EU Sanctions Count Tops 4,600 as Targeting Expands to UAE and China

The European Union has sanctioned more than 4,600 individuals and entities since the full-scale invasion of Ukraine began in 2022. This total reflects the formal approval of 1,600 new names by EU foreign ministers on October 12. The bloc now moves monthly, adding visa bans and asset freezes rather than large sectoral packages.

A new proposal presented to member state ambassadors on October 21 lists 12 individuals and 105 companies. Tatyana Kim, founder and chief executive of Wildberries, is the most prominent name on the list. The proposal states that Wildberries functions as a supply network for the Russian military by facilitating sales of military and dual-use goods. It also notes a strategic partnership with VTB Bank, which the EU has already sanctioned.

Other high-profile targets include Aleksandr Chachava, who holds the biggest stake in Ozon and a stake in Yandex. The document describes Ozon as a supply network for the Russian military. Ruslan Baysarov, chairman of a major infrastructure firm, is also listed for his controlling stake in BTS-Gold, a gold mining company already under EU sanctions. Sergei Matvienko, a shareholder in a major real estate developer, is proposed for blacklisting due to his firm's fiscal contribution to the Russian budget.

The proposal targets 105 companies, including several regional Russian banks. Many of these banks are being sanctioned for offering loan-repayment grace periods to members of the Russian armed forces. The list also includes numerous companies controlling Russian oil refineries. The text asserts that the energy sector provides a substantial source of revenue to the Russian government.

The list extends beyond Russia for the first time at this scale. Several companies from the United Arab Emirates are proposed for sanctioning for managing vessels that transport crude oil from Russia. The EU describes their shipping practices as irregular and high-risk. Two companies registered in the Seychelles face similar charges. Several Chinese companies based in Hong Kong are included because they purchase Russian oil or own vessels already sanctioned by the EU.

Diplomats are simultaneously exploring whether to add Russia's GRU military intelligence agency to the EU terrorist list. This debate follows recent hybrid attacks on EU member states linked to the agency. The legal challenge is finding a prior court ruling in an EU or trusted third country that designates the GRU specifically for terrorism, not just espionage or murder. Previous cases, such as the 2018 Salisbury poisoning, charged GRU agents with attempted murder rather than terrorism.

Lithuania offers potential legal pathways for the designation. In 2025, Lithuanian prosecutors charged 15 individuals with terrorism for an incident involving incendiary devices intended for cargo planes. These individuals were described as GRU-recruited proxies rather than direct officers. A separate trial involves six foreign nationals accused of planning an arson attack in September 2024 against a private military supplier in Siauliai. Legal experts in Brussels are examining if these links are strong enough to justify a bloc-wide listing.

Unanimity from all 27 EU member states is required to designate the GRU as a terrorist organization. Some officials argue that existing sanctions, which freeze assets and ban visas for leadership, are sufficient. Others contend that a terror listing would target every single officer, closing loopholes for unsanctioned individuals. It would also allow European prosecutors to arrest local proxy networks and issue EU-wide counterterrorism arrest warrants, integrating GRU operations into Europol’s European Counter Terrorism Center.