New EU regulation: a blow to Russia-linked infrastructure, media and cryptosphere

On 21 May 2025, a new sanctions regulation 2025/964, adopted by the EU Council as a supplement and reinforcement to the previous one, Regulation 2024/2642, entered into force in the European Union. Despite the common language of law, behind this document is a whole new chapter of Russia's economic and information blockade. The EU is now purposefully expanding not only the range of individuals and companies under sanctions, but also the very logic of the bans: infrastructure, the media field, and even cryptocurrencies are now in the restricted zone.

Sanctions move to the "material level": from ships to submarine cables

For the first time, the EU formally prohibits any direct or indirect transactions with facilities of strategic importance used in the interests of the Russian government or persons associated with it. What are these facilities?

This includes not only ships, aircraft, ports and airfields, but also digital network infrastructure, including submarine cables - in other words, anything that can be used for intelligence, destabilisation, surveillance, cyber-attacks and the transport of weapons. Examples are included in special Annex III of the document.

The test for involvement in violation of international order now extends to infrastructure: who owns a facility, how it is used, in whose interests - all this becomes a criterion for banning any transactions.

Exceptions are allowed, e.g. in case of humanitarian emergencies or by decision of national authorities, in strict agreement with the objectives of the regulations.

Cryptocurrency exchanges and financial operators outside the EU in the crosshairs

The EU is also taking an important step in combating the transpartisan financial network operating outside its borders. The ban now covers all companies providing financial or cryptocurrency services that directly or indirectly support Russia's actions deemed destabilising - for example, exchanges, wallets, and payment gateways involved in circumventing sanctions.

These organisations will be listed in Annex IV and any activity with them within the EU will be blocked.

Media: direct blocking, no illusions

One of the most high-profile measures is the rigid blocking of broadcasting of Russian media resources in the EU, regardless of the channel of distribution:

• TV and radio airplay,
• satellite and IPTV broadcasting,
• mobile and internet applications,
• pre-installed systems on devices,
• streaming platforms,
• social networks.

Even advertising in these sources is banned. This is not just a question of blocking "broadcasting" - it is a structural clean-up of the entire information field in which these resources can operate.

However, journalists from these media outlets are not prohibited from working in other formats not related to content distribution. The EU separately emphasises that the regulation does not violate the principle of freedom of speech - it is aimed at combating systemic disinformation and manipulation.

Who can now be subject to sanctions?

Another innovation concerns the grounds for inclusion in the sanctions lists. Now the list may include those who:

• disrupts the electoral process and the rule of law,
• spreading misinformation,
• engages in pressure and intimidation campaigns,
• organises cyber attacks and interferes with critical infrastructure,
• provokes conflicts in third countries for resources.

In other words, not only Russians, but also those who co-operate with Russian interests outside the EU - including companies, experts, influencers and intermediaries - are at risk.

The EU has consistently expanded its sanctions mechanisms: before it was accounts, then exports and investments, now it is infrastructure and information flow itself. The new regulation allows EU governments to block or prohibit transactions, even if it is not goods, but, say, the right to use a port or transmit traffic through a server.

This means that the sanctions become "functional" - they are not so much about the nationality of the participant as about his or her involvement in the system that serves Russian policy.

In the coming weeks, the European Commission and Member States will start publishing additional lists of assets (Annex III), financial structures (Annex IV) and media (Annex V). This will give specificity to the new restrictions.

In the coming weeks, the European Commission and Member States will start publishing additional lists of assets (Annex III), financial structures (Annex IV) and media (Annex V). This will give specificity to the new restrictions.