In conjunction with EU Member States’ diplomatic efforts on the Ukraine crisis, the European Union decided to target both Russian and Ukrainian individuals and entities considered responsible for actions undermining or threatening Ukraine’s territorial sovereignty.

On February 9, 2015, the EU published Council Implementing Regulation (EU) 2015/240 to expand the list of individuals and entities targeted under Regulation (EU) 269/2014 (see our earlier Sanctions Update of March 25, 2014). With effect from February 16, 2015, the EU imposed asset-freezing measures on 19 individuals – among which are some high-ranking Russian officials – and nine entities. 

The following additional individuals and entities are now subject to restrictive measures:


Pavel Dremov (aka Batya)

Alexey Milchakov (aka Fritz, Serbian)

Arseny Pavlov (aka Motorola)

Mikhail Tolstykh (aka Givi)

Eduard Basurin 

Alexandr Shubin

Sergey Litvin 

Sergey Ignatov

Ekaterina Filippova

Aleksandr Timofeev

Evgeny Manuilov

Viktor Yatsenko

Olga Besedina

Zaur Ismailov

Anatoly Ivanovich Antonov

Arkady Viktorovich Bakhin

Andrei Valeryevich Kartapolov

Iosif (Joseph) Davydovich Kobzon

Valery Fedorovich Rashkin


Cossack National Guard

Sparta Battalion

Somali Battalion

Zarya Battalion

Prizrak Brigade

Oplot Battalion

Kalmius Battalion

Death Battalion

Public Movement "Novorossiya"

From a practical perspective, the updated legislation does not significantly increase the burden of compliance procedures that companies must follow. Companies must, however, maintain robust screening procedures and ban virtually all transactions with targeted individuals and entities.