The EU’s 17th Sanctions Package and Finland’s National Implementation of the Sanctions Criminalisation Offences Directive

Authors: Annika Lampela, Juuso Lumilahti, Ricardo Gomes, and Anna-Maria Tamminen

On 20 May 2025, the European Union (EU) adopted its anticipated 17th package of sanctions against Russia. The 17^th package targets an unprecedented amount of vessels in Russia’s shadow fleet, aiming to further restrict Russia’s access to battlefield technologies and reduce revenues from Russia’s energy imports. On the same day, Finnish national legislation implementing the Directive (EU) 2024/1226 (the “Sanctions Criminalisation Offences Directive”) entered into force. Below, we summarise the changes brought on by the 17^th package of sanctions, as well as the changes in Finnish criminal legislation following the implementation of the directive.

The EU’s 17^th Sanctions Package: What is New?

1. An unprecedented number of vessels in Russia’s shadow fleet targeted and additional entities and individuals sanction-listed. The 17^th sanctions package lists an additional 189 vessels which are part of Russia’s shadow fleet of oil tankers or contribute to Russia’s energy revenues, making the package the largest single G7 sanctions action targeting such vessels. The additional listings more than double the amount of sanctioned vessels, bringing their total number to 342. The listed vessels are subject to bans on port access and provision of services, and have been identified together with Member States and the European Maritime Safety Agency (EMSA). The added listings, together with efforts from countries such as the United Kingdom and the United States of America, aim to make exporting oil more difficult and costly for Russia.

In addition, the package adds 31 new companies which support Russia’s military-industrial complex or engage in sanctions circumvention to the sanctions list. Of these sanctioned companies, 18 are established in Russia, while 13 are established in third countries, namely Turkey, Vietnam, the United Arab Emirates, Serbia and Uzbekistan.

17 individuals and 58 additional entities which have committed actions undermining the territorial integrity, sovereignty, and independence of Ukraine are also listed. These listings mostly target the Russian military and defence sectors, though actors involved in the looting of cultural heritage and other actors active in occupied territories are also listed. The new listings make use of new criteria adopted in the 16^th sanctions package (you can find our overview of the 16^th package here). With the 17th package, over 2,400 individuals and entities are now included in EU’s sanctions lists.

Among the listed entities are the Russian oil giant Surgutneftegas and the Russian shipping company Joint Stock Company Volga Shipping.

2. Export restrictions expanded. The list of dual-use and advanced technology items subject to export restrictions is also expanded with the 17^th package, in an effort to impede Russian access to key technologies particularly for military use.

Among the additional restricted items are chemical precursors to energetic material such as sodium chlorate, potassium chlorate, aluminium powder, magnesium powder and boron powder, following evidence that these precursors are being used—directly or indirectly—as propellants for Russian missiles. In addition, spare parts and components of high-precision Computer Numerical Control (CNC) machine tools, such as ball screws and encoders, are also among those items added to the list. The export of CNC machine tools themselves has largely been restricted already previously, while the new listings seek to hinder Russia’s ability to maintain its industrial base serving its military complex.

3. The so-called “Sakhalin exemption” extended. To ensure Japan’s energy security needs, the 17^th package further extends the so-called “Sakhalin exemption”, previously extended in the 14^th and 11^th sanctions packages as well. The exemption exempts the export of crude oil originating from the Sakhalin-2 project in Russia by vessel to Japan from the oil price cap which otherwise applies to Russian oil exports. The 17^th package extends the exemption until 28 June 2025

Changes to Finnish National Legislation Following the Implementation of the EU’s Sanctions Criminalisation Offences Directive

On the same day as the EU adopted the 17^th package, national legislation implementing the Sanctions Criminalisation Offences Directive entered into force in Finland. The directive aims to ensure that violating sanctions is punishable in all EU Member States and to establish common minimum criminal penalties for such violations. Below, we summarise the key changes brought on by the national implementation of the directive into Finnish law.

1. New provisions adopted into the Finnish Criminal Code.  With the national implementation of the directive, new provisions implementing sanctions offence, aggravated sanctions offence, negligent sanctions offence and sanctions violation as criminal offences are adopted into the Finnish Criminal Code. Previously, violating sanctions was criminally punishable in Finland as a regulation offence, which will no longer apply to such violations or offences. The penalties for the aforementioned offences range from a fine to five years in prison.

2. Changes to the maximum amount of corporate criminal fines. The new legislation also entails changes to corporate criminal liability. Of the newly implemented criminal offences, the sanctions offence, aggravated sanctions offence and negligent sanctions offence are subject to corporate criminal liability, meaning that a legal person may be sentenced to a corporate fine if a person exercising true decision-making power in the legal person has been involved in such an offence or has allowed the commission of such an offence, or if the care and diligence necessary for preventing such an offence have not been observed in the operations of said legal person.

This does not, in and of itself, significantly change the previous state of affairs, as a regulation offence is also subject to corporate criminal liability, and thus breaching EU sanctions carried the risk of corporate criminal liability previously as well. However, the new legislation also introduces an exception to the general maximum amount of a corporate fine. Whereas the general scale for a corporate fine is between EUR 850 and EUR 850,000, the new legislation stipulates that the maximum corporate fine for the aforementioned offences against sanctions is five per cent of the turnover of the liable legal person, but no less than EUR 850,000 and no more than EUR 40 million. This means that for legal entities with an annual turnover exceeding EUR 17 million, the maximum amount of a corporate fine is higher than previously, EUR 850,000 being five per cent of EUR 17 million. For entities with an annual turnover below EUR 17 million, the maximum amount of the corporate fine remains EUR 850,000. The new legislation does not bring changes to the minimum amount of the corporate fine nor other aspects of corporate criminal liability.

The EU’s 17^th package of sanctions, falling on the same day as the entry into force of the national implementation of the EU’s Sanctions Criminalisation Offences Directive in Finland, emphasises the broad set of measures taken by the EU to not only increase pressure on Russia via sanctions, but also tackle sanctions circumvention in Member States. The EU has reported that further sanctions are also already in the works, emphasising the need for companies to remain vigilant and up-to-date to ensure sanctions compliance.

Hannes Snellman regularly advises clients on matters related to EU sanctions and sanction control. Our experts closely follow developments in sanctions-related legislation. Please contact us if you would like to discuss any questions related to this topic.