On December 16, 2024, the Council adopted Decision (CFSP) 2024/3187, updating Decision 2014/512/CFSP.
This new decision adds 32 entities to the list in Annex IV of Decision 2014/512/CFSP, which targets individuals, companies, and organizations that support Russia’s military-industrial complex in its ongoing aggression against Ukraine. These entities are now subject to stricter export controls on dual-use goods, technology, and any items that might enhance Russia’s defense or security sectors. The decision also lists entities outside Russia that indirectly aid its military and technological efforts by evading export restrictions, including in areas like drones and missiles.
To further limit activities supporting Russia’s actions in Ukraine, the decision also adds more vessels to Annex XVI of Decision 2014/512/CFSP. These vessels face bans from EU ports and locks, as well as restrictions on maritime transport services.
Additionally, the decision clarifies the responsibilities of central securities depositories under Regulation (EU) 2024/1469. As outlined in recital 17, these depositories typically transfer customer cash balances by the end of each day without offering any compensation. Therefore, they are not liable for interest or other payments related to frozen assets, unless explicitly agreed upon in a contract. Furthermore, managing assets under the transaction ban or handling related cash balances does not expose these depositories, their directors, or employees to liability unless negligence is proven.
The decision also responds to actions by Russian courts under Article 248 of the Russian Arbitration Procedure Code, which block European companies from pursuing cases against Russian entities in foreign courts and impose excessive penalties for non-compliance. The EU considers such rulings to violate international dispute resolution norms. To counter this, the decision bans the recognition or enforcement of these anti-suit injunctions, fines, or any related court decisions within the Union.
Finally, Decision (CFSP) 2024/3187 includes technical updates to Regulation (EU) No 833/2014, such as extending deadlines for specific derogations tied to divestments from Russia or the supply of certain petroleum products. Given the risks of doing business in Russia, including legal threats to EU assets and the lack of rule of law, Union operators are encouraged to wind down operations and avoid new ventures there. The extended derogations aim to help businesses exit Russia in an orderly manner, with approvals granted on a case-by-case basis by Member States.