EU Sanctions Against Russia: New Protections for EU Businesses

The European Union adopted its 15th sanctions package against Russia on 16 December 2024, introducing additional safeguards for European entities. A key development is the introduction of Article 11c to Council Regulation (EU) No 833/2014, as amended by Regulation (EU) 2024/3192, which aims to protect EU businesses from legal actions initiated in Russian courts in response to EU sanctions. The provision prohibits the recognition or enforcement within EU Member States of certain Russian court decisions issued under Article 248 of the Russian Arbitration Procedure Code. 

Article 248 of the Russian Arbitration Procedure Code allows Russian courts to claim exclusive jurisdiction over specific disputes involving foreign parties and enables the issuance of anti-suit injunctions preventing parties from pursuing proceedings in foreign courts or arbitral tribunals. By introducing Article 11c, the EU ensures that such Russian court decisions—including related penalties or fines—cannot produce legal effects within the EU. The measure strengthens the EU’s sanctions framework and provides greater legal certainty and protection for EU businesses operating in the context of ongoing geopolitical tensions. 

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