg and France. Lithuania's Kęstutis Budrys added that when the EU showed weakness by removing two prominent oligarchs, Russia responded with escalation in both Ukraine and Europe. Estonia's Margus Tsahkna said the American diesel deal is unlikely to change much in reality, since it is much more closely tied to the upcoming midterm elections, and that Europe should focus on what it itself can do for Ukraine. German Minister for Europe Gunther Krichbaum said that every euro and every dollar flowing from energy purchases into Putin's coffers helps fund the production of new weapons, while Kallas called on Washington to introduce sanctions, noting that once the war ends, there will be no need for attacks on refineries either.

The EU also acted on other fronts: Lithuania proposed that the bloc designate Russia's foreign intelligence service, the SVR, a terrorist organization; Finland urged in a letter that EU entry for Russian citizens be almost entirely halted; and according to Volodymyr Zelensky, Ukraine will receive this week another installment of about three billion euros in military funding from the EU's 90-billion-euro loan facility. Ukrainian Foreign Minister Andrii Sybiha, however, pointed out that frozen Russian assets will only serve as a genuine tool of pressure if Europe actually uses them to defend Ukraine.

This latest decision thus reveals both the strength and the limits of the EU. Adding sixteen hundred names to the list, based on the Russian state's own register no less, is a strong signal to Moscow and to all those supplying Russia's military industry from third countries — especially in a week when Washington is easing pressure by buying diesel. Yet the impact of sanctions depends not on the length of the lists but on the consistency of enforcement, since the same EU that is now targeting almost 1,600 Russian companies removed two oligarchs close to Putin from the list just three weeks earlier, because three member states wanted it that way. If Europe is serious about believing that the path to ending the war lies in isolating Russia, it will need not only longer lists but also a more consistent policy.

Ugar