Council Implementing Decision (EU) 2025/2612 of 11 December 2025 establishing the satisfactory fulfilment of the conditions for the partial payment of the sixth instalment under the Ukraine Plan of the Ukraine Facility

Official Journalof the European Union ENL series
2025/2612 18.12.2025
(1) Pillar I of the Ukraine Facility (the ‘Facility’), established by Regulation (EU) 2024/792, makes financial support of up to EUR 38 337 000 000(2)available to Ukraine for the period 2024-2027 in the form of non-repayable support and a loan. Financing under Pillar I is mainly allocated on the basis of the Ukraine Plan of the Ukraine Facility (the ‘Plan’), approved by Council Implementing Decision (EU) 2024/1447(3), as amended by Council Implementing Decision (EU) 2025/2157(4). The Plan sets out Ukraine’s reform and investment agenda, and the qualitative and quantitative steps that are linked to funding under Pillar I of the Facility.
(2) The timetable for monitoring and implementing the Plan, including the qualitative and quantitative steps that are linked to funding under Pillar I of the Facility, is set out in the Annex to Implementing Decision (EU) 2024/1447, as amended by Implementing Decision (EU) 2025/2157.
(3) The total sum of financial resources made available for the Plan amounts to EUR 32 337 000 000, of which EUR 5 337 000 000 is in the form of non-repayable financial support and up to EUR 27 000 000 000 is in the form of a loan.
(4) In accordance with Articles 24 and 25 of Regulation (EU) 2024/792, EUR 6 000 000 000 has been disbursed to Ukraine as exceptional bridge financing and EUR 1 890 000 000 in the form of pre-financing, representing an advance payment of 7 % of the loan support that Ukraine is eligible to receive under the Plan.
(5) In accordance with Article 26(4) of Regulation (EU) 2024/792, EUR 16 576 146 834 has been disbursed to Ukraine in the first five instalments under the Plan, of which EUR 3 400 000 000 has been disbursed in the form of non-repayable financial support and EUR 13 176 146 834 in the form of a loan. In accordance with the Loan Agreement concluded between the Union and Ukraine pursuant to Article 22 of Regulation (EU) 2024/792, an amount of EUR 991 752 987 from the first five instalments was used to clear the pre-financing of the loan.
(6) In accordance with Article 26(2) of Regulation (EU) 2024/792, on 31 October 2025 Ukraine submitted a duly justified request for the payment of part of the sixth instalment of the loan support. On 11 November 2025, it submitted an updated request to take into account the adoption of an outstanding step under the fourth instalment. Pursuant to Article 26(5) of Regulation (EU) 2024/792, a withheld payment is to be disbursed only when Ukraine has duly justified, as part of a subsequent payment request, that it has taken the necessary measures to ensure satisfactory fulfilment of the qualitative and quantitative steps. The request was accompanied by a series of documents evidencing the satisfactory fulfilment of one step under the fourth instalment and eight steps under the sixth instalment. It also submitted all documents required under Article 12 of the Framework Agreement, Article 5 of the Financing Agreement and Article 6 of the Loan Agreement concluded between the Union and Ukraine pursuant to Articles 9, 10 and 22, respectively, of Regulation (EU) 2024/792.
(7) The steps underpinning Ukraine’s latest request relate to various reforms set out in the Plan under the chapters on public finance management, the judicial system, financial markets, human capital, the business environment, decentralisation and regional policy, the management of critical raw materials, and the green transition and environmental protection. The digital management tool for the reconstruction of Ukraine has been developed and implemented. The law establishing a new court to hear administrative cases, the legislation on the principles for the sale of state-owned banks, the law on reforming the territorial organisation of the executive authorities in Ukraine and the legislation on public support for agriculture have entered into force. Harmonised standards for three groups of industrial products, the second Nationally Determined Contribution of Ukraine to the Paris Agreement adopted under the United Nations Framework Convention on Climate Change and the National Waste Management Plan until 2033 have been adopted. A report on the verification of Ukraine’s reserves of critical raw materials has been published.
(8) In accordance with Article 26(3) of Regulation (EU) 2024/792, the Commission has assessed Ukraine’s request in detail and made a positive assessment of the satisfactory fulfilment of one of the two outstanding steps required for the fourth instalment and eight of the ten steps required for the sixth instalment, as specified in the Annex to this Decision. The positive assessment has been made in the context of the implementation of the Plan. Further alignment with the Unionacquiswill be facilitated through the Union accession process.
(9) In its payment request, Ukraine confirmed that it has not reversed any measure related to the steps which it had previously satisfactorily fulfilled.
(10) The Commission has further assessed that Ukraine continues to fulfil the pre-condition for Union support set out in Article 5 of Regulation (EU) 2024/792. In particular, Ukraine continues to uphold and respect effective democratic mechanisms, including a multi-party parliamentary system and the rule of law, and to guarantee respect for human rights, including the rights of persons belonging to minorities.
(11) This Decision should therefore establish that the relevant conditions for the payment of the fourth instalment in respect of one of the two outstanding steps and of the sixth instalment in respect of eight of the ten steps under the Plan have been satisfactorily fulfilled.
(12) Considering the difficult financial situation Ukraine is facing, it is of the utmost importance to disburse the funds as soon as possible. Given the urgency of the situation and with a view to expediting the process, this Decision should enter into force on the date of its publication in theOfficial Journal of the European Unionand should apply from the date of its adoption,
Name of the step:Development and implementation of the digital management tool for the reconstruction of Ukraine
Related reform/investment:Reform 4. Improved public investment management
Financed from:loan
ContextThe requirement for Step 2.8 described in the CID Annex is:‘Development and implementation of the digital management tool for the reconstruction of Ukraine, which provides public access to data on reconstruction projects at all stages, including planning, financing, procurement, construction and commissioning, to enable a public and transparent monitoring of project implementation and better coordination of reconstruction efforts between sectors.’Step 2.8 is the second of two steps in the implementation of Reform 4 of Chapter 2 (public financial management). It was preceded by Step 2.7 (Q2 2024) on the adoption of the action plan for the implementation of the roadmap for reforming public investment management.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;2)link to the website of the digital tool for public investment management:DREAM;3)copy of the Resolution of the Cabinet of Ministers No. 527 ‘On some issues of public investment management’ dated 28 February 2025 and amended on 26 August 2025;4)copy of the Law of Ukraine No. 4225-IX‘On amendments to the Budget Code of Ukraine concerning the update and improvement of certain provisions’ dated 5 March 2025;5)copy of the Order of the Ministry for Development of Communities and Territories of Ukraine No. 1289 ‘On the commissioning of the software of the Unified Digital Integrated Information and Analytical System for the Management of the Process of Reconstruction of Real Estate, Construction, and Infrastructures’ dated 20 August 2025;6)copy of the certificates of works completion. 1) summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex; 2) link to the website of the digital tool for public investment management:DREAM; 3) copy of the Resolution of the Cabinet of Ministers No. 527 ‘On some issues of public investment management’ dated 28 February 2025 and amended on 26 August 2025; 4) copy of the Law of Ukraine No. 4225-IX‘On amendments to the Budget Code of Ukraine concerning the update and improvement of certain provisions’ dated 5 March 2025; 5) copy of the Order of the Ministry for Development of Communities and Territories of Ukraine No. 1289 ‘On the commissioning of the software of the Unified Digital Integrated Information and Analytical System for the Management of the Process of Reconstruction of Real Estate, Construction, and Infrastructures’ dated 20 August 2025; 6) copy of the certificates of works completion.
1) summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;
2) link to the website of the digital tool for public investment management:DREAM;
3) copy of the Resolution of the Cabinet of Ministers No. 527 ‘On some issues of public investment management’ dated 28 February 2025 and amended on 26 August 2025;
4) copy of the Law of Ukraine No. 4225-IX‘On amendments to the Budget Code of Ukraine concerning the update and improvement of certain provisions’ dated 5 March 2025;
5) copy of the Order of the Ministry for Development of Communities and Territories of Ukraine No. 1289 ‘On the commissioning of the software of the Unified Digital Integrated Information and Analytical System for the Management of the Process of Reconstruction of Real Estate, Construction, and Infrastructures’ dated 20 August 2025;
6) copy of the certificates of works completion.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 2.8.The objective of Reform 4 is to improve public investment management. To this end, the Ukrainian authorities have developed and implemented a digital tool for managing reconstruction projects, in line with the roadmap for reforming public investment management.The Digital Restoration Ecosystem for Accountable Management (DREAM) was developed by the Open Contracting Partnership in cooperation with the Ministry for Development of Communities and Territories of Ukraine. DREAM serves as the unified digital platform for managing public investment projects at all levels of government. It provides public access to real-time information at every stage of a project’s lifecycle, ensuring transparency and accountability. By consolidating all project data into a single system, DREAM enables continuous public and donor monitoring throughout the public investment cycle – from project preparation to implementation – and better coordination of reconstruction efforts between government tiers.DREAM enables line ministries to submit their proposed annual public investment projects for funding, guided by the Medium-Term Plan for Priority Public Investment, which is updated annually and defines the priority sectors, policy goals, and indicative public investment ceiling set by the Ministry of Finance. DREAM supports the formation of sectoral project portfolios and the Single Project Pipeline – i.e. the portfolio of priority projects that have been approved by the Strategic Investment Council. DREAM also allows to mirror these central-level processes at the regional and local levels, where each region and municipality is required to form its own Single Project Pipeline of regional and local public investment projects.DREAM is composed of a user portal (e-cabinet), a public portal, and an analytics portal. The user portal allows local, regional, and central authorities to submit their project proposals for funding. The public portal – availablehere– provides access to all approved priority public investment projects in the sectoral portfolios and the Single Project Pipelines at all levels of government. For each project, comprehensive information is publicly available, including: project description and strategic objective(s), detailed budget breakdown and funding source(s), planning and implementation timeline and status; procurement and contracting process; construction and commissioning details. All relevant project documentation – legal and technical – is also published. The analytics portal allows to generate reporting tables and visualisations using filters based on granular project data. It also features an interactive map that allows to explore all projects geographically, down to the local level.DREAM is integrated with other key digital systems, including Prozorro (digital public procurement system) and Open Budget (treasury transaction data). Integration with the Ministry of Finance’s LOGICA system (local budget data) is planned within the next six months.
Commission assessment:satisfactorily fulfilled
1) summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;
2) link to the website of the digital tool for public investment management:DREAM;
3) copy of the Resolution of the Cabinet of Ministers No. 527 ‘On some issues of public investment management’ dated 28 February 2025 and amended on 26 August 2025;
4) copy of the Law of Ukraine No. 4225-IX‘On amendments to the Budget Code of Ukraine concerning the update and improvement of certain provisions’ dated 5 March 2025;
5) copy of the Order of the Ministry for Development of Communities and Territories of Ukraine No. 1289 ‘On the commissioning of the software of the Unified Digital Integrated Information and Analytical System for the Management of the Process of Reconstruction of Real Estate, Construction, and Infrastructures’ dated 20 August 2025;
6) copy of the certificates of works completion.
Name of the step:Entry into force of the law establishing a new court to hear administrative cases
Related reform/investment:Reform 1. Enhancing the accountability, integrity and professionalism of the judiciary
Financed from:loan
ContextThe requirement for Step 3.2 described in the CID Annex is:‘The law on the establishment of the Specialised District Administrative Court and the Specialised Administrative Court of Appeal entered into force and a transparent selection of judges in line with the adopted legislation is launched.’Step 3.2 is the second of six steps in the implementation of Reform 1 of Chapter 3 (judicial system). It is implemented in parallel with Step 3.1 on the filling of at least 20 % of judicial vacancies. It was preceded by Step 3.5 on the entry into force of the legislation revising the declarations of integrity of judges and their verification process, which remains unfulfilled from Q2 2025. It is followed by Step 3.3 on the settlement/adjudication of 20 % of old disciplinary cases not considered as of end of 2023, Step 3.4 on the completion of the qualification evaluation (vetting) in respect of 50 % of judges who still had to undergo it as of 30 September 2016 due in Q4 2025 and Step 3.15 which requires the new court to hear administrative cases to be operational due in Q4 2026.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;2)copy of Law of Ukraine No. 4264-IX ‘On Amendments to the Law of Ukraine “On the Judiciary and the Status of Judges” and Certain Other Legislative Acts of Ukraine Regarding the Legal Basis for the Establishment and Functioning of the Kyiv Specialized District Administrative Court and the Kyiv Specialized Administrative Court of Appeal’dated 26 February 2025;3)copy of the Law of Ukraine No. 4602-IX ‘On the Establishment of the Specialized District Administrative Court, the Specialized Administrative Court of Appeal’ dated 16 September 2025;4)copy of the Notice of the competition for 17 judges in the Specialized District Administrative Court;5)copy of the Notice of the competition for 10 judges in the Specialised Administrative Court of Appeal. 1) summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex; 2) copy of Law of Ukraine No. 4264-IX ‘On Amendments to the Law of Ukraine “On the Judiciary and the Status of Judges” and Certain Other Legislative Acts of Ukraine Regarding the Legal Basis for the Establishment and Functioning of the Kyiv Specialized District Administrative Court and the Kyiv Specialized Administrative Court of Appeal’dated 26 February 2025; 3) copy of the Law of Ukraine No. 4602-IX ‘On the Establishment of the Specialized District Administrative Court, the Specialized Administrative Court of Appeal’ dated 16 September 2025; 4) copy of the Notice of the competition for 17 judges in the Specialized District Administrative Court; 5) copy of the Notice of the competition for 10 judges in the Specialised Administrative Court of Appeal.
1) summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;
2) copy of Law of Ukraine No. 4264-IX ‘On Amendments to the Law of Ukraine “On the Judiciary and the Status of Judges” and Certain Other Legislative Acts of Ukraine Regarding the Legal Basis for the Establishment and Functioning of the Kyiv Specialized District Administrative Court and the Kyiv Specialized Administrative Court of Appeal’dated 26 February 2025;
3) copy of the Law of Ukraine No. 4602-IX ‘On the Establishment of the Specialized District Administrative Court, the Specialized Administrative Court of Appeal’ dated 16 September 2025;
4) copy of the Notice of the competition for 17 judges in the Specialized District Administrative Court;
5) copy of the Notice of the competition for 10 judges in the Specialised Administrative Court of Appeal.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 3.2.The objective of Reform 1 is to enhance the accountability, integrity and professionalism of the judiciary and to build public trust in the judiciary by resuming the transparent and meritocratic selection of judges, boosting the qualification evaluation of sitting judges, strengthening the disciplinary responsibility system, reinforcing existing judicial integrity tools, and establishing a new court to hear administrative cases involving state agencies. To this end the Ukrainian Parliament adopted Law No. 4264-IX, which entered into force on 26 March 2025 and Law No. 4602-IX, which entered into force on 2 October 2025. The laws establish the Specialized District Administrative Court and the Specialized Administrative Court of Appeal.Law No. 4264-IX establishes the legal basis for the Kyiv Specialized District Administrative Court (Specialized District Court) and the Kyiv Specialized Administrative Court of Appeal (Specialized Court of Appeal) as two separate specialized high courts. The law defines the jurisdiction of the new courts stating that the Specialized District Court considers administrative appeals against decisions, actions or inaction of the Cabinet of Ministers of Ukraine, the ministry or other central body of executive power, the National Bank of Ukraine, or another body, whose powers extend nationwide. It has also jurisdiction to e.g. consider appeals against the decisions of the selection commissions responsible for high-level appointments in several state agencies. Specialized Court of Appeal is an appellate instance to Specialized District Court only and will not be reviewing the cases of other district administrative courts.The law No. 4264-IX introduces eligibility requirements for judges of the new courts and provides for a transparent procedure for the selection of judges. It provides for the involvement of a special body, the Expert Council, in the vetting of the judgeship candidates. The Expert Council is composed of six members, three of which are proposed by the Council of Judges of Ukraine and the other three by international and foreign organizations providing Ukraine with international technical assistance in the field of judicial reform and/or preventing and combating corruption. The Expert Council assesses candidates’ integrity and professional competence, in particular, through the right to conduct interviews with the candidates.In line with the Ukrainian legislation, a separate special law No. 4602-IX submitted to the Ukrainian Parliament by the President formally establishes the two courts. It establishes their location as the city of Kyiv and territorial jurisdiction as the entire territory of Ukraine.Following the entry into force of Law No. 4602-IX, on 29 October 2025 High Qualification Commission of Judges launched the selection procedure for 17 judges in the first instance, and 10 judges in the appeal instance.
Commission assessment:satisfactorily fulfilled
1) summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;
2) copy of Law of Ukraine No. 4264-IX ‘On Amendments to the Law of Ukraine “On the Judiciary and the Status of Judges” and Certain Other Legislative Acts of Ukraine Regarding the Legal Basis for the Establishment and Functioning of the Kyiv Specialized District Administrative Court and the Kyiv Specialized Administrative Court of Appeal’dated 26 February 2025;
3) copy of the Law of Ukraine No. 4602-IX ‘On the Establishment of the Specialized District Administrative Court, the Specialized Administrative Court of Appeal’ dated 16 September 2025;
4) copy of the Notice of the competition for 17 judges in the Specialized District Administrative Court;
5) copy of the Notice of the competition for 10 judges in the Specialised Administrative Court of Appeal.
Name of the step:Entry into force of the legislation on the principles for the sale of state-owned banks
Related reform/investment:Reform 2. Reducing state ownership in the banking sector
Financed from:loan
ContextThe requirement for step 5.2 described in the CID annex is:‘Entry into force of the updated legislation on the sale of state-owned banks, namely, the Law of Ukraine “On Divesting State-Owned Shareholdings in the Charter Capital of Banks that Have Undergone Recapitalisation by the State” No. 4524-VI dated 2012. The revised legislation should facilitate the sale of varying ownership stakes in State-owned banks (SOBs), while also providing the flexibility for complete acquisition. The fundamental principles guiding the sale of SOBs will be developed through collaborative discussions and in consensus with the international donors.’Step 5.2 is the first of two steps in the implementation of Reform 2 in Chapter 5 (financial markets). It is followed by Step 5.3 on the adoption of the strategy for gradual reduction of state ownership in the banking sector due in Q2 2026.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’dated 19 September 2024;3)copy the Order of the Cabinet of Ministers of Ukraine No. 1061-r ‘On Preparation for the Sale of State-Owned Share Packages in the Authorised Capital of Banks’dated 1 October 2025. 1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; 2) copy of the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’dated 19 September 2024; 3) copy the Order of the Cabinet of Ministers of Ukraine No. 1061-r ‘On Preparation for the Sale of State-Owned Share Packages in the Authorised Capital of Banks’dated 1 October 2025.
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’dated 19 September 2024;
3) copy the Order of the Cabinet of Ministers of Ukraine No. 1061-r ‘On Preparation for the Sale of State-Owned Share Packages in the Authorised Capital of Banks’dated 1 October 2025.
AnalysisThe justification and evidence provided by the Ukrainian authorities cover all constitutive elements of step 5.2.The objective of Reform 2 is to lay down the principles for the sale of state-owned banks and the strategy for gradually reducing state ownership in the banking sector. To this end, the Ukrainian parliament adopted the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’of 19 September 2024. The Law entered into force on 19 October 2024.The law facilitates the sale of varying ownership stakes in state-owned banks (SOBs) by establishing a unified legal and procedural framework for the divestment of state-held shares. It defines the key terms, objectives, and mechanisms governing such transactions. The framework regulates the preparation, approval, and execution of sales through competitive processes, supported by the engagement of sale advisors and the oversight of a designated sale commission. It provides procedures for determining eligibility, conducting tenders, and concluding sale agreements, while also setting rules for post-sale acquisitions and valuation of controlling interests. Collectively, these provisions enable the state to reduce its participation in the banking sector in a structured and market-oriented manner.The law provides also for the flexibility for complete acquisition, allowing the Government of Ukraine to tailor each transaction to market conditions. It empowers the Cabinet of Ministers of Ukraine to adjust the size of share packages, select the most appropriate sale procedure, and modify the terms prior to bidding. The framework permits repeated tenders and price adjustments to ensure completion, while the involvement of professional sale advisors introduces adaptability in structuring and valuation processes. Furthermore, contractual terms, including applicable foreign law and arbitration clauses, may be customized to meet investor expectations, thereby ensuring both regulatory consistency and commercial flexibility in the privatization process.The fundamental principles governing the sale of SOBs are established through collaborative discussions and consensus with international donors. Specifically, representatives from international financial institutions, EU institutions and EU Member States, as well as other international and foreign organizations providing technical assistance to Ukraine, may participate in the work of the sales commission with their consent. They have the right to express their positions, request and receive information from the sales commission, and provide recommendations regarding the preparation and conduct of the competition.The sales commission has the authority to decide on the approval of a contestant’s risk profile in compliance with the National Bank of Ukraine’s requirements on business reputation and ownership structure; the conduct and procedures of competition; the admission, refusal, or termination of applicants’ participation on grounds prescribed by law; the approval of draft purchase and sale contracts for the bank’s shares, related documents, and/or principal terms of such agreements, including the starting trading price as recommended by the sale advisor; the modification of the number of shares subject to sale; the appointment of new bidding rounds or termination of the tender in cases defined by law upon the advisor’s recommendation; the approval of the tender winner and the final purchase and sale contract for the bank’s block of shares, together with all related documents and the final sale price determined by the bidding results; the recognition of whether bidding has occurred under the conditions set forth by law; and other matters as provided in the sales commission’s regulations, the orders of the Cabinet of Ministers of Ukraine, or as otherwise required for the implementation of the law.Additionally, representatives of international financial institutions, EU institutions and Member States, and other international and foreign organizations providing technical assistance to Ukraine may participate in the selection of a sales advisor, with the right to express opinions, request and receive information, and offer recommendations.
Commission assessment:satisfactorily fulfilled
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’dated 19 September 2024;
3) copy the Order of the Cabinet of Ministers of Ukraine No. 1061-r ‘On Preparation for the Sale of State-Owned Share Packages in the Authorised Capital of Banks’dated 1 October 2025.
Name of the step:Adoption of harmonised standards for three groups of industrial products
Related reform/investment:Reform 5. Harmonisation of legislation and standards with the EU
Financed from:loan
ContextThe requirement for Step 8.8 described in the CID Annex is:‘Harmonised standards for 3 groups of industrial products (machinery, electromagnetic compatibility of equipment, low-voltage electrical equipment) are adopted as national ones by translation method’Step 8.8 is the second step in the implementation of Reform 5 in Chapter 8 (business environment). It follows Step 8.7 on the resumption of market surveillance measures and the control of non-food products, including product safety. Step 8.7 was due in Q4 2024 and was positively assessed as part of the third instalment.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the explanatory table listing the 71 standards that were tendered, translated and adopted;3)copy of the orders of the State Enterprise ‘UkrNDNC’ (Ukraine’s national standardisation body) Nos 310–334 dated 26 December 2024. 1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; 2) copy of the explanatory table listing the 71 standards that were tendered, translated and adopted; 3) copy of the orders of the State Enterprise ‘UkrNDNC’ (Ukraine’s national standardisation body) Nos 310–334 dated 26 December 2024.
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the explanatory table listing the 71 standards that were tendered, translated and adopted;
3) copy of the orders of the State Enterprise ‘UkrNDNC’ (Ukraine’s national standardisation body) Nos 310–334 dated 26 December 2024.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 8.8.The objective of Reform 5 is to resume market surveillance measures and facilitate the adoption of EU norms and standards in Ukraine, particularly in the areas of industrial products. To this end, Ukraine has adopted harmonised standards for three priority product groups – machinery, electromagnetic-compatibility (EMC) equipment and low-voltage electrical equipment – as national State Standards of Ukraine (DSTU) standards by the translation method. Through a series of open tenders in 2024, the national standardisation body contracted, translated and formally approved 71 DSTU EN / DSTU EN IEC / DSTU EN ISO standards. Each of the standards was enacted by Ministry of Economy Orders Nos 310–334 of 26 December 2024 and linked to the relevant EU directives 2006/42/EC (Machinery), 2014/30/EU (EMC) and 2014/35/EU (Low-Voltage Directive).—Machinery: 43 translations, notably DSTU EN ISO 13849-1:2024 (general principles of machine-safety control systems) and DSTU EN 474-1:2022 (earth-moving machinery – general safety).—EMC-related equipment: 4 translations, e.g. DSTU EN 60947-8:2015 (devices with embedded thermal protection for rotating machines) and DSTU EN 62196-1:2015 (connectors for conductive charging of electric vehicles).—Low-voltage electrical equipment: 24 translations, including DSTU EN IEC 62477-1:2024 (power electronic converters) and DSTU EN IEC 62052-11:2024 (electricity meters), together with 16 household-appliance standards in the EN 60335-2-xx series. — Machinery: 43 translations, notably DSTU EN ISO 13849-1:2024 (general principles of machine-safety control systems) and DSTU EN 474-1:2022 (earth-moving machinery – general safety). — EMC-related equipment: 4 translations, e.g. DSTU EN 60947-8:2015 (devices with embedded thermal protection for rotating machines) and DSTU EN 62196-1:2015 (connectors for conductive charging of electric vehicles). — Low-voltage electrical equipment: 24 translations, including DSTU EN IEC 62477-1:2024 (power electronic converters) and DSTU EN IEC 62052-11:2024 (electricity meters), together with 16 household-appliance standards in the EN 60335-2-xx series.
— Machinery: 43 translations, notably DSTU EN ISO 13849-1:2024 (general principles of machine-safety control systems) and DSTU EN 474-1:2022 (earth-moving machinery – general safety).
— EMC-related equipment: 4 translations, e.g. DSTU EN 60947-8:2015 (devices with embedded thermal protection for rotating machines) and DSTU EN 62196-1:2015 (connectors for conductive charging of electric vehicles).
— Low-voltage electrical equipment: 24 translations, including DSTU EN IEC 62477-1:2024 (power electronic converters) and DSTU EN IEC 62052-11:2024 (electricity meters), together with 16 household-appliance standards in the EN 60335-2-xx series.
Commission assessment:satisfactorily fulfilled
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the explanatory table listing the 71 standards that were tendered, translated and adopted;
3) copy of the orders of the State Enterprise ‘UkrNDNC’ (Ukraine’s national standardisation body) Nos 310–334 dated 26 December 2024.
— Machinery: 43 translations, notably DSTU EN ISO 13849-1:2024 (general principles of machine-safety control systems) and DSTU EN 474-1:2022 (earth-moving machinery – general safety).
— EMC-related equipment: 4 translations, e.g. DSTU EN 60947-8:2015 (devices with embedded thermal protection for rotating machines) and DSTU EN 62196-1:2015 (connectors for conductive charging of electric vehicles).
— Low-voltage electrical equipment: 24 translations, including DSTU EN IEC 62477-1:2024 (power electronic converters) and DSTU EN IEC 62052-11:2024 (electricity meters), together with 16 household-appliance standards in the EN 60335-2-xx series.
Name of the step:Entry into force of the legislation on reforming of territorial organisation of the executive authorities in Ukraine with delayed application
Related reform/investment:Reform 1. Advancing decentralisation
Financed from:loan/non-repayable support
ContextThe requirement for Step 9.1 described in the CID Annex is:‘Entry into force of the Law of Ukraine “On Amendments to the Law of Ukraine ‘On Local State Administrations’ and Some Other Legislative Acts of Ukraine as Regards the Reforming of Territorial Organisation of the Executive Authorities in Ukraine” with its application within 12 months from the date of termination or abolition of martial law in Ukraine. Subordinate legal acts for the implementation of the law shall be adopted after it enters into force. The law focuses on these main areas:—transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies;—ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.’Step 9.1 is the first of three steps in the implementation of Reform 1 of Chapter 9 (decentralisation and regional policy). — transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies; — ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.’
— transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies;
— ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.’
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Law of Ukraine No. 4677-IX on‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’dated 5 November 2025. 1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; 2) copy of the Law of Ukraine No. 4677-IX on‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’dated 5 November 2025.
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Law of Ukraine No. 4677-IX on‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’dated 5 November 2025.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 9.1.The objective of Reform 1 is to put in place a framework for transforming local state administrations into prefecture-type authorities and to ensure a better distribution of powers between local governments and executive authorities. To this end, the law on ‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’was adopted by the Verkhovna Rada on 5 November and entered into force on 12 November 2025, with application delayed by 12 months from the date of termination or cancellation of martial law in Ukraine.The law initiates the transformation of local state administrations into prefecture-type of authorities by establishing a system of supervision of the legality of local self-government acts. The law defines the scope, the responsibilities and the procedures for ensuring the legality of acts of local self-government bodies. The law introduces measures aimed at preventing the violation of the legality of activities of local self-government bodies; including a mechanism for ensuring that local self-government bodies are informed about changes in the legislation related to local self-government and, in case of disputes, may have recourse for court.The law establishes a mechanism for enhancing coordination. The law identifies the heads of local state administrations as responsible for coordination and for ensuring the legality in the activities of territorial bodies of ministries and other central executive bodies.
Commission assessment:satisfactorily fulfilled
— transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies;
— ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.’
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Law of Ukraine No. 4677-IX on‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’dated 5 November 2025.
Name of the step:Entry into force of the legislation on the public support of agriculture of Ukraine
Related reform/investment:Reform 3. Improving the institutional and administrative set up for managing investment programmes
Financed from:loan
ContextThe requirement for Step 12.4 described in the CID Annex is:‘Entry into force of the Law on Amendments to the Law of Ukraine “On State Support of Agriculture of Ukraine”. The Law focuses on these main areas:—design future public support measures in line with the principles of the EU acquis in this area. The selection of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT);—design measures to support agricultural production for small scale farms to undertake private investments (physical assets of agricultural holdings producers, for processing and marketing);—design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions;—digitalisation through electronic document management systems;—state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.’Step 12.4 is the only step of Reform 3 of Chapter 12 (agri-food sector). — design future public support measures in line with the principles of the EU acquis in this area. The selection of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT); — design measures to support agricultural production for small scale farms to undertake private investments (physical assets of agricultural holdings producers, for processing and marketing); — design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions; — digitalisation through electronic document management systems; — state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.’
— design future public support measures in line with the principles of the EU acquis in this area. The selection of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT);
— design measures to support agricultural production for small scale farms to undertake private investments (physical assets of agricultural holdings producers, for processing and marketing);
— design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions;
— digitalisation through electronic document management systems;
— state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.’
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Law of Ukraine No. 4619-IX‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’dated 8 October 2025. 1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; 2) copy of the Law of Ukraine No. 4619-IX‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’dated 8 October 2025.
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Law of Ukraine No. 4619-IX‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’dated 8 October 2025.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 12.4.The objective of the Reform 3 is to improve the set up for managing public financial support schemes to the agri-food sector. The Parliament adopted the Law of Ukraine No. 4619-IX ‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’on 8 October 2025. The law entered into force on 4 November 2025.The law designs future public support measures in line with the principles of the EU acquis in the area of agriculture and rural development. It sets the provisions in line with the principles of the current Common Agricultural Policy (CAP). It specifies the overall aim, objectives of the agriculture and rural development policy and measures for implementing this policy. Based on the overall aim and objectives, the multiannual Strategy for the Development of Agriculture and Rural Territories will be developed, and the choice of national support measures and types of support will be selected on the basis of a comprehensive analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT).The law sets out the structures on the financing, management and monitoring of state support for agriculture and rural development. It provides for the establishment of the responsible authorities defining their tasks – such as a Paying Agency, Certification bodies, and the Central Executive Body, which ensures the formation and implementation of the national policy of agriculture and rural development.The law introduces provisions, amongst others, on the separation of policymaking and payment functions, on the institutional independence of the Paying Agency and on the detailed tasks of the Paying Agency for administering national support for agriculture and rural development, particularly on transparency and accountability, verification and authorisation of payments, performing administrative checks and on-site inspections to control eligibility for support.Small agricultural producers are the priority recipients of state support. The criteria for classifying agricultural producers as small producers will be determined for each type of support. The law also defines measures for the implementation of national support for agriculture and rural development, including investments in physical assets of agricultural producers to improve efficiency, competitiveness and sustainable agricultural production. Similarly, associations of agricultural producers can be supported in the marketing of agricultural products.The law authorises the design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with international financial institutions for the implementation of agriculture and rural development policy.The law aims to promote digitalisation through electronic document management systems. The law provides the legal basis for the development of the Integrated Administration and Control System (IACS), which will function together with other already existing systems as electronic document management systems for the administration of national support for agriculture and rural development.The law requires state support to be exclusively channelled to the beneficiaries enlisted in the State Agrarian Register. Entities which are not registered in the State Agrarian Register are excluded from receiving state support.
Commission assessment:satisfactorily fulfilled
— design future public support measures in line with the principles of the EU acquis in this area. The selection of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT);
— design measures to support agricultural production for small scale farms to undertake private investments (physical assets of agricultural holdings producers, for processing and marketing);
— design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions;
— digitalisation through electronic document management systems;
— state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.’
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Law of Ukraine No. 4619-IX‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’dated 8 October 2025.
Name of the step:Publishing of a report on the verification of Critical Raw Materials’ reserves of Ukraine
Related reform/investment:Reform 1. Strengthening strategic planning and ensuring optimum framework for strategic investors
Financed from:loan
ContextThe requirement for step 13.2 described in the CID Annex is:‘Publication of a report on the verification of Critical Raw Materials reserves of Ukraine using international classification system and results are made available to investors.’Step 13.2 is the second step in the implementation of Reform 1 of Chapter 13 (management of critical raw materials). It was preceded by Step 13.1 on the entry into force of the legislation on revising the National Programme for the Development of the Mineral Resource Base of Ukraine to 2030 which was positively assessed in Q4 2024 as part of the third instalment.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of ‘Report on the verification of Critical Raw Materials reserves of Ukraine using international classification system’,published on the website of the Ukrainian Geological Survey:Strategic/Critical Mineral Reserves Verification Report 1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; 2) copy of ‘Report on the verification of Critical Raw Materials reserves of Ukraine using international classification system’,published on the website of the Ukrainian Geological Survey:Strategic/Critical Mineral Reserves Verification Report
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of ‘Report on the verification of Critical Raw Materials reserves of Ukraine using international classification system’,published on the website of the Ukrainian Geological Survey:Strategic/Critical Mineral Reserves Verification Report
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 13.2.The objective of Reform 1 is to attract investments in the extraction and processing of critical raw materials.The report on the verification of Critical Raw Materials’ reserves of Ukraine is published on the official website of the Geological Survey with the hyperlink:Strategic/Critical Mineral Reserves Verification Report.The report uses international classification system UNFC –United Nations Framework Classification for Resources,that was endorsed by the United Nations Economic and Social Council in 2004 and remains an important tool to analyse the availability and sustainability of critical resources.The 2019 version of the UNFC is a classification system for resource development projects based on the following principles:—environmental and socio-economic viability;—technical feasibility;—commercial potential of raw materials projects.The results are made available to investors by being published on the website. — environmental and socio-economic viability; — technical feasibility; — commercial potential of raw materials projects.
— environmental and socio-economic viability;
— technical feasibility;
— commercial potential of raw materials projects.
Commission assessment:satisfactorily fulfilled
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of ‘Report on the verification of Critical Raw Materials reserves of Ukraine using international classification system’,published on the website of the Ukrainian Geological Survey:Strategic/Critical Mineral Reserves Verification Report
— environmental and socio-economic viability;
— technical feasibility;
— commercial potential of raw materials projects.
Name of the step:Adoption of the second Nationally Determined Contribution of Ukraine to the Paris Agreement
Related reform/investment:Reform 2. Climate policy
Financed from:loan
ContextThe requirement for step 15.4 described in the CID Annex is:‘Adoption of the Order of the Cabinet of Ministers of Ukraine “On Approval of the Second Nationally Determined Contribution (NDC) of Ukraine to the Paris Agreement”. The NDC focuses on these main areas:—higher emission reduction target than in the current NDC of Ukraine;—establishing a base year for calculating emissions from sources and sinks of greenhouse gases;—duration of implementation and/or time periods of the proposed measures;—scope and coverage of economic sectors and greenhouse gases;—process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases;—justification of the equity and ambition of the NDC in the light of national circumstances;—contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.The Second NDC of Ukraine to the Paris Agreement will be more ambitious than the current Updated NDC.’Step 15.4 is the second step in the implementation of Reform 2, of Chapter 15 (green transition and environmental protection). Step 15.2 on the entry into force of the legislation on the State Climate Policy was positively assessed in Q1 2025 as part of the fourth instalment. Step 15.4 will be followed by step 15.3 on the adoption of the resolution on the Scientific and Expert Council on Climate Change and Preservation of the Ozone Layer in Q4 2025. — higher emission reduction target than in the current NDC of Ukraine; — establishing a base year for calculating emissions from sources and sinks of greenhouse gases; — duration of implementation and/or time periods of the proposed measures; — scope and coverage of economic sectors and greenhouse gases; — process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases; — justification of the equity and ambition of the NDC in the light of national circumstances; — contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.
— higher emission reduction target than in the current NDC of Ukraine;
— establishing a base year for calculating emissions from sources and sinks of greenhouse gases;
— duration of implementation and/or time periods of the proposed measures;
— scope and coverage of economic sectors and greenhouse gases;
— process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases;
— justification of the equity and ambition of the NDC in the light of national circumstances;
— contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Order of the Cabinet of Ministers of Ukraine No. 1172-r of 29 October 2025‘On approval of Ukraine’s second nationally determined contribution to the Paris Agreement’;3)copy of the annex to the Order of the Cabinet of Minister of Ukraine No. 1172-r of 29 October 2025 on ‘Ukraine’s second nationally determined contribution to the Paris Agreement’. 1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; 2) copy of the Order of the Cabinet of Ministers of Ukraine No. 1172-r of 29 October 2025‘On approval of Ukraine’s second nationally determined contribution to the Paris Agreement’; 3) copy of the annex to the Order of the Cabinet of Minister of Ukraine No. 1172-r of 29 October 2025 on ‘Ukraine’s second nationally determined contribution to the Paris Agreement’.
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Order of the Cabinet of Ministers of Ukraine No. 1172-r of 29 October 2025‘On approval of Ukraine’s second nationally determined contribution to the Paris Agreement’;
3) copy of the annex to the Order of the Cabinet of Minister of Ukraine No. 1172-r of 29 October 2025 on ‘Ukraine’s second nationally determined contribution to the Paris Agreement’.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 15.4.The objective of Reform 2, climate policy, is to create an architecture for climate governance as well as an appropriate mechanism for the development and implementation of state policy in the field of climate change in Ukraine.The Order of the Cabinet of Ministers of Ukraine ‘On Approval of the Second Nationally Determined Contribution (NDC) of Ukraine to the Paris Agreement’ was adopted on 29 October 2025. It sets an emission reduction target (including absorption) ‘more than 65 %’ from the 1990 level in 2035. The previous updated NDC aimed for a 65 % reduction by 2030. The base year for calculation is 1990, with the reference indicator being the emissions for that year assessed by the national report on the inventory of anthropogenic emissions from GHG emission sources and removals.The second NDC of Ukraine explains that, due to Russia’s war of aggression, ‘the planning of more ambitious emission reduction targets is objectively limited due to the extremely high level of uncertainty about the scale of recovery, the dynamics of economic growth, the future structure of the energy balance and the rate of decarbonisation’.The duration of implementation for the second NDC is from 1 January 2031 to 31 December 2035, and the goal is established as a target for the year 2035. Sectors covered by the second NDC include energy, industrial processes and product use; agriculture, land use, land-use change and forestry; and waste. It covers all greenhouse gases not regulated by the Montreal Protocol.The process planning is coordinated by the relevant line ministry, with national governance based on the Law of Ukraine No. 3991-IX ‘On the Basic Principles of State Climate Policy’. The estimation and accounting use the approach of comparing total emissions in the target year to the total emissions in the base year and relies on the 2006 IPCC Guidelines and employs mathematical models to develop three forecast scenarios up to 2050.The assessment above is valid only in the context of the Ukraine Plan’s implementation. The level of climate ambition of Ukraine in the context of EU accession is being addressed separately.
Commission assessment:satisfactorily fulfilled
— higher emission reduction target than in the current NDC of Ukraine;
— establishing a base year for calculating emissions from sources and sinks of greenhouse gases;
— duration of implementation and/or time periods of the proposed measures;
— scope and coverage of economic sectors and greenhouse gases;
— process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases;
— justification of the equity and ambition of the NDC in the light of national circumstances;
— contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Order of the Cabinet of Ministers of Ukraine No. 1172-r of 29 October 2025‘On approval of Ukraine’s second nationally determined contribution to the Paris Agreement’;
3) copy of the annex to the Order of the Cabinet of Minister of Ukraine No. 1172-r of 29 October 2025 on ‘Ukraine’s second nationally determined contribution to the Paris Agreement’.
Name of the step:Adoption of the National Waste Management Plan until 2033
Related reform/investment:Reform 5. Increased circular economy
Financed from:loan
ContextThe requirement for step 15.9 described in the CID Annex is:‘Adoption of the Order of the Cabinet of Ministers of Ukraine “On Approval of the National Waste Management Plan until 2033”. The National Waste Management Plan focuses on these main areas:—household waste management;—hazardous waste management;—infrastructure needs;—economic and financial sustainability analyses of the action plan;—implementation of economic instruments to improve waste management;—monitoring and control of waste management;—strategic planning of waste management in Ukraine;—implementation of waste management at the regional level.’Step 15.9 is the first step in the implementation of Reform 5 of Chapter 15 (Green Transition and Environmental Protection). Step 15.9 is followed by Step 15.8 on the adoption of a strategy for implementing the principles of the circular economy and an action plan for its implementation in Q1 2026. — household waste management; — hazardous waste management; — infrastructure needs; — economic and financial sustainability analyses of the action plan; — implementation of economic instruments to improve waste management; — monitoring and control of waste management; — strategic planning of waste management in Ukraine; — implementation of waste management at the regional level.’
— household waste management;
— hazardous waste management;
— infrastructure needs;
— economic and financial sustainability analyses of the action plan;
— implementation of economic instruments to improve waste management;
— monitoring and control of waste management;
— strategic planning of waste management in Ukraine;
— implementation of waste management at the regional level.’
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Order of the Cabinet of Ministers No. 1353-r on the‘Approval of the National Waste Management Plan until 2033’dated 27 December 2024.;3)copy of the annex to the Cabinet of Ministers No. 1353-r on the ‘National Waste Management Plan until 2033’ dated 27 December 2024. 1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; 2) copy of the Order of the Cabinet of Ministers No. 1353-r on the‘Approval of the National Waste Management Plan until 2033’dated 27 December 2024.; 3) copy of the annex to the Cabinet of Ministers No. 1353-r on the ‘National Waste Management Plan until 2033’ dated 27 December 2024.
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Order of the Cabinet of Ministers No. 1353-r on the‘Approval of the National Waste Management Plan until 2033’dated 27 December 2024.;
3) copy of the annex to the Cabinet of Ministers No. 1353-r on the ‘National Waste Management Plan until 2033’ dated 27 December 2024.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 15.9.The objective of Reform 5 is to implement the principles of circular economy and waste management. To this end, Cabinet of Ministers adopted the National Waste Management Plan until 2033 (National Plan) on 27 December 2024.In the National Plan, household waste is comprehensively defined to include mixed and separately collected waste from households, which also accounts for hazardous components contained within. The current waste management system in Ukraine largely relies on low-level technologies, leading to the direct disposal of waste primarily in landfills and dumps. Despite existing efforts, the coverage of the population by separate waste collection programs remains low, at only about 30 %.The primary sources of hazardous waste are identified as industrial, agricultural, and transport enterprises, alongside healthcare facilities and households. While the annual volume of hazardous waste significantly decreased in a post-war period from 2010 to 2022, the efficiency of management is still inadequate.In terms of infrastructure needs, the National Plan serves as a framework document, meaning the specific infrastructure objects, technologies, and economic calculations are to be detailed in regional and local waste management plans. The successful execution of the plan is expected to establish the necessary conditions to attract both financing and investments into the sector. The regional and local plans, which derive from the National Plan, are explicitly required to include economic calculations and an assessment of their implementation capacity. The National Plan mandates the implementation of essential economic instruments, including the polluter pays principle and extended producer responsibility. The document also emphasizes the need to achieve a high level of recycling to return secondary raw materials into economic circulation.A key anticipated outcome of the National Plan’s implementation is a general improvement in the system for monitoring and control over all waste management activities. The National Plan functions as the primary framework document that defines the major strategic directions for state policy in the waste management sector until 2033. Consequently, it forms the foundation for strategic planning and the development of specific measures at the regional, local, enterprise, and institutional levels. Forecasts for future waste generation volumes are strategically based on projections related to population size and the expected development of the country’s production potential and infrastructure. In accordance with the Law, local self-government bodies are responsible for ensuring household waste management and guaranteeing that services are provided to every waste generator within their territory. To improve efficiency, territorial communities are encouraged to cooperate, including through joint financing for the construction, reconstruction, and maintenance of household waste processing facilities. All regional and local plans developed under the National Plan must account for specific local conditions and required economic calculations.
Commission assessment:satisfactorily fulfilled
— household waste management;
— hazardous waste management;
— infrastructure needs;
— economic and financial sustainability analyses of the action plan;
— implementation of economic instruments to improve waste management;
— monitoring and control of waste management;
— strategic planning of waste management in Ukraine;
— implementation of waste management at the regional level.’
1) summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) copy of the Order of the Cabinet of Ministers No. 1353-r on the‘Approval of the National Waste Management Plan until 2033’dated 27 December 2024.;
3) copy of the annex to the Cabinet of Ministers No. 1353-r on the ‘National Waste Management Plan until 2033’ dated 27 December 2024.
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February 2024 establishing the Ukraine Facility(1), and in particular Article 26(4) thereof,
Having regard to the proposal from the European Commission,
(1) Pillar I of the Ukraine Facility (the ‘Facility’), established by Regulation (EU) 2024/792, makes financial support of up to EUR 38 337 000 000(2)available to Ukraine for the period 2024-2027 in the form of non-repayable support and a loan. Financing under Pillar I is mainly allocated on the basis of the Ukraine Plan of the Ukraine Facility (the ‘Plan’), approved by Council Implementing Decision (EU) 2024/1447(3), as amended by Council Implementing Decision (EU) 2025/2157(4). The Plan sets out Ukraine’s reform and investment agenda, and the qualitative and quantitative steps that are linked to funding under Pillar I of the Facility.
(2) The timetable for monitoring and implementing the Plan, including the qualitative and quantitative steps that are linked to funding under Pillar I of the Facility, is set out in the Annex to Implementing Decision (EU) 2024/1447, as amended by Implementing Decision (EU) 2025/2157.
(3) The total sum of financial resources made available for the Plan amounts to EUR 32 337 000 000, of which EUR 5 337 000 000 is in the form of non-repayable financial support and up to EUR 27 000 000 000 is in the form of a loan.
(4) In accordance with Articles 24 and 25 of Regulation (EU) 2024/792, EUR 6 000 000 000 has been disbursed to Ukraine as exceptional bridge financing and EUR 1 890 000 000 in the form of pre-financing, representing an advance payment of 7 % of the loan support that Ukraine is eligible to receive under the Plan.
(5) In accordance with Article 26(4) of Regulation (EU) 2024/792, EUR 16 576 146 834 has been disbursed to Ukraine in the first five instalments under the Plan, of which EUR 3 400 000 000 has been disbursed in the form of non-repayable financial support and EUR 13 176 146 834 in the form of a loan. In accordance with the Loan Agreement concluded between the Union and Ukraine pursuant to Article 22 of Regulation (EU) 2024/792, an amount of EUR 991 752 987 from the first five instalments was used to clear the pre-financing of the loan.
(6) In accordance with Article 26(2) of Regulation (EU) 2024/792, on 31 October 2025 Ukraine submitted a duly justified request for the payment of part of the sixth instalment of the loan support. On 11 November 2025, it submitted an updated request to take into account the adoption of an outstanding step under the fourth instalment. Pursuant to Article 26(5) of Regulation (EU) 2024/792, a withheld payment is to be disbursed only when Ukraine has duly justified, as part of a subsequent payment request, that it has taken the necessary measures to ensure satisfactory fulfilment of the qualitative and quantitative steps. The request was accompanied by a series of documents evidencing the satisfactory fulfilment of one step under the fourth instalment and eight steps under the sixth instalment. It also submitted all documents required under Article 12 of the Framework Agreement, Article 5 of the Financing Agreement and Article 6 of the Loan Agreement concluded between the Union and Ukraine pursuant to Articles 9, 10 and 22, respectively, of Regulation (EU) 2024/792.
(7) The steps underpinning Ukraine’s latest request relate to various reforms set out in the Plan under the chapters on public finance management, the judicial system, financial markets, human capital, the business environment, decentralisation and regional policy, the management of critical raw materials, and the green transition and environmental protection. The digital management tool for the reconstruction of Ukraine has been developed and implemented. The law establishing a new court to hear administrative cases, the legislation on the principles for the sale of state-owned banks, the law on reforming the territorial organisation of the executive authorities in Ukraine and the legislation on public support for agriculture have entered into force. Harmonised standards for three groups of industrial products, the second Nationally Determined Contribution of Ukraine to the Paris Agreement adopted under the United Nations Framework Convention on Climate Change and the National Waste Management Plan until 2033 have been adopted. A report on the verification of Ukraine’s reserves of critical raw materials has been published.
(8) In accordance with Article 26(3) of Regulation (EU) 2024/792, the Commission has assessed Ukraine’s request in detail and made a positive assessment of the satisfactory fulfilment of one of the two outstanding steps required for the fourth instalment and eight of the ten steps required for the sixth instalment, as specified in the Annex to this Decision. The positive assessment has been made in the context of the implementation of the Plan. Further alignment with the Unionacquiswill be facilitated through the Union accession process.
(9) In its payment request, Ukraine confirmed that it has not reversed any measure related to the steps which it had previously satisfactorily fulfilled.
(10) The Commission has further assessed that Ukraine continues to fulfil the pre-condition for Union support set out in Article 5 of Regulation (EU) 2024/792. In particular, Ukraine continues to uphold and respect effective democratic mechanisms, including a multi-party parliamentary system and the rule of law, and to guarantee respect for human rights, including the rights of persons belonging to minorities.
(11) This Decision should therefore establish that the relevant conditions for the payment of the fourth instalment in respect of one of the two outstanding steps and of the sixth instalment in respect of eight of the ten steps under the Plan have been satisfactorily fulfilled.
(12) Considering the difficult financial situation Ukraine is facing, it is of the utmost importance to disburse the funds as soon as possible. Given the urgency of the situation and with a view to expediting the process, this Decision should enter into force on the date of its publication in theOfficial Journal of the European Unionand should apply from the date of its adoption,
HAS ADOPTED THIS DECISION:
The satisfactory fulfilment of the relevant conditions for the partial payment of the fourth and sixth instalments of the non-repayable financial support and of the loan support amounting to EUR 2 456 365 209, before clearing the pre-financing, out of which EUR 597 494 240 corresponds to the fourth instalment and EUR 1 858 870 969 corresponds to the sixth instalment, is hereby established in line with the assessment provided by the Commission in accordance with Article 26 of Regulation (EU) 2024/792 and annexed to this Decision.
This Decision shall enter into force on the date of its publication in theOfficial Journal of the European Union.
It shall apply from the date of its adoption.

EXECUTIVE SUMMARY

ANNEXto the Council Implementing Decision establishing the satisfactory fulfilment of the conditions for the partial payment of the sixth instalment under the Ukraine Plan of the Ukraine FacilityOn 31 October 2025, Ukraine submitted a request for a partial payment of the sixth instalment of the Ukraine Plan, in accordance with Article 26 of Regulation (EU) 2024/792 of 29 February 2024 establishing the Ukraine Facility(1). On 11 November 2025, Ukraine submitted the updated request for the payment declaring the satisfactory fulfilment of one step outstanding from the fourth instalment. To support the payment request, Ukraine provided justification of the satisfactory fulfilment of one step in the fourth instalment and eight steps in the sixth instalment as set out in the Annex to Council Implementing Decision (EU) 2024/1447 of 14 May 2024 on the approval of the assessment of the Ukraine Plan(2), as amended by Council Implementing Decision (EU) 2025/2157 (‘the CID Annex’)(3).
Based on the information provided by Ukraine, nine steps are considered to have been satisfactorily fulfilled.
As part ofChapter 2on public financial management, the digital management tool for the reconstruction of Ukraine has been developed and implemented.
As part ofChapter 3on judicial system, the law establishing a new court to hear administrative cases entered into force.
As part ofChapter 5on financial markets, updated legislation on the sale of state-owned banks entered into force.
As part ofChapter 8on business environment, harmonised standards for three groups of industrial products were adopted.
As part ofChapter 9on decentralisation and regional policy, legislation on reforming of territorial organisation of the executive authorities in Ukraine entered into force.
As part ofChapter 12on agri-food sector, legislation on the public support of agriculture of Ukraine entered into force.
As part ofChapter 13on management of critical raw materials, the report on the verification of Critical Raw Materials’ reserves of Ukraine was published.
As part ofChapter 15on green transition and environmental protection, the second Nationally Determined Contribution of Ukraine to the Paris Agreement and National Waste Management Plan until 2033 were adopted.

Step 2.8

Name of the step:Development and implementation of the digital management tool for the reconstruction of Ukraine
Related reform/investment:Reform 4. Improved public investment management
Financed from:loan
ContextThe requirement for Step 2.8 described in the CID Annex is:‘Development and implementation of the digital management tool for the reconstruction of Ukraine, which provides public access to data on reconstruction projects at all stages, including planning, financing, procurement, construction and commissioning, to enable a public and transparent monitoring of project implementation and better coordination of reconstruction efforts between sectors.’Step 2.8 is the second of two steps in the implementation of Reform 4 of Chapter 2 (public financial management). It was preceded by Step 2.7 (Q2 2024) on the adoption of the action plan for the implementation of the roadmap for reforming public investment management.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;2)link to the website of the digital tool for public investment management:DREAM;3)copy of the Resolution of the Cabinet of Ministers No. 527 ‘On some issues of public investment management’ dated 28 February 2025 and amended on 26 August 2025;4)copy of the Law of Ukraine No. 4225-IX‘On amendments to the Budget Code of Ukraine concerning the update and improvement of certain provisions’ dated 5 March 2025;5)copy of the Order of the Ministry for Development of Communities and Territories of Ukraine No. 1289 ‘On the commissioning of the software of the Unified Digital Integrated Information and Analytical System for the Management of the Process of Reconstruction of Real Estate, Construction, and Infrastructures’ dated 20 August 2025;6)copy of the certificates of works completion. | 1) | summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex; | 2) | link to the website of the digital tool for public investment management:DREAM; | 3) | copy of the Resolution of the Cabinet of Ministers No. 527 ‘On some issues of public investment management’ dated 28 February 2025 and amended on 26 August 2025; | 4) | copy of the Law of Ukraine No. 4225-IX‘On amendments to the Budget Code of Ukraine concerning the update and improvement of certain provisions’ dated 5 March 2025; | 5) | copy of the Order of the Ministry for Development of Communities and Territories of Ukraine No. 1289 ‘On the commissioning of the software of the Unified Digital Integrated Information and Analytical System for the Management of the Process of Reconstruction of Real Estate, Construction, and Infrastructures’ dated 20 August 2025; | 6) | copy of the certificates of works completion.
1) | summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;
2) | link to the website of the digital tool for public investment management:DREAM;
3) | copy of the Resolution of the Cabinet of Ministers No. 527 ‘On some issues of public investment management’ dated 28 February 2025 and amended on 26 August 2025;
4) | copy of the Law of Ukraine No. 4225-IX‘On amendments to the Budget Code of Ukraine concerning the update and improvement of certain provisions’ dated 5 March 2025;
5) | copy of the Order of the Ministry for Development of Communities and Territories of Ukraine No. 1289 ‘On the commissioning of the software of the Unified Digital Integrated Information and Analytical System for the Management of the Process of Reconstruction of Real Estate, Construction, and Infrastructures’ dated 20 August 2025;
6) | copy of the certificates of works completion.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 2.8.The objective of Reform 4 is to improve public investment management. To this end, the Ukrainian authorities have developed and implemented a digital tool for managing reconstruction projects, in line with the roadmap for reforming public investment management.The Digital Restoration Ecosystem for Accountable Management (DREAM) was developed by the Open Contracting Partnership in cooperation with the Ministry for Development of Communities and Territories of Ukraine. DREAM serves as the unified digital platform for managing public investment projects at all levels of government. It provides public access to real-time information at every stage of a project’s lifecycle, ensuring transparency and accountability. By consolidating all project data into a single system, DREAM enables continuous public and donor monitoring throughout the public investment cycle – from project preparation to implementation – and better coordination of reconstruction efforts between government tiers.DREAM enables line ministries to submit their proposed annual public investment projects for funding, guided by the Medium-Term Plan for Priority Public Investment, which is updated annually and defines the priority sectors, policy goals, and indicative public investment ceiling set by the Ministry of Finance. DREAM supports the formation of sectoral project portfolios and the Single Project Pipeline – i.e. the portfolio of priority projects that have been approved by the Strategic Investment Council. DREAM also allows to mirror these central-level processes at the regional and local levels, where each region and municipality is required to form its own Single Project Pipeline of regional and local public investment projects.DREAM is composed of a user portal (e-cabinet), a public portal, and an analytics portal. The user portal allows local, regional, and central authorities to submit their project proposals for funding. The public portal – availablehere– provides access to all approved priority public investment projects in the sectoral portfolios and the Single Project Pipelines at all levels of government. For each project, comprehensive information is publicly available, including: project description and strategic objective(s), detailed budget breakdown and funding source(s), planning and implementation timeline and status; procurement and contracting process; construction and commissioning details. All relevant project documentation – legal and technical – is also published. The analytics portal allows to generate reporting tables and visualisations using filters based on granular project data. It also features an interactive map that allows to explore all projects geographically, down to the local level.DREAM is integrated with other key digital systems, including Prozorro (digital public procurement system) and Open Budget (treasury transaction data). Integration with the Ministry of Finance’s LOGICA system (local budget data) is planned within the next six months.
Commission assessment:satisfactorily fulfilled
Step 3.2

Name of the step:Entry into force of the law establishing a new court to hear administrative cases
Related reform/investment:Reform 1. Enhancing the accountability, integrity and professionalism of the judiciary
Financed from:loan
ContextThe requirement for Step 3.2 described in the CID Annex is:‘The law on the establishment of the Specialised District Administrative Court and the Specialised Administrative Court of Appeal entered into force and a transparent selection of judges in line with the adopted legislation is launched.’Step 3.2 is the second of six steps in the implementation of Reform 1 of Chapter 3 (judicial system). It is implemented in parallel with Step 3.1 on the filling of at least 20 % of judicial vacancies. It was preceded by Step 3.5 on the entry into force of the legislation revising the declarations of integrity of judges and their verification process, which remains unfulfilled from Q2 2025. It is followed by Step 3.3 on the settlement/adjudication of 20 % of old disciplinary cases not considered as of end of 2023, Step 3.4 on the completion of the qualification evaluation (vetting) in respect of 50 % of judges who still had to undergo it as of 30 September 2016 due in Q4 2025 and Step 3.15 which requires the new court to hear administrative cases to be operational due in Q4 2026.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;2)copy of Law of Ukraine No. 4264-IX ‘On Amendments to the Law of Ukraine “On the Judiciary and the Status of Judges” and Certain Other Legislative Acts of Ukraine Regarding the Legal Basis for the Establishment and Functioning of the Kyiv Specialized District Administrative Court and the Kyiv Specialized Administrative Court of Appeal’dated 26 February 2025;3)copy of the Law of Ukraine No. 4602-IX ‘On the Establishment of the Specialized District Administrative Court, the Specialized Administrative Court of Appeal’ dated 16 September 2025;4)copy of the Notice of the competition for 17 judges in the Specialized District Administrative Court;5)copy of the Notice of the competition for 10 judges in the Specialised Administrative Court of Appeal. | 1) | summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex; | 2) | copy of Law of Ukraine No. 4264-IX ‘On Amendments to the Law of Ukraine “On the Judiciary and the Status of Judges” and Certain Other Legislative Acts of Ukraine Regarding the Legal Basis for the Establishment and Functioning of the Kyiv Specialized District Administrative Court and the Kyiv Specialized Administrative Court of Appeal’dated 26 February 2025; | 3) | copy of the Law of Ukraine No. 4602-IX ‘On the Establishment of the Specialized District Administrative Court, the Specialized Administrative Court of Appeal’ dated 16 September 2025; | 4) | copy of the Notice of the competition for 17 judges in the Specialized District Administrative Court; | 5) | copy of the Notice of the competition for 10 judges in the Specialised Administrative Court of Appeal.
1) | summary document duly justifying how the step was satisfactorily fulfilled, in line with the requirements set out in the CID Annex;
2) | copy of Law of Ukraine No. 4264-IX ‘On Amendments to the Law of Ukraine “On the Judiciary and the Status of Judges” and Certain Other Legislative Acts of Ukraine Regarding the Legal Basis for the Establishment and Functioning of the Kyiv Specialized District Administrative Court and the Kyiv Specialized Administrative Court of Appeal’dated 26 February 2025;
3) | copy of the Law of Ukraine No. 4602-IX ‘On the Establishment of the Specialized District Administrative Court, the Specialized Administrative Court of Appeal’ dated 16 September 2025;
4) | copy of the Notice of the competition for 17 judges in the Specialized District Administrative Court;
5) | copy of the Notice of the competition for 10 judges in the Specialised Administrative Court of Appeal.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 3.2.The objective of Reform 1 is to enhance the accountability, integrity and professionalism of the judiciary and to build public trust in the judiciary by resuming the transparent and meritocratic selection of judges, boosting the qualification evaluation of sitting judges, strengthening the disciplinary responsibility system, reinforcing existing judicial integrity tools, and establishing a new court to hear administrative cases involving state agencies. To this end the Ukrainian Parliament adopted Law No. 4264-IX, which entered into force on 26 March 2025 and Law No. 4602-IX, which entered into force on 2 October 2025. The laws establish the Specialized District Administrative Court and the Specialized Administrative Court of Appeal.Law No. 4264-IX establishes the legal basis for the Kyiv Specialized District Administrative Court (Specialized District Court) and the Kyiv Specialized Administrative Court of Appeal (Specialized Court of Appeal) as two separate specialized high courts. The law defines the jurisdiction of the new courts stating that the Specialized District Court considers administrative appeals against decisions, actions or inaction of the Cabinet of Ministers of Ukraine, the ministry or other central body of executive power, the National Bank of Ukraine, or another body, whose powers extend nationwide. It has also jurisdiction to e.g. consider appeals against the decisions of the selection commissions responsible for high-level appointments in several state agencies. Specialized Court of Appeal is an appellate instance to Specialized District Court only and will not be reviewing the cases of other district administrative courts.The law No. 4264-IX introduces eligibility requirements for judges of the new courts and provides for a transparent procedure for the selection of judges. It provides for the involvement of a special body, the Expert Council, in the vetting of the judgeship candidates. The Expert Council is composed of six members, three of which are proposed by the Council of Judges of Ukraine and the other three by international and foreign organizations providing Ukraine with international technical assistance in the field of judicial reform and/or preventing and combating corruption. The Expert Council assesses candidates’ integrity and professional competence, in particular, through the right to conduct interviews with the candidates.In line with the Ukrainian legislation, a separate special law No. 4602-IX submitted to the Ukrainian Parliament by the President formally establishes the two courts. It establishes their location as the city of Kyiv and territorial jurisdiction as the entire territory of Ukraine.Following the entry into force of Law No. 4602-IX, on 29 October 2025 High Qualification Commission of Judges launched the selection procedure for 17 judges in the first instance, and 10 judges in the appeal instance.
Commission assessment:satisfactorily fulfilled
Step 5.2

Name of the step:Entry into force of the legislation on the principles for the sale of state-owned banks
Related reform/investment:Reform 2. Reducing state ownership in the banking sector
Financed from:loan
ContextThe requirement for step 5.2 described in the CID annex is:‘Entry into force of the updated legislation on the sale of state-owned banks, namely, the Law of Ukraine “On Divesting State-Owned Shareholdings in the Charter Capital of Banks that Have Undergone Recapitalisation by the State” No. 4524-VI dated 2012. The revised legislation should facilitate the sale of varying ownership stakes in State-owned banks (SOBs), while also providing the flexibility for complete acquisition. The fundamental principles guiding the sale of SOBs will be developed through collaborative discussions and in consensus with the international donors.’Step 5.2 is the first of two steps in the implementation of Reform 2 in Chapter 5 (financial markets). It is followed by Step 5.3 on the adoption of the strategy for gradual reduction of state ownership in the banking sector due in Q2 2026.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’dated 19 September 2024;3)copy the Order of the Cabinet of Ministers of Ukraine No. 1061-r ‘On Preparation for the Sale of State-Owned Share Packages in the Authorised Capital of Banks’dated 1 October 2025. | 1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; | 2) | copy of the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’dated 19 September 2024; | 3) | copy the Order of the Cabinet of Ministers of Ukraine No. 1061-r ‘On Preparation for the Sale of State-Owned Share Packages in the Authorised Capital of Banks’dated 1 October 2025.
1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) | copy of the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’dated 19 September 2024;
3) | copy the Order of the Cabinet of Ministers of Ukraine No. 1061-r ‘On Preparation for the Sale of State-Owned Share Packages in the Authorised Capital of Banks’dated 1 October 2025.
AnalysisThe justification and evidence provided by the Ukrainian authorities cover all constitutive elements of step 5.2.The objective of Reform 2 is to lay down the principles for the sale of state-owned banks and the strategy for gradually reducing state ownership in the banking sector. To this end, the Ukrainian parliament adopted the Law of Ukraine No. 3983-IX‘On the Peculiarities of the Sale of Shareholdings Owned by the State in the Authorised Capital of Banks’of 19 September 2024. The Law entered into force on 19 October 2024.The law facilitates the sale of varying ownership stakes in state-owned banks (SOBs) by establishing a unified legal and procedural framework for the divestment of state-held shares. It defines the key terms, objectives, and mechanisms governing such transactions. The framework regulates the preparation, approval, and execution of sales through competitive processes, supported by the engagement of sale advisors and the oversight of a designated sale commission. It provides procedures for determining eligibility, conducting tenders, and concluding sale agreements, while also setting rules for post-sale acquisitions and valuation of controlling interests. Collectively, these provisions enable the state to reduce its participation in the banking sector in a structured and market-oriented manner.The law provides also for the flexibility for complete acquisition, allowing the Government of Ukraine to tailor each transaction to market conditions. It empowers the Cabinet of Ministers of Ukraine to adjust the size of share packages, select the most appropriate sale procedure, and modify the terms prior to bidding. The framework permits repeated tenders and price adjustments to ensure completion, while the involvement of professional sale advisors introduces adaptability in structuring and valuation processes. Furthermore, contractual terms, including applicable foreign law and arbitration clauses, may be customized to meet investor expectations, thereby ensuring both regulatory consistency and commercial flexibility in the privatization process.The fundamental principles governing the sale of SOBs are established through collaborative discussions and consensus with international donors. Specifically, representatives from international financial institutions, EU institutions and EU Member States, as well as other international and foreign organizations providing technical assistance to Ukraine, may participate in the work of the sales commission with their consent. They have the right to express their positions, request and receive information from the sales commission, and provide recommendations regarding the preparation and conduct of the competition.The sales commission has the authority to decide on the approval of a contestant’s risk profile in compliance with the National Bank of Ukraine’s requirements on business reputation and ownership structure; the conduct and procedures of competition; the admission, refusal, or termination of applicants’ participation on grounds prescribed by law; the approval of draft purchase and sale contracts for the bank’s shares, related documents, and/or principal terms of such agreements, including the starting trading price as recommended by the sale advisor; the modification of the number of shares subject to sale; the appointment of new bidding rounds or termination of the tender in cases defined by law upon the advisor’s recommendation; the approval of the tender winner and the final purchase and sale contract for the bank’s block of shares, together with all related documents and the final sale price determined by the bidding results; the recognition of whether bidding has occurred under the conditions set forth by law; and other matters as provided in the sales commission’s regulations, the orders of the Cabinet of Ministers of Ukraine, or as otherwise required for the implementation of the law.Additionally, representatives of international financial institutions, EU institutions and Member States, and other international and foreign organizations providing technical assistance to Ukraine may participate in the selection of a sales advisor, with the right to express opinions, request and receive information, and offer recommendations.
Commission assessment:satisfactorily fulfilled
Step 8.8

Name of the step:Adoption of harmonised standards for three groups of industrial products
Related reform/investment:Reform 5. Harmonisation of legislation and standards with the EU
Financed from:loan
ContextThe requirement for Step 8.8 described in the CID Annex is:‘Harmonised standards for 3 groups of industrial products (machinery, electromagnetic compatibility of equipment, low-voltage electrical equipment) are adopted as national ones by translation method’Step 8.8 is the second step in the implementation of Reform 5 in Chapter 8 (business environment). It follows Step 8.7 on the resumption of market surveillance measures and the control of non-food products, including product safety. Step 8.7 was due in Q4 2024 and was positively assessed as part of the third instalment.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the explanatory table listing the 71 standards that were tendered, translated and adopted;3)copy of the orders of the State Enterprise ‘UkrNDNC’ (Ukraine’s national standardisation body) Nos 310–334 dated 26 December 2024. | 1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; | 2) | copy of the explanatory table listing the 71 standards that were tendered, translated and adopted; | 3) | copy of the orders of the State Enterprise ‘UkrNDNC’ (Ukraine’s national standardisation body) Nos 310–334 dated 26 December 2024.
1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) | copy of the explanatory table listing the 71 standards that were tendered, translated and adopted;
3) | copy of the orders of the State Enterprise ‘UkrNDNC’ (Ukraine’s national standardisation body) Nos 310–334 dated 26 December 2024.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 8.8.The objective of Reform 5 is to resume market surveillance measures and facilitate the adoption of EU norms and standards in Ukraine, particularly in the areas of industrial products. To this end, Ukraine has adopted harmonised standards for three priority product groups – machinery, electromagnetic-compatibility (EMC) equipment and low-voltage electrical equipment – as national State Standards of Ukraine (DSTU) standards by the translation method. Through a series of open tenders in 2024, the national standardisation body contracted, translated and formally approved 71 DSTU EN / DSTU EN IEC / DSTU EN ISO standards. Each of the standards was enacted by Ministry of Economy Orders Nos 310–334 of 26 December 2024 and linked to the relevant EU directives 2006/42/EC (Machinery), 2014/30/EU (EMC) and 2014/35/EU (Low-Voltage Directive).—Machinery: 43 translations, notably DSTU EN ISO 13849-1:2024 (general principles of machine-safety control systems) and DSTU EN 474-1:2022 (earth-moving machinery – general safety).—EMC-related equipment: 4 translations, e.g. DSTU EN 60947-8:2015 (devices with embedded thermal protection for rotating machines) and DSTU EN 62196-1:2015 (connectors for conductive charging of electric vehicles).—Low-voltage electrical equipment: 24 translations, including DSTU EN IEC 62477-1:2024 (power electronic converters) and DSTU EN IEC 62052-11:2024 (electricity meters), together with 16 household-appliance standards in the EN 60335-2-xx series. | — | Machinery: 43 translations, notably DSTU EN ISO 13849-1:2024 (general principles of machine-safety control systems) and DSTU EN 474-1:2022 (earth-moving machinery – general safety). | — | EMC-related equipment: 4 translations, e.g. DSTU EN 60947-8:2015 (devices with embedded thermal protection for rotating machines) and DSTU EN 62196-1:2015 (connectors for conductive charging of electric vehicles). | — | Low-voltage electrical equipment: 24 translations, including DSTU EN IEC 62477-1:2024 (power electronic converters) and DSTU EN IEC 62052-11:2024 (electricity meters), together with 16 household-appliance standards in the EN 60335-2-xx series.
— | Machinery: 43 translations, notably DSTU EN ISO 13849-1:2024 (general principles of machine-safety control systems) and DSTU EN 474-1:2022 (earth-moving machinery – general safety).
— | EMC-related equipment: 4 translations, e.g. DSTU EN 60947-8:2015 (devices with embedded thermal protection for rotating machines) and DSTU EN 62196-1:2015 (connectors for conductive charging of electric vehicles).
— | Low-voltage electrical equipment: 24 translations, including DSTU EN IEC 62477-1:2024 (power electronic converters) and DSTU EN IEC 62052-11:2024 (electricity meters), together with 16 household-appliance standards in the EN 60335-2-xx series.
Commission assessment:satisfactorily fulfilled
Step 9.1

Name of the step:Entry into force of the legislation on reforming of territorial organisation of the executive authorities in Ukraine with delayed application
Related reform/investment:Reform 1. Advancing decentralisation
Financed from:loan/non-repayable support
ContextThe requirement for Step 9.1 described in the CID Annex is:‘Entry into force of the Law of Ukraine “On Amendments to the Law of Ukraine ‘On Local State Administrations’ and Some Other Legislative Acts of Ukraine as Regards the Reforming of Territorial Organisation of the Executive Authorities in Ukraine” with its application within 12 months from the date of termination or abolition of martial law in Ukraine. Subordinate legal acts for the implementation of the law shall be adopted after it enters into force. The law focuses on these main areas:—transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies;—ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.’Step 9.1 is the first of three steps in the implementation of Reform 1 of Chapter 9 (decentralisation and regional policy). | — | transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies; | — | ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.’
— | transforming local state administrations into prefecture-type authorities in order to create a balanced system of ensuring a legal nature of activities undertaken by local self-government bodies;
— | ensuring coordination of the territorial bodies of the central executive authorities when implementing the state policy at the regional and local levels.’
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Law of Ukraine No. 4677-IX on‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’dated 5 November 2025. | 1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; | 2) | copy of the Law of Ukraine No. 4677-IX on‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’dated 5 November 2025.
1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) | copy of the Law of Ukraine No. 4677-IX on‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’dated 5 November 2025.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all the constitutive elements of Step 9.1.The objective of Reform 1 is to put in place a framework for transforming local state administrations into prefecture-type authorities and to ensure a better distribution of powers between local governments and executive authorities. To this end, the law on ‘Amendments to Certain Legislative Acts of Ukraine to Ensure Legality and Transparency in the Activities of Local Self-Government Bodies’was adopted by the Verkhovna Rada on 5 November and entered into force on 12 November 2025, with application delayed by 12 months from the date of termination or cancellation of martial law in Ukraine.The law initiates the transformation of local state administrations into prefecture-type of authorities by establishing a system of supervision of the legality of local self-government acts. The law defines the scope, the responsibilities and the procedures for ensuring the legality of acts of local self-government bodies. The law introduces measures aimed at preventing the violation of the legality of activities of local self-government bodies; including a mechanism for ensuring that local self-government bodies are informed about changes in the legislation related to local self-government and, in case of disputes, may have recourse for court.The law establishes a mechanism for enhancing coordination. The law identifies the heads of local state administrations as responsible for coordination and for ensuring the legality in the activities of territorial bodies of ministries and other central executive bodies.
Commission assessment:satisfactorily fulfilled
Step 12.4

Name of the step:Entry into force of the legislation on the public support of agriculture of Ukraine
Related reform/investment:Reform 3. Improving the institutional and administrative set up for managing investment programmes
Financed from:loan
ContextThe requirement for Step 12.4 described in the CID Annex is:‘Entry into force of the Law on Amendments to the Law of Ukraine “On State Support of Agriculture of Ukraine”. The Law focuses on these main areas:—design future public support measures in line with the principles of the EU acquis in this area. The selection of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT);—design measures to support agricultural production for small scale farms to undertake private investments (physical assets of agricultural holdings producers, for processing and marketing);—design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions;—digitalisation through electronic document management systems;—state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.’Step 12.4 is the only step of Reform 3 of Chapter 12 (agri-food sector). | — | design future public support measures in line with the principles of the EU acquis in this area. The selection of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT); | — | design measures to support agricultural production for small scale farms to undertake private investments (physical assets of agricultural holdings producers, for processing and marketing); | — | design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions; | — | digitalisation through electronic document management systems; | — | state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.’
— | design future public support measures in line with the principles of the EU acquis in this area. The selection of future public support measures will include an analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT);
— | design measures to support agricultural production for small scale farms to undertake private investments (physical assets of agricultural holdings producers, for processing and marketing);
— | design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with International Financial Institutions;
— | digitalisation through electronic document management systems;
— | state support exclusively channelled to beneficiaries enlisted in the State Agrarian Register.’
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Law of Ukraine No. 4619-IX‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’dated 8 October 2025. | 1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; | 2) | copy of the Law of Ukraine No. 4619-IX‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’dated 8 October 2025.
1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) | copy of the Law of Ukraine No. 4619-IX‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’dated 8 October 2025.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 12.4.The objective of the Reform 3 is to improve the set up for managing public financial support schemes to the agri-food sector. The Parliament adopted the Law of Ukraine No. 4619-IX ‘On Amendments to Certain Laws of Ukraine on the Organizational Principles of Support in the Agricultural Sector’on 8 October 2025. The law entered into force on 4 November 2025.The law designs future public support measures in line with the principles of the EU acquis in the area of agriculture and rural development. It sets the provisions in line with the principles of the current Common Agricultural Policy (CAP). It specifies the overall aim, objectives of the agriculture and rural development policy and measures for implementing this policy. Based on the overall aim and objectives, the multiannual Strategy for the Development of Agriculture and Rural Territories will be developed, and the choice of national support measures and types of support will be selected on the basis of a comprehensive analysis of Strengths, Weaknesses, Opportunities, and Threats (SWOT).The law sets out the structures on the financing, management and monitoring of state support for agriculture and rural development. It provides for the establishment of the responsible authorities defining their tasks – such as a Paying Agency, Certification bodies, and the Central Executive Body, which ensures the formation and implementation of the national policy of agriculture and rural development.The law introduces provisions, amongst others, on the separation of policymaking and payment functions, on the institutional independence of the Paying Agency and on the detailed tasks of the Paying Agency for administering national support for agriculture and rural development, particularly on transparency and accountability, verification and authorisation of payments, performing administrative checks and on-site inspections to control eligibility for support.Small agricultural producers are the priority recipients of state support. The criteria for classifying agricultural producers as small producers will be determined for each type of support. The law also defines measures for the implementation of national support for agriculture and rural development, including investments in physical assets of agricultural producers to improve efficiency, competitiveness and sustainable agricultural production. Similarly, associations of agricultural producers can be supported in the marketing of agricultural products.The law authorises the design of future financial instruments (including credit guarantee facilities) for all farm categories in collaboration with international financial institutions for the implementation of agriculture and rural development policy.The law aims to promote digitalisation through electronic document management systems. The law provides the legal basis for the development of the Integrated Administration and Control System (IACS), which will function together with other already existing systems as electronic document management systems for the administration of national support for agriculture and rural development.The law requires state support to be exclusively channelled to the beneficiaries enlisted in the State Agrarian Register. Entities which are not registered in the State Agrarian Register are excluded from receiving state support.
Commission assessment:satisfactorily fulfilled
Step 13.2

Name of the step:Publishing of a report on the verification of Critical Raw Materials’ reserves of Ukraine
Related reform/investment:Reform 1. Strengthening strategic planning and ensuring optimum framework for strategic investors
Financed from:loan
ContextThe requirement for step 13.2 described in the CID Annex is:‘Publication of a report on the verification of Critical Raw Materials reserves of Ukraine using international classification system and results are made available to investors.’Step 13.2 is the second step in the implementation of Reform 1 of Chapter 13 (management of critical raw materials). It was preceded by Step 13.1 on the entry into force of the legislation on revising the National Programme for the Development of the Mineral Resource Base of Ukraine to 2030 which was positively assessed in Q4 2024 as part of the third instalment.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of ‘Report on the verification of Critical Raw Materials reserves of Ukraine using international classification system’,published on the website of the Ukrainian Geological Survey:Strategic/Critical Mineral Reserves Verification Report | 1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; | 2) | copy of ‘Report on the verification of Critical Raw Materials reserves of Ukraine using international classification system’,published on the website of the Ukrainian Geological Survey:Strategic/Critical Mineral Reserves Verification Report
1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) | copy of ‘Report on the verification of Critical Raw Materials reserves of Ukraine using international classification system’,published on the website of the Ukrainian Geological Survey:Strategic/Critical Mineral Reserves Verification Report
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 13.2.The objective of Reform 1 is to attract investments in the extraction and processing of critical raw materials.The report on the verification of Critical Raw Materials’ reserves of Ukraine is published on the official website of the Geological Survey with the hyperlink:Strategic/Critical Mineral Reserves Verification Report.The report uses international classification system UNFC –United Nations Framework Classification for Resources,that was endorsed by the United Nations Economic and Social Council in 2004 and remains an important tool to analyse the availability and sustainability of critical resources.The 2019 version of the UNFC is a classification system for resource development projects based on the following principles:—environmental and socio-economic viability;—technical feasibility;—commercial potential of raw materials projects.The results are made available to investors by being published on the website. | — | environmental and socio-economic viability; | — | technical feasibility; | — | commercial potential of raw materials projects.
— | environmental and socio-economic viability;
— | technical feasibility;
— | commercial potential of raw materials projects.
Commission assessment:satisfactorily fulfilled
Step 15.4

Name of the step:Adoption of the second Nationally Determined Contribution of Ukraine to the Paris Agreement
Related reform/investment:Reform 2. Climate policy
Financed from:loan
ContextThe requirement for step 15.4 described in the CID Annex is:‘Adoption of the Order of the Cabinet of Ministers of Ukraine “On Approval of the Second Nationally Determined Contribution (NDC) of Ukraine to the Paris Agreement”. The NDC focuses on these main areas:—higher emission reduction target than in the current NDC of Ukraine;—establishing a base year for calculating emissions from sources and sinks of greenhouse gases;—duration of implementation and/or time periods of the proposed measures;—scope and coverage of economic sectors and greenhouse gases;—process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases;—justification of the equity and ambition of the NDC in the light of national circumstances;—contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.The Second NDC of Ukraine to the Paris Agreement will be more ambitious than the current Updated NDC.’Step 15.4 is the second step in the implementation of Reform 2, of Chapter 15 (green transition and environmental protection). Step 15.2 on the entry into force of the legislation on the State Climate Policy was positively assessed in Q1 2025 as part of the fourth instalment. Step 15.4 will be followed by step 15.3 on the adoption of the resolution on the Scientific and Expert Council on Climate Change and Preservation of the Ozone Layer in Q4 2025. | — | higher emission reduction target than in the current NDC of Ukraine; | — | establishing a base year for calculating emissions from sources and sinks of greenhouse gases; | — | duration of implementation and/or time periods of the proposed measures; | — | scope and coverage of economic sectors and greenhouse gases; | — | process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases; | — | justification of the equity and ambition of the NDC in the light of national circumstances; | — | contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.
— | higher emission reduction target than in the current NDC of Ukraine;
— | establishing a base year for calculating emissions from sources and sinks of greenhouse gases;
— | duration of implementation and/or time periods of the proposed measures;
— | scope and coverage of economic sectors and greenhouse gases;
— | process planning, assumptions and methodological approaches used, including for estimation and accounting of anthropogenic emissions by sources and removals by sinks of greenhouse gases;
— | justification of the equity and ambition of the NDC in the light of national circumstances;
— | contribution to the achievement of the objective of the UN Framework Convention on Climate Change and to limit greenhouse gas emissions/enhance sinks, in accordance with the objective set out in Article 2 of the UN Framework Convention on Climate Change.
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Order of the Cabinet of Ministers of Ukraine No. 1172-r of 29 October 2025‘On approval of Ukraine’s second nationally determined contribution to the Paris Agreement’;3)copy of the annex to the Order of the Cabinet of Minister of Ukraine No. 1172-r of 29 October 2025 on ‘Ukraine’s second nationally determined contribution to the Paris Agreement’. | 1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; | 2) | copy of the Order of the Cabinet of Ministers of Ukraine No. 1172-r of 29 October 2025‘On approval of Ukraine’s second nationally determined contribution to the Paris Agreement’; | 3) | copy of the annex to the Order of the Cabinet of Minister of Ukraine No. 1172-r of 29 October 2025 on ‘Ukraine’s second nationally determined contribution to the Paris Agreement’.
1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) | copy of the Order of the Cabinet of Ministers of Ukraine No. 1172-r of 29 October 2025‘On approval of Ukraine’s second nationally determined contribution to the Paris Agreement’;
3) | copy of the annex to the Order of the Cabinet of Minister of Ukraine No. 1172-r of 29 October 2025 on ‘Ukraine’s second nationally determined contribution to the Paris Agreement’.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 15.4.The objective of Reform 2, climate policy, is to create an architecture for climate governance as well as an appropriate mechanism for the development and implementation of state policy in the field of climate change in Ukraine.The Order of the Cabinet of Ministers of Ukraine ‘On Approval of the Second Nationally Determined Contribution (NDC) of Ukraine to the Paris Agreement’ was adopted on 29 October 2025. It sets an emission reduction target (including absorption) ‘more than 65 %’ from the 1990 level in 2035. The previous updated NDC aimed for a 65 % reduction by 2030. The base year for calculation is 1990, with the reference indicator being the emissions for that year assessed by the national report on the inventory of anthropogenic emissions from GHG emission sources and removals.The second NDC of Ukraine explains that, due to Russia’s war of aggression, ‘the planning of more ambitious emission reduction targets is objectively limited due to the extremely high level of uncertainty about the scale of recovery, the dynamics of economic growth, the future structure of the energy balance and the rate of decarbonisation’.The duration of implementation for the second NDC is from 1 January 2031 to 31 December 2035, and the goal is established as a target for the year 2035. Sectors covered by the second NDC include energy, industrial processes and product use; agriculture, land use, land-use change and forestry; and waste. It covers all greenhouse gases not regulated by the Montreal Protocol.The process planning is coordinated by the relevant line ministry, with national governance based on the Law of Ukraine No. 3991-IX ‘On the Basic Principles of State Climate Policy’. The estimation and accounting use the approach of comparing total emissions in the target year to the total emissions in the base year and relies on the 2006 IPCC Guidelines and employs mathematical models to develop three forecast scenarios up to 2050.The assessment above is valid only in the context of the Ukraine Plan’s implementation. The level of climate ambition of Ukraine in the context of EU accession is being addressed separately.
Commission assessment:satisfactorily fulfilled
Step 15.9

Name of the step:Adoption of the National Waste Management Plan until 2033
Related reform/investment:Reform 5. Increased circular economy
Financed from:loan
ContextThe requirement for step 15.9 described in the CID Annex is:‘Adoption of the Order of the Cabinet of Ministers of Ukraine “On Approval of the National Waste Management Plan until 2033”. The National Waste Management Plan focuses on these main areas:—household waste management;—hazardous waste management;—infrastructure needs;—economic and financial sustainability analyses of the action plan;—implementation of economic instruments to improve waste management;—monitoring and control of waste management;—strategic planning of waste management in Ukraine;—implementation of waste management at the regional level.’Step 15.9 is the first step in the implementation of Reform 5 of Chapter 15 (Green Transition and Environmental Protection). Step 15.9 is followed by Step 15.8 on the adoption of a strategy for implementing the principles of the circular economy and an action plan for its implementation in Q1 2026. | — | household waste management; | — | hazardous waste management; | — | infrastructure needs; | — | economic and financial sustainability analyses of the action plan; | — | implementation of economic instruments to improve waste management; | — | monitoring and control of waste management; | — | strategic planning of waste management in Ukraine; | — | implementation of waste management at the regional level.’
— | household waste management;
— | hazardous waste management;
— | infrastructure needs;
— | economic and financial sustainability analyses of the action plan;
— | implementation of economic instruments to improve waste management;
— | monitoring and control of waste management;
— | strategic planning of waste management in Ukraine;
— | implementation of waste management at the regional level.’
Evidence provided1)summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;2)copy of the Order of the Cabinet of Ministers No. 1353-r on the‘Approval of the National Waste Management Plan until 2033’dated 27 December 2024.;3)copy of the annex to the Cabinet of Ministers No. 1353-r on the ‘National Waste Management Plan until 2033’ dated 27 December 2024. | 1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex; | 2) | copy of the Order of the Cabinet of Ministers No. 1353-r on the‘Approval of the National Waste Management Plan until 2033’dated 27 December 2024.; | 3) | copy of the annex to the Cabinet of Ministers No. 1353-r on the ‘National Waste Management Plan until 2033’ dated 27 December 2024.
1) | summary document duly justifying how the step was satisfactorily fulfilled in line with the requirements set out in the CID Annex;
2) | copy of the Order of the Cabinet of Ministers No. 1353-r on the‘Approval of the National Waste Management Plan until 2033’dated 27 December 2024.;
3) | copy of the annex to the Cabinet of Ministers No. 1353-r on the ‘National Waste Management Plan until 2033’ dated 27 December 2024.
AnalysisThe justification and substantive evidence provided by the Ukrainian authorities cover all constitutive elements of step 15.9.The objective of Reform 5 is to implement the principles of circular economy and waste management. To this end, Cabinet of Ministers adopted the National Waste Management Plan until 2033 (National Plan) on 27 December 2024.In the National Plan, household waste is comprehensively defined to include mixed and separately collected waste from households, which also accounts for hazardous components contained within. The current waste management system in Ukraine largely relies on low-level technologies, leading to the direct disposal of waste primarily in landfills and dumps. Despite existing efforts, the coverage of the population by separate waste collection programs remains low, at only about 30 %.The primary sources of hazardous waste are identified as industrial, agricultural, and transport enterprises, alongside healthcare facilities and households. While the annual volume of hazardous waste significantly decreased in a post-war period from 2010 to 2022, the efficiency of management is still inadequate.In terms of infrastructure needs, the National Plan serves as a framework document, meaning the specific infrastructure objects, technologies, and economic calculations are to be detailed in regional and local waste management plans. The successful execution of the plan is expected to establish the necessary conditions to attract both financing and investments into the sector. The regional and local plans, which derive from the National Plan, are explicitly required to include economic calculations and an assessment of their implementation capacity. The National Plan mandates the implementation of essential economic instruments, including the polluter pays principle and extended producer responsibility. The document also emphasizes the need to achieve a high level of recycling to return secondary raw materials into economic circulation.A key anticipated outcome of the National Plan’s implementation is a general improvement in the system for monitoring and control over all waste management activities. The National Plan functions as the primary framework document that defines the major strategic directions for state policy in the waste management sector until 2033. Consequently, it forms the foundation for strategic planning and the development of specific measures at the regional, local, enterprise, and institutional levels. Forecasts for future waste generation volumes are strategically based on projections related to population size and the expected development of the country’s production potential and infrastructure. In accordance with the Law, local self-government bodies are responsible for ensuring household waste management and guaranteeing that services are provided to every waste generator within their territory. To improve efficiency, territorial communities are encouraged to cooperate, including through joint financing for the construction, reconstruction, and maintenance of household waste processing facilities. All regional and local plans developed under the National Plan must account for specific local conditions and required economic calculations.
Commission assessment:satisfactorily fulfilled
(1) Regulation (EU) 2024/792 of the European Parliament and of the Council of 29 February 2024 establishing the Ukraine Facility (OJ L, 2024/792, 29.2.2024, ELI: http://data.europa.eu/eli/reg/2024/792/oj).
(2) Council Implementing Decision (EU) 2024/1447 of 14 May 2024 on the approval of the assessment of the Ukraine Plan (OJ L, 2024/1447, 24.5.2024, ELI: http://data.europa.eu/eli/dec_impl/2024/1447/oj). Annex to the Council Implementing Decision https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CONSIL%3AST_9492_2024_ADD_1&qid=1716536456361.
(3) Council Implementing Decision (EU) 2025/2157 of 17 October 2025 amending Implementing Decision (EU) 2024/1447 on the approval of the assessment of the Ukraine Plan (OJ L, 2025/2157, 27.10.2025, ELI: http://data.europa.eu/eli/dec_impl/2025/2157/oj).

Council Decision of 11 December 2025 replacing a member of the Advisory Committee on freedom of movement for workers for Austria

Official Journalof the European Union ENC series
C/2025/6758 19.12.2025
(1) By Decision of 23 September 2024(2), the Council appointed members and alternate members of the Advisory Committee on freedom of movement for workers for the period from 25 September 2024 to 24 September 2026.
(2) A seat as member in the trade union representatives category has fallen vacant as a result of the resignation of Mr Johannes PEYRL.
(3) Austria has designated a candidate for the vacant seat,
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) No 492/2011 of the European Parliament and of the Council of 5 April 2011 on freedom of movement for workers within the Union(1), and in particular Articles 23 and 24 thereof,
(1) By Decision of 23 September 2024(2), the Council appointed members and alternate members of the Advisory Committee on freedom of movement for workers for the period from 25 September 2024 to 24 September 2026.
(2) A seat as member in the trade union representatives category has fallen vacant as a result of the resignation of Mr Johannes PEYRL.
(3) Austria has designated a candidate for the vacant seat,
HAS ADOPTED THIS DECISION:

Article 1
Ms Nicole PINTER is appointed member of the Advisory Committee on freedom of movement for workers in place of Mr Johannes PEYRL for the remainder of the current term of office, ending on 24 September 2026.

Article 2
This Decision shall enter into force on the date of its adoption.

THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Regulation (EU) No 492/2011 of the European Parliament and of the Council of 5 April 2011 on freedom of movement for workers within the Union(1), and in particular Articles 23 and 24 thereof,
(1) By Decision of 23 September 2024(2), the Council appointed members and alternate members of the Advisory Committee on freedom of movement for workers for the period from 25 September 2024 to 24 September 2026.
(2) A seat as member in the trade union representatives category has fallen vacant as a result of the resignation of Mr Johannes PEYRL.
(3) Austria has designated a candidate for the vacant seat,
HAS ADOPTED THIS DECISION:
Ms Nicole PINTER is appointed member of the Advisory Committee on freedom of movement for workers in place of Mr Johannes PEYRL for the remainder of the current term of office, ending on 24 September 2026.
This Decision shall enter into force on the date of its adoption.

Council Decision (EU) 2025/2610 of 12 December 2025 on amendments to the Monetary Agreement between the European Union and the Principality of Andorra and to the Monetary Agreement between the European Union and the Republic of San Marino

Official Journalof the European Union ENL series
2025/2610 17.12.2025
(1) The Union has exclusive competence for monetary law as of the date of the introduction of the euro.
(2) The Council is to determine the arrangements for the amendment of agreements concerning monetary or foreign exchange regime matters.
(3) The Monetary Agreement between the European Union and the Principality of Andorra(2)and the Monetary Agreement between the European Union and the Republic of San Marino(3)(the ‘Monetary Agreements’) were signed on 30 June 2011 and 27 March 2012, respectively.
(4) Following the finalisation of the negotiations in December 2023, the Union is expected to sign the Agreement establishing an association between the European Union and the Principality of Andorra and the Republic of San Marino, respectively (the ‘Association Agreement’). Under the Association Agreement and Framework Protocol 3 thereto on financial services, Andorra and San Marino will progressively join the single market for financial services. Andorra and San Marino should therefore transpose the Unionacquisand new legislation on combatting money laundering and terrorist financing and on financial services.
(5) The Monetary Agreements and the Association Agreement provide for the implementation of Union legal acts by Andorra and San Marino. Those Union legal acts are listed in the Annexes to the Monetary Agreements and to the Association Agreement.
(6) The Union legal acts on combatting money laundering and terrorist financing to be implemented pursuant to the Monetary Agreements and the Association Agreement are identical. In contrast, the Union legal acts on financial services overlap only partially. The Union legal acts that apply under the Monetary Agreements mainly concern banking and financial law related to the supervision of financial institutions that are relevant for the euro, whereas all Union legal acts on financial services fall within the scope of the Association Agreement.
(7) The Monetary Agreements and the Association Agreement have different purposes and different legal bases. The legal basis for the Monetary Agreements is Article 219(3) of the Treaty on the Functioning of the European Union (TFEU), whereby the Council – representing only those Member States that have introduced the euro as their national currency – acts by the default rule of qualified majority on a recommendation from the Commission and after having consulted the European Central Bank. The Association Agreement is based on Article 218 TFEU, whereby, further to the consent of the European Parliament, the Council – representing all Member States – is able to adopt a decision on the conclusion of the Association Agreement. Therefore, the Monetary Agreements are independent of, and cannot be integrated into, the Association Agreement.
(8) A mechanism should be established to address the partial overlapping of identical duties under the Monetary Agreements and the Association Agreement and to ensure the smooth interaction between them. A viable and simple solution is to amend the Monetary Agreements.
(9) Clauses should be inserted into the Monetary Agreements that provide for the incorporation into the Association Agreement of all new Union legal acts on combatting money laundering and terrorist financing and all new Union legal acts on banking and finance relevant for the euro once those Union legal acts become applicable under the Association Agreement. The assessment of the implementation of those Union legal acts, whether they have been adopted in the past or are going to be adopted in the future, having become part of the Association Agreement, should be undertaken in the framework of the Association Agreement, and may be relevant for the application of the Monetary Agreements.
(10) Implementation of Union legal acts concerning monetary law should remain governed exclusively by the Monetary Agreements.
(11) Clauses should be inserted into the Monetary Agreements in order to ensure the independence of the Monetary Agreements and of the Association Agreement.
(12) The Union legal acts on banking and finance relevant for the euro and the Union legal acts on combatting money laundering and terrorist financing that have become part of the Association Agreement should be incorporated into the Monetary Agreements automatically if the Association Agreement is partially or fully suspended or if it is terminated,
(a) insertion into the Monetary Agreements of clauses by which all new Union legal acts on banking and financial law relevant for the euro and all new Union legal acts on combatting money laundering and terrorist financing become part of the relevant annex to the Agreement establishing an association between the European Union and the Principality of Andorra and the Republic of San Marino, respectively, (the ‘Association Agreement’) exclusively once those Union legal acts become applicable under the Association Agreement; those clauses should also clarify that, if a Union legal act relevant to the application of the relevant Monetary Agreement is adopted or amended before Framework Protocol 3 to the Association Agreement on financial services becomes applicable, it will be inserted into the Annex to the Monetary Agreement and transferred to the relevant annex to the Association Agreement once such Union legal act becomes applicable under the Association Agreement;
(b) insertion into the Monetary Agreements of clauses which ensure that the assessment of the implementation of all Union legal acts on banking and financial law relevant for the euro and all Union legal acts on combatting money laundering or terrorist financing, whether they have been adopted in the past or are going to be adopted in the future, once they have become part of the relevant annex to the Association Agreement, is undertaken in the framework of the Association Agreement;
(c) insertion into the Monetary Agreements of clauses by which the Union legal acts on banking and financial law relevant for the euro and all Union legal acts on combatting money laundering and terrorist financing that are listed in the Annexes to the Association Agreement are clearly marked as relevant for the application of the Monetary Agreements, so that the assessment of the implementation of those Union legal acts in Andorra and San Marino under the Association Agreement can be done at the same time for the purposes of the Monetary Agreements;
(d) insertion into the Monetary Agreements of clauses by which all new Union legal acts on banking and financial law relevant for the euro and all new Union legal acts on combatting money laundering and terrorist financing, having become part of the Association Agreement, are automatically incorporated into the Annexes to the Monetary Agreements and their implementation is assessed in the framework of the Monetary Agreements if the Association Agreement is partially or fully suspended or if it is terminated.
(e) insertion into the Monetary Agreements of clauses which ensure that the implementation of Union legal acts concerning monetary law remains governed exclusively by the Monetary Agreements.
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular Article 219(3) thereof,
Having regard to the recommendation from the Commission,
Having regard to the opinion of the European Central Bank(1),
(1) The Union has exclusive competence for monetary law as of the date of the introduction of the euro.
(2) The Council is to determine the arrangements for the amendment of agreements concerning monetary or foreign exchange regime matters.
(3) The Monetary Agreement between the European Union and the Principality of Andorra(2)and the Monetary Agreement between the European Union and the Republic of San Marino(3)(the ‘Monetary Agreements’) were signed on 30 June 2011 and 27 March 2012, respectively.
(4) Following the finalisation of the negotiations in December 2023, the Union is expected to sign the Agreement establishing an association between the European Union and the Principality of Andorra and the Republic of San Marino, respectively (the ‘Association Agreement’). Under the Association Agreement and Framework Protocol 3 thereto on financial services, Andorra and San Marino will progressively join the single market for financial services. Andorra and San Marino should therefore transpose the Unionacquisand new legislation on combatting money laundering and terrorist financing and on financial services.
(5) The Monetary Agreements and the Association Agreement provide for the implementation of Union legal acts by Andorra and San Marino. Those Union legal acts are listed in the Annexes to the Monetary Agreements and to the Association Agreement.
(6) The Union legal acts on combatting money laundering and terrorist financing to be implemented pursuant to the Monetary Agreements and the Association Agreement are identical. In contrast, the Union legal acts on financial services overlap only partially. The Union legal acts that apply under the Monetary Agreements mainly concern banking and financial law related to the supervision of financial institutions that are relevant for the euro, whereas all Union legal acts on financial services fall within the scope of the Association Agreement.
(7) The Monetary Agreements and the Association Agreement have different purposes and different legal bases. The legal basis for the Monetary Agreements is Article 219(3) of the Treaty on the Functioning of the European Union (TFEU), whereby the Council – representing only those Member States that have introduced the euro as their national currency – acts by the default rule of qualified majority on a recommendation from the Commission and after having consulted the European Central Bank. The Association Agreement is based on Article 218 TFEU, whereby, further to the consent of the European Parliament, the Council – representing all Member States – is able to adopt a decision on the conclusion of the Association Agreement. Therefore, the Monetary Agreements are independent of, and cannot be integrated into, the Association Agreement.
(8) A mechanism should be established to address the partial overlapping of identical duties under the Monetary Agreements and the Association Agreement and to ensure the smooth interaction between them. A viable and simple solution is to amend the Monetary Agreements.
(9) Clauses should be inserted into the Monetary Agreements that provide for the incorporation into the Association Agreement of all new Union legal acts on combatting money laundering and terrorist financing and all new Union legal acts on banking and finance relevant for the euro once those Union legal acts become applicable under the Association Agreement. The assessment of the implementation of those Union legal acts, whether they have been adopted in the past or are going to be adopted in the future, having become part of the Association Agreement, should be undertaken in the framework of the Association Agreement, and may be relevant for the application of the Monetary Agreements.
(10) Implementation of Union legal acts concerning monetary law should remain governed exclusively by the Monetary Agreements.
(11) Clauses should be inserted into the Monetary Agreements in order to ensure the independence of the Monetary Agreements and of the Association Agreement.
(12) The Union legal acts on banking and finance relevant for the euro and the Union legal acts on combatting money laundering and terrorist financing that have become part of the Association Agreement should be incorporated into the Monetary Agreements automatically if the Association Agreement is partially or fully suspended or if it is terminated,
HAS ADOPTED THIS DECISION:
The Commission shall seek to negotiate the following amendments to the Monetary Agreement between the European Union and the Principality of Andorra and to the Monetary Agreement between the European Union and the Republic of San Marino (the ‘Monetary Agreements’):
(a)
insertion into the Monetary Agreements of clauses by which all new Union legal acts on banking and financial law relevant for the euro and all new Union legal acts on combatting money laundering and terrorist financing become part of the relevant annex to the Agreement establishing an association between the European Union and the Principality of Andorra and the Republic of San Marino, respectively, (the ‘Association Agreement’) exclusively once those Union legal acts become applicable under the Association Agreement; those clauses should also clarify that, if a Union legal act relevant to the application of the relevant Monetary Agreement is adopted or amended before Framework Protocol 3 to the Association Agreement on financial services becomes applicable, it will be inserted into the Annex to the Monetary Agreement and transferred to the relevant annex to the Association Agreement once such Union legal act becomes applicable under the Association Agreement;
(b)
insertion into the Monetary Agreements of clauses which ensure that the assessment of the implementation of all Union legal acts on banking and financial law relevant for the euro and all Union legal acts on combatting money laundering or terrorist financing, whether they have been adopted in the past or are going to be adopted in the future, once they have become part of the relevant annex to the Association Agreement, is undertaken in the framework of the Association Agreement;
(c)
insertion into the Monetary Agreements of clauses by which the Union legal acts on banking and financial law relevant for the euro and all Union legal acts on combatting money laundering and terrorist financing that are listed in the Annexes to the Association Agreement are clearly marked as relevant for the application of the Monetary Agreements, so that the assessment of the implementation of those Union legal acts in Andorra and San Marino under the Association Agreement can be done at the same time for the purposes of the Monetary Agreements;
(d)
insertion into the Monetary Agreements of clauses by which all new Union legal acts on banking and financial law relevant for the euro and all new Union legal acts on combatting money laundering and terrorist financing, having become part of the Association Agreement, are automatically incorporated into the Annexes to the Monetary Agreements and their implementation is assessed in the framework of the Monetary Agreements if the Association Agreement is partially or fully suspended or if it is terminated.
(e)
insertion into the Monetary Agreements of clauses which ensure that the implementation of Union legal acts concerning monetary law remains governed exclusively by the Monetary Agreements.
The Commission shall inform Andorra and San Marino of the need and of the Union’s readiness to amend the Monetary Agreements.
1. The Commission is empowered to negotiate, sign and conclude the amendments to the Monetary Agreement between the European Union and the Principality of Andorra referred to in Article 1 in four languages: Catalan, French, English and Spanish. The text in each of those languages shall be considered equally authentic.
2. The Commission is empowered to negotiate, sign and conclude the amendments to the Monetary Agreement between the European Union and the Republic of San Marino referred to in Article 1 in English.
3. The European Central Bank shall be fully associated with the negotiations referred to in paragraphs 1 and 2 insofar as they concern its field of competence.
4. The Commission shall submit the draft amendments to the Monetary Agreements to the Economic and Financial Committee (EFC) for its opinion.
5. The Commission shall be entitled to conclude the amendments to the Monetary Agreements on behalf of the Union, unless the EFC is of the opinion that the amendments to the Monetary Agreements should be submitted to the Council.
This Decision is addressed to the Commission.

Council Decision (CFSP) 2025/2594 of 15 December 2025 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Official Journalof the European Union ENL series
2025/2594 15.12.2025
(1) On 17 March 2014, the Council adopted Decision 2014/145/CFSP(1).
(2) In its conclusions of 19 December 2024, the European Council reiterated its resolute condemnation of Russia’s war of aggression against Ukraine, which constitutes a manifest violation of the Charter of the United Nations, and reaffirmed its continued support for Ukraine’s independence, sovereignty and territorial integrity within its internationally recognised borders. The European Council stated that efforts to further limit Russia’s ability to wage war must continue. It also expressed the Union’s readiness to step up pressure on Russia, including by adopting further sanctions.
(3) In view of Russia’s continued and escalating aggression against Ukraine, and in particular its recent brutal military campaign deliberately targeting civilian infrastructure, including energy, water and health facilities, which has caused severe suffering to the civilian population and which aims to undermine Ukraine’s resilience, the Council considers it necessary to adopt further restrictive measures.
(4) In particular, the Council considers that 5 persons and 4 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine should be added to the list of persons, entities and bodies subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP.
(5) Decision 2014/145/CFSP should therefore be amended accordingly,
Name Identifying information Reasons Date of listing
‘1981. Murtaza Ali LAKHANI Function: BusinesspersonDOB: March 1962POB: PakistanNationality: Pakistani; CanadianGender: male Murtaza Lakhani is a businessperson with interests in the oil sector. Through his companies, he enables shipments and export of Russian oil, notably from the Russian state-owned oil company Rosneft. In particular, Murtaza Lakhani controls vessels transporting crude oil or petroleum products, originating in Russia or being exported from Russia, while practicing irregular and high-risk shipping practices. Such practices include not maintaining adequate liability insurance, carrying out unsafe operations, intentionally taking measures to avoid ship detection, such as switching off Automatic Identification Systems, or not operating under a transparent corporate governance policy. Furthermore, the energy sector, in particular the oil sector, is a sector providing a substantial source of revenue to the Russian Government.Therefore, Murtaza Lakhani is involved in an economic sector providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine. He is also controlling vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33). 15.12.2025
1982. Valery KILDIYAROV Function: Manager of Alghaf Marine DMCC; finance director of Litasco Middle East DMCCGender: male Valery Kildiyarov is a manager of Alghaf Marine DMCC, and the finance director of Litasco Middle East DMCC. Both companies supply significant volumes of Russian crude oil. The energy sector, in particular the oil sector, is a sector providing a substantial source of revenue to the Russian Government.Therefore, Valery Kildiyarov is involved in an economic sector providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine. Additionally, Valery Kildiyarov is associated with Litasco Middle East DMCC. 15.12.2025
1983. Anar MADATLI Function: Shareholder in and Director of 2Rivers Group Anar Madatli is a shareholder in and director of 2Rivers Group, a UAE based oil-trading company previously known as “Coral Energy”. Since 2024, the company’s shares have been held by three company managers – Talat Safarov, Ahmed Kerimov and Anar Madatli. 2Rivers Group enables shipments and exports of Russian oil, notably from the Russian state owned oil-company Rosneft, by concealing the actual origin of the oil. In particular, 2Rivers Group controls a large proportion of the vessels in Russia’s so-called “shadow fleet”. Regardless of its change in name and ownership, 2Rivers Group continues to operate the same network as Coral Energy, which includes associated entities such as Nord Axis and Bellatrix, as demonstrated by the connection between the previous owners and the new management. Furthermore, the energy sector, in particular the oil sector, is a sector providing substantial revenue to the Russian Government.Therefore, Anar Madatli is involved in an economic sector providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine. 15.12.2025
1984. Talat SAFAROV Function: Shareholder in and CEO of 2Rivers GroupNationality: AzerbaijaniGender: maleAddress: 301 JBC 4, Jumeriah Lake Towers Dubai, UAE; 336 Smith Street #04-304, New Bridge Centre Singapore 050336; 409 Platinum Tower, Jumeirah Lake Towers, Dubai United Arab EmiratesAssociated individuals: Ahmed KERIMOV; Anar MADATLIAssociated entities: 2Rivers PTE LTD; 2Rivers DMCCE-mail: [email protected] Talat Safarov is a shareholder and holds a management position (CEO) in 2Rivers Group, a UAE-based oil-trading group, previously known as “Coral Energy”, which enables shipments and exports of Russian oil, notably from the Russian state owned oil-company Rosneft, by concealing the actual origin of the oil. Since 2024, the company’s shares have been held by three company managers (Talat Safarov, Ahmed Kerimov and Anar Madatli). In particular, 2Rivers Group controls a large proportion of the vessels in Russia’s so-called “shadow fleet”. Regardless of its change in name and ownership, 2Rivers Group continues to operate the same network as Coral Energy, which includes associated entities such as Nord Axis and Bellatrix, as demonstrated by the connection between the previous owner and the new management. Furthermore, the energy sector, in particular the oil sector, is a sector providing substantial revenue to the Russian Government.Therefore, Talat Safarov is significantly frustrating the provisions of Decision 2014/512/CFSP and Regulation (EU) No 833/2014. Through his position as shareholder and his management position in 2Rivers Group (formerly “Coral Energy”), he is involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine. 15.12.2025
1985. Etibar EYYUBa.k.a. Akin KOCAK POB: AzerbaijanNationality: AzerbaijanGender: male Etibar Eyyub founded and runs a network of companies including Coral Energy (later 2Rivers Group). Through this network of companies, he enables shipments and exports of Russian oil, notably from the Russian state owned oil-company Rosneft, by concealing the actual origin of the oil. In particular, the 2Rivers network controls and utilises a large proportion of the vessels in Russia’s so-called “shadow fleet”.Therefore, Etibar Eyyub is significantly frustrating the provisions of Decision 2014/512/CFSP and Regulation (EU) No 833/2014. He is also involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine. 15.12.2025’
Name Identifying information Reasons Date of listing
‘684. Nova Shipmanagement LLC-FZ Address: 6th Floor, Meydan Grandstand, Al Meydan Road, Nad Al Sheba, Dubai, United Arab EmiratesType of entity: Limited Liability CompanyPlace of registration: United Arab EmiratesIMO: 0055652 Nova Shipmanagement LLC-FZ is a UAE-based shipping company, which manages tankers transporting Russian crude oil, including for export purposes.Various tankers managed by Nova Shipmanagement LLC-FZ are part of Russia’s so-called “shadow fleet”, and are involved in high-risk shipping practices, while transporting Russian crude oil. In particular, it manages tankers previously managed by the Sovcomflot group, such as the vessels Arrow (IMO: 9413561), Amulet (IMO: 9413547) and Bobcat (IMO: 9422457).Therefore, Nova Shipmanagement LLC-FZ is controlling and managing vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33). 15.12.2025
685. Citrine Marine SPC Address: C/O: Nova Shipmanagement LLC-FZ, 6th Floor, Meydan Grandstand, Al Meydan Road, Nad Al Sheba, Dubai, United Arab EmiratesType of company: Limited Liability CompanyPlace of registration: United Arab EmiratesIMO: 0138716 Citrine Marine SPC is a UAE-based shipping company, which owns tankers transporting Russian crude oil, including for export purposes.Various tankers owned by Citrine Marine SPC are managed by Nova Shipmanagement LLC-FZ; both share the same address in the UAE. The ships are part of Russia’s so-called “shadow fleet” and are involved in high-risk shipping practices, while transporting Russian crude oil. In particular, Citrine Marine SPC manages tankers previously managed by the Sovcomflot group, such as the vessels Arrow (IMO: 9413561), Amulet (IMO: 9413547) and Bobcat (IMO: 9422457).Therefore, Citrine Marine SPC owns vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33). Citrine Marine SPC is also associated with Nova Shipmanagement LLC-FZ. 15.12.2025
686. Hung Phat Maritime Tradinga.k.a. HPMT Address: Service Zone No. 04, Level 06, R2 Tower, The Everrich Building, No. 968 3/2 Street, Word 15, District 11, Ho Chi Minh City, VietnamPlace of registration: VietnamDate of registration: 24.2.2011IMO: 6198018 Hung Phat Maritime Trading is a company that owns or manages tankers that are subject to restrictive measures imposed by the Union and by other countries for being part of the Russia’s so-called “shadow fleet”, transporting crude oil or petroleum products while practicing irregular and high-risk shipping practices.Therefore, Hung Phat Maritime Trading owns and manages vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33). Hung Phat Maritime Trading is furthermore providing technical support to the operations of such vessels. 15.12.2025
687. SeverTransBunker Company Limited Address: Office 207A, Lit A, ul Yakornaya 13, Saint Petersburg, 195027, Russian Federation; Office 601, prospect Budyonnovskiy 2, Rostov-on-Don, 344002, Russian FederationIMO: 6197187 SeverTransBunker Company Limited is a shipping company based in Russia which owns and manages tankers. The company is registered as the Beneficial Owner of multiple vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organization General Assembly resolution A.1192(33). 15.12.2025’
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 17 March 2014, the Council adopted Decision 2014/145/CFSP(1).
(2) In its conclusions of 19 December 2024, the European Council reiterated its resolute condemnation of Russia’s war of aggression against Ukraine, which constitutes a manifest violation of the Charter of the United Nations, and reaffirmed its continued support for Ukraine’s independence, sovereignty and territorial integrity within its internationally recognised borders. The European Council stated that efforts to further limit Russia’s ability to wage war must continue. It also expressed the Union’s readiness to step up pressure on Russia, including by adopting further sanctions.
(3) In view of Russia’s continued and escalating aggression against Ukraine, and in particular its recent brutal military campaign deliberately targeting civilian infrastructure, including energy, water and health facilities, which has caused severe suffering to the civilian population and which aims to undermine Ukraine’s resilience, the Council considers it necessary to adopt further restrictive measures.
(4) In particular, the Council considers that 5 persons and 4 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine should be added to the list of persons, entities and bodies subject to restrictive measures set out in the Annex to Decision 2014/145/CFSP.
(5) Decision 2014/145/CFSP should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:
The Annex to Decision 2014/145/CFSP is amended in accordance with the Annex to this Decision.
This Decision shall enter into force on the date of its publication in theOfficial Journal of the European Union.

Persons

ANNEXThe following persons and entities are added to the list of persons, entities and bodies set out in the Annex to Decision 2014/145/CFSP:

Name
Identifying information
Reasons
Date of listing
‘1981. Murtaza Ali LAKHANI
Function: Businessperson
DOB: March 1962
POB: Pakistan
Nationality: Pakistani; Canadian
Gender: male
Murtaza Lakhani is a businessperson with interests in the oil sector. Through his companies, he enables shipments and export of Russian oil, notably from the Russian state-owned oil company Rosneft. In particular, Murtaza Lakhani controls vessels transporting crude oil or petroleum products, originating in Russia or being exported from Russia, while practicing irregular and high-risk shipping practices. Such practices include not maintaining adequate liability insurance, carrying out unsafe operations, intentionally taking measures to avoid ship detection, such as switching off Automatic Identification Systems, or not operating under a transparent corporate governance policy. Furthermore, the energy sector, in particular the oil sector, is a sector providing a substantial source of revenue to the Russian Government.
Therefore, Murtaza Lakhani is involved in an economic sector providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine. He is also controlling vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33).
15.12.2025 1982. Valery KILDIYAROV
Function: Manager of Alghaf Marine DMCC; finance director of Litasco Middle East DMCC
Gender: male
Valery Kildiyarov is a manager of Alghaf Marine DMCC, and the finance director of Litasco Middle East DMCC. Both companies supply significant volumes of Russian crude oil. The energy sector, in particular the oil sector, is a sector providing a substantial source of revenue to the Russian Government.
Therefore, Valery Kildiyarov is involved in an economic sector providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine. Additionally, Valery Kildiyarov is associated with Litasco Middle East DMCC.
15.12.2025 1983. Anar MADATLI
Function: Shareholder in and Director of 2Rivers Group
Anar Madatli is a shareholder in and director of 2Rivers Group, a UAE based oil-trading company previously known as “Coral Energy”. Since 2024, the company’s shares have been held by three company managers – Talat Safarov, Ahmed Kerimov and Anar Madatli. 2Rivers Group enables shipments and exports of Russian oil, notably from the Russian state owned oil-company Rosneft, by concealing the actual origin of the oil. In particular, 2Rivers Group controls a large proportion of the vessels in Russia’s so-called “shadow fleet”. Regardless of its change in name and ownership, 2Rivers Group continues to operate the same network as Coral Energy, which includes associated entities such as Nord Axis and Bellatrix, as demonstrated by the connection between the previous owners and the new management. Furthermore, the energy sector, in particular the oil sector, is a sector providing substantial revenue to the Russian Government.
Therefore, Anar Madatli is involved in an economic sector providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine.
15.12.2025 1984. Talat SAFAROV
Function: Shareholder in and CEO of 2Rivers Group
Nationality: Azerbaijani
Gender: male
Address: 301 JBC 4, Jumeriah Lake Towers Dubai, UAE; 336 Smith Street #04-304, New Bridge Centre Singapore 050336; 409 Platinum Tower, Jumeirah Lake Towers, Dubai United Arab Emirates
Associated individuals: Ahmed KERIMOV; Anar MADATLI
Associated entities: 2Rivers PTE LTD; 2Rivers DMCC
E-mail: [email protected]
Talat Safarov is a shareholder and holds a management position (CEO) in 2Rivers Group, a UAE-based oil-trading group, previously known as “Coral Energy”, which enables shipments and exports of Russian oil, notably from the Russian state owned oil-company Rosneft, by concealing the actual origin of the oil. Since 2024, the company’s shares have been held by three company managers (Talat Safarov, Ahmed Kerimov and Anar Madatli). In particular, 2Rivers Group controls a large proportion of the vessels in Russia’s so-called “shadow fleet”. Regardless of its change in name and ownership, 2Rivers Group continues to operate the same network as Coral Energy, which includes associated entities such as Nord Axis and Bellatrix, as demonstrated by the connection between the previous owner and the new management. Furthermore, the energy sector, in particular the oil sector, is a sector providing substantial revenue to the Russian Government.
Therefore, Talat Safarov is significantly frustrating the provisions of Decision 2014/512/CFSP and Regulation (EU) No 833/2014. Through his position as shareholder and his management position in 2Rivers Group (formerly “Coral Energy”), he is involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine.
15.12.2025 1985. Etibar EYYUB
a.k.a. Akin KOCAK
POB: Azerbaijan
Nationality: Azerbaijan
Gender: male
Etibar Eyyub founded and runs a network of companies including Coral Energy (later 2Rivers Group). Through this network of companies, he enables shipments and exports of Russian oil, notably from the Russian state owned oil-company Rosneft, by concealing the actual origin of the oil. In particular, the 2Rivers network controls and utilises a large proportion of the vessels in Russia’s so-called “shadow fleet”.
Therefore, Etibar Eyyub is significantly frustrating the provisions of Decision 2014/512/CFSP and Regulation (EU) No 833/2014. He is also involved in economic sectors providing a substantial source of revenue to the Government of the Russian Federation, which is responsible for the annexation of Crimea and the destabilisation of Ukraine.
15.12.2025’

Entities

Name
Identifying information
Reasons
Date of listing
‘684. Nova Shipmanagement LLC-FZ
Address: 6th Floor, Meydan Grandstand, Al Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates
Type of entity: Limited Liability Company
Place of registration: United Arab Emirates
IMO: 0055652
Nova Shipmanagement LLC-FZ is a UAE-based shipping company, which manages tankers transporting Russian crude oil, including for export purposes.
Various tankers managed by Nova Shipmanagement LLC-FZ are part of Russia’s so-called “shadow fleet”, and are involved in high-risk shipping practices, while transporting Russian crude oil. In particular, it manages tankers previously managed by the Sovcomflot group, such as the vessels Arrow (IMO: 9413561), Amulet (IMO: 9413547) and Bobcat (IMO: 9422457).
Therefore, Nova Shipmanagement LLC-FZ is controlling and managing vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33).
15.12.2025 685. Citrine Marine SPC
Address: C/O: Nova Shipmanagement LLC-FZ, 6th Floor, Meydan Grandstand, Al Meydan Road, Nad Al Sheba, Dubai, United Arab Emirates
Type of company: Limited Liability Company
Place of registration: United Arab Emirates
IMO: 0138716
Citrine Marine SPC is a UAE-based shipping company, which owns tankers transporting Russian crude oil, including for export purposes.
Various tankers owned by Citrine Marine SPC are managed by Nova Shipmanagement LLC-FZ; both share the same address in the UAE. The ships are part of Russia’s so-called “shadow fleet” and are involved in high-risk shipping practices, while transporting Russian crude oil. In particular, Citrine Marine SPC manages tankers previously managed by the Sovcomflot group, such as the vessels Arrow (IMO: 9413561), Amulet (IMO: 9413547) and Bobcat (IMO: 9422457).
Therefore, Citrine Marine SPC owns vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33). Citrine Marine SPC is also associated with Nova Shipmanagement LLC-FZ.
15.12.2025 686. Hung Phat Maritime Trading
a.k.a. HPMT
Address: Service Zone No. 04, Level 06, R2 Tower, The Everrich Building, No. 968 3/2 Street, Word 15, District 11, Ho Chi Minh City, Vietnam
Place of registration: Vietnam
Date of registration: 24.2.2011
IMO: 6198018
Hung Phat Maritime Trading is a company that owns or manages tankers that are subject to restrictive measures imposed by the Union and by other countries for being part of the Russia’s so-called “shadow fleet”, transporting crude oil or petroleum products while practicing irregular and high-risk shipping practices.
Therefore, Hung Phat Maritime Trading owns and manages vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33). Hung Phat Maritime Trading is furthermore providing technical support to the operations of such vessels.
15.12.2025 687. SeverTransBunker Company Limited
Address: Office 207A, Lit A, ul Yakornaya 13, Saint Petersburg, 195027, Russian Federation; Office 601, prospect Budyonnovskiy 2, Rostov-on-Don, 344002, Russian Federation
IMO: 6197187
SeverTransBunker Company Limited is a shipping company based in Russia which owns and manages tankers. The company is registered as the Beneficial Owner of multiple vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices as set out in the International Maritime Organization General Assembly resolution A.1192(33).
15.12.2025’

Council Decision (CFSP) 2025/2572 of 15 December 2025 amending Decision (CFSP) 2024/2643 concerning restrictive measures in view of Russia’s destabilising activities

Official Journalof the European Union ENL series
2025/2572 15.12.2025
(1) On 8 October 2024, the Council adopted Decision (CFSP) 2024/2643(1).
(2) On 18 July 2025, the High Representative of the Union for Foreign Affairs and Security Policy (‘the High Representative’) published a statement on behalf of the Union in which she strongly condemned the persistent malicious activities posed by Russia, which form part of broader, coordinated and long-standing hybrid campaigns aimed at threatening and undermining the security, resilience and democratic foundations of the Union, its Member States and its partners. The High Representative stressed that Russia’s malicious activities had escalated further since the beginning of the war of aggression against Ukraine and were highly likely to persist in the foreseeable future.
(3) The Union remains unwavering in its condemnation of Russia’s malicious activities directed against the Union, its Member States, international organisations and third countries.
(4) In view of the gravity of the situation, the Council considers that 12 natural persons and two entities should be added to the list of natural and legal persons, entities and bodies set out in Annex I to Decision (CFSP) 2024/2643.
(5) Decision (CFSP) 2024/2643 should therefore be amended accordingly,
(1) the following entries are added under the heading ‘A. Natural persons’:NameIdentifying informationStatement of ReasonsDate of listing‘48.John Mark DOUGANFunction: former Florida deputy sheriffDOB: 15.12.1976POB: Wilmington, Delaware, United States of AmericaNationality: American, RussianGender: maleJohn Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is publicly accused of participating in pro-Kremlin digital information operations from Moscow by operating the CopyCop network of fake news websites and supporting Storm-1516 activities. The inauthentic websites mimic legitimate media outlets and spread fabricated stories and AI-generated deepfake content. Reports from Western authorities and independent investigative sources link Dougan’s activities to Russia’s military intelligence agency (GRU) and the Moscow-based think tank the Center for Geopolitical Expertise, suggesting he receives Russian support and direction to influence elections, discredit political figures and manipulate public discourse in Western countries.Therefore, John Dougan is responsible for, implementing, supporting or benefitting from actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union and in third countries by planning, directing, engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference.15.12.202549.Andrey Andreievich SUSHENTSOV(Russian: Андрей Андреевич СУШЕНЦОВ)Function: Director of the Institute for International Studies (IIS), Moscow State Institute of International Relations (MGIMO University) – a diplomatic academy under the Ministry of Foreign Affairs of the Russian Federation; Programme Director of the Valdai Discussion Club; member of the Council on Foreign and Defence Policy (SVOP); frequent commentator for Russian state media and author for Russia in Global Affairs and other Kremlin-aligned outletsDOB: 8.6.1983POB: Orenburg, USSR (now Russian Federation)Nationality: RussianGender: maleINN: 400407010797Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating within the state-academic and think-tank system. His institute (IIS MGIMO) is directly subordinated to the Russian Ministry of Foreign Affairs and closely integrated with official diplomatic and strategic planning structures. Sushentsov regularly appears in Russian and international media, presenting Russia’s foreign-policy worldview in line with Kremlin messaging. His commentary consistently promotes the following narratives: the West provoked the conflict in Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are defensive and aimed at restoring “strategic balance” in the international system; the “unipolar world order” led by the US is collapsing, and Russia, together with China and the “Global South”, is constructing a fairer multipolar world; and Western sanctions are illegitimate and self-destructive, used as tools of coercion against sovereign states. He frequently represents the Russian perspective at Valdai panels attended by President Vladimir Putin and senior officials, serving as both an organiser and a spokesperson for Kremlin-approved messaging.Therefore, Andrey Sushentsov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference.15.12.202550.Dmitry Vyacheslavovich SUSLOV(Russian: Дмитрий Вячеславович СУСЛОВ)Function: Deputy Director, Centre for Comprehensive European and International Studies (CCEIS), Higher School of Economics (HSE University), Moscow; Deputy Director for Research Programmes at the Council on Foreign and Defence Policy (SVOP); expert and frequent speaker at the Valdai Discussion Club; contributor to Russia in Global Affairs and other Kremlin-aligned publicationsDOB: 15.2.1979POB: Leningrad, USSR (now Saint Petersburg, Russian Federation)Nationality: RussianGender: maleDmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE University, the Council on Foreign and Defence Policy, and the Valdai Discussion Club, he regularly participates in high-level discussions shaping and disseminating Russia’s foreign-policy narratives. He frequently appears as an “independent expert” in Russian state and international media, where he advances positions consistent with official Kremlin lines: portraying NATO and the United States as responsible for provoking the war in Ukraine, framing Western military support to Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian coercive actions as defensive or inevitable responses to Western aggression.In 2024, Suslov publicly suggested that Russia should consider a “demonstrative nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement widely reported by Reuters and other outlets. Such remarks normalise the idea of nuclear signalling and coercion, directly contributing to the climate of intimidation surrounding Russia’s war policy.Therefore, Dmitry Suslov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating or otherwise facilitating a violent conflict in a third country.15.12.202551.Fyodor Aleksandrovich LUKYANOV(Russian: Фёдор Александрович ЛУКЬЯНОВ)Function: journalist, TV presenter and political scientist; Editor-in-Chief of Russia in Global Affairs; Research Director of the Valdai Discussion Club; member of the Russian International Affairs Council (RIAC)DOB: 1.2.1967POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: maleFyodor Lukyanov is a prominent Russian political analyst, foreign-policy commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential foreign-policy journals, and serves as Research Director of the Valdai Discussion Club, a platform strongly linked to the Russian leadership and frequently used to promote official narratives. He is also a member of the Russian International Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin at Valdai forums.Through his writing, interviews and public appearances, Lukyanov consistently amplifies Kremlin propaganda, portraying Russia’s war of aggression against Ukraine as a defensive reaction to Western policies. He repeatedly blames the Union, NATO and the United States for “provoking” the conflict, describes Ukraine as a Western proxy rather than a sovereign state, and justifies Russian military actions as “necessary” to stop NATO expansion. His arguments are frequently cited in pro-Kremlin media and shape the intellectual framework used to legitimise Russia’s aggression.He is a key opinion leader providing ideological cover for Russian aggression. His work at Valdai and Russia in Global Affairs directly supports Kremlin foreign-policy narratives abroad. He contributes to systematic disinformation campaigns that shift blame for the war onto Ukraine and the West.Therefore, Fyodor Lukyanov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating a violent conflict in a third country.15.12.202552.Ivan Nikolaevich TIMOFEEVFunction: political scientist, foreign-policy analyst and policy strategist; Director-General of the Russian International Affairs Council (RIAC); Programme Director of the Valdai Discussion ClubDOB: 1983POB: USSR (now Russian Federation)Nationality: RussianGender: maleIvan Timofeev is a prominent Russian political scientist and foreign-policy analyst closely associated with Kremlin-aligned institutions. He serves as the Director-General of the Russian International Affairs Council (RIAC) – an organisation established by the Russian Foreign Ministry – and as a Programme Director of the Valdai Discussion Club, a high-profile platform used by the Russian leadership, including President Vladimir Putin, to promote official state narratives to domestic and international audiences. Timofeev is also a frequent contributor to Russia in Global Affairs and a commentator for state media such as TASS and Izvestia.Through his writing, interviews and appearances at Valdai forums, Timofeev consistently amplifies Kremlin propaganda. He portrays Russia’s invasion of Ukraine as a defensive response to Western provocation, describes Ukraine as a Western “proxy,” and blames the United States and NATO for escalating the conflict. His analyses routinely legitimise Russian military aggression and normalise confrontation with the West, while discrediting Western sanctions and portraying them as acts of hostility.Therefore, Ivan Timofeev is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country (Ukraine), or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference.15.12.202553.Andrey Georgievich BYSTRITSKYI(Russian: Андрей Георгиевич БЫСТРИЦКИЙ)Function: journalist, media manager, academic and think-tank executive; Chairman of the Board of the Valdai Discussion Club FoundationDOB: 21.7.1960POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: maleAndrei Bystritskyi’s leadership in Valdai and his media/academic background suggest he actively supports and disseminates the official Russian narrative regarding international relations, media control and Russia’s role in global affairs. The Valdai Club is used as a tool of Russian public diplomacy and soft power; by managing this body, Bystritskyi contributes to the infrastructure of state narrative production and dissemination. As dean of a major university faculty (communications/media) and a seasoned media-manager, he is in a position to shape curricula, research and public discourse around media, communications and state narratives – which can facilitate coordinated information or interference campaigns. His quotes and speeches reflect and promote Russian diplomatic narratives – such as those about a multipolar world or the Global South cooperating with Russia, which align with Kremlin strategic messaging.Therefore, Andrei Bystritskyi is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States or in a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference.15.12.202554.Vladislav Yevgenevich BOROVKOV(Russian: Владислав Евгеньевич БОРОВКОВ)Function: officer (Senior Lieutenant) of GRU Unit 29155DOB: 7.10.1997POB: Russian FederationNationality: RussianGender: maleVladislav Borovkov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Borovkov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Vladislav Borovkov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and Ukraine by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155.15.12.202555.Denis Igorevich DENISENKO(Russian: Денис Игоревич ДЕНИСЕНКО)Function: officer of GRU Unit 29155DOB: 14.5.1997POB: Russian FederationNationality: RussianGender: maleDenis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Denisenko took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Denis Denisenko is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155.15.12.202556.Dmitry Iurevich GOLOSHUBOV(Russian: Дмитрий Юрьевич ГОЛОШУБОВ)Function: officer of GRU Unit 29155DOB: 10.10.1998POB: Russian FederationNationality: RussianGender: maleDmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Goloshubov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Unionand members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Dmitry Goloshubov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155.15.12.202557.Jacques BAUDFunction: former colonel in the Swiss army; former strategic analyst, intelligence and terrorism specialistDOB: 1.4.1955Nationality: SwissGender: maleJacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest on pro-Russian television and radio programmes. He acts as a mouthpiece for pro-Russian propaganda and makes conspiracy theories, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Jacques Baud is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference.15.12.202558.Xavier MOREAUFunction: former military officer and Franco-Russian businessman; founder of the Stratpol websiteDOB: 25.10.1971Nationality: FrenchGender: maleXavier Moreau is a businessman and founder of the Stratpol website, and a former military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Xavier Moreau is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference.15.12.202559.Diana Vitaliivna PANCHENKO (Ukrainian: Діана Віталіївна ПАНЧЕНКО)(Russian: Диана Витальевна ПАНЧЕНКО)DOB: 21.5.1988POB: Mykolaïv, Ukrainian SSR (now Ukraine)Nationality: Ukrainian, RussianGender: femaleDiana Panchenko is a Ukrainian-born journalist and propagandist. She produces and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.In her videos, she deliberately mimics news-broadcast formats, in order to legitimise the Kremlin’s narratives. She manipulates information to portray Ukrainian authorities as “Nazis” and accuses them of betraying their own people, while justifying Russia’s military aggression and crimes.She has produced work in occupied Ukrainian regions (including in Mariupol and Donetsk) which has been described as propaganda justifying war crimes by the Ukrainian Security Service (SBU). Her content was broadcasted on Ukrainian televisions during a Russian cyber attack that disrupted television programming.Panchenko also amplifies conspiratorial and anti-Ukrainian rhetoric on her Telegram channel (402k subscribers) and on X (148k followers). On her X account, she tries to increase her English-speaking audience by using clickbait content and inauthentic activity and by promoting pro-Russian accounts.Therefore, Diana Panchenko is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference.15.12.2025’ Name Identifying information Statement of Reasons Date of listing ‘48. John Mark DOUGAN Function: former Florida deputy sheriffDOB: 15.12.1976POB: Wilmington, Delaware, United States of AmericaNationality: American, RussianGender: male John Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is publicly accused of participating in pro-Kremlin digital information operations from Moscow by operating the CopyCop network of fake news websites and supporting Storm-1516 activities. The inauthentic websites mimic legitimate media outlets and spread fabricated stories and AI-generated deepfake content. Reports from Western authorities and independent investigative sources link Dougan’s activities to Russia’s military intelligence agency (GRU) and the Moscow-based think tank the Center for Geopolitical Expertise, suggesting he receives Russian support and direction to influence elections, discredit political figures and manipulate public discourse in Western countries.Therefore, John Dougan is responsible for, implementing, supporting or benefitting from actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union and in third countries by planning, directing, engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025 49. Andrey Andreievich SUSHENTSOV(Russian: Андрей Андреевич СУШЕНЦОВ) Function: Director of the Institute for International Studies (IIS), Moscow State Institute of International Relations (MGIMO University) – a diplomatic academy under the Ministry of Foreign Affairs of the Russian Federation; Programme Director of the Valdai Discussion Club; member of the Council on Foreign and Defence Policy (SVOP); frequent commentator for Russian state media and author for Russia in Global Affairs and other Kremlin-aligned outletsDOB: 8.6.1983POB: Orenburg, USSR (now Russian Federation)Nationality: RussianGender: maleINN: 400407010797 Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating within the state-academic and think-tank system. His institute (IIS MGIMO) is directly subordinated to the Russian Ministry of Foreign Affairs and closely integrated with official diplomatic and strategic planning structures. Sushentsov regularly appears in Russian and international media, presenting Russia’s foreign-policy worldview in line with Kremlin messaging. His commentary consistently promotes the following narratives: the West provoked the conflict in Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are defensive and aimed at restoring “strategic balance” in the international system; the “unipolar world order” led by the US is collapsing, and Russia, together with China and the “Global South”, is constructing a fairer multipolar world; and Western sanctions are illegitimate and self-destructive, used as tools of coercion against sovereign states. He frequently represents the Russian perspective at Valdai panels attended by President Vladimir Putin and senior officials, serving as both an organiser and a spokesperson for Kremlin-approved messaging.Therefore, Andrey Sushentsov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025 50. Dmitry Vyacheslavovich SUSLOV(Russian: Дмитрий Вячеславович СУСЛОВ) Function: Deputy Director, Centre for Comprehensive European and International Studies (CCEIS), Higher School of Economics (HSE University), Moscow; Deputy Director for Research Programmes at the Council on Foreign and Defence Policy (SVOP); expert and frequent speaker at the Valdai Discussion Club; contributor to Russia in Global Affairs and other Kremlin-aligned publicationsDOB: 15.2.1979POB: Leningrad, USSR (now Saint Petersburg, Russian Federation)Nationality: RussianGender: male Dmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE University, the Council on Foreign and Defence Policy, and the Valdai Discussion Club, he regularly participates in high-level discussions shaping and disseminating Russia’s foreign-policy narratives. He frequently appears as an “independent expert” in Russian state and international media, where he advances positions consistent with official Kremlin lines: portraying NATO and the United States as responsible for provoking the war in Ukraine, framing Western military support to Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian coercive actions as defensive or inevitable responses to Western aggression.In 2024, Suslov publicly suggested that Russia should consider a “demonstrative nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement widely reported by Reuters and other outlets. Such remarks normalise the idea of nuclear signalling and coercion, directly contributing to the climate of intimidation surrounding Russia’s war policy.Therefore, Dmitry Suslov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating or otherwise facilitating a violent conflict in a third country. 15.12.2025 51. Fyodor Aleksandrovich LUKYANOV(Russian: Фёдор Александрович ЛУКЬЯНОВ) Function: journalist, TV presenter and political scientist; Editor-in-Chief of Russia in Global Affairs; Research Director of the Valdai Discussion Club; member of the Russian International Affairs Council (RIAC)DOB: 1.2.1967POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male Fyodor Lukyanov is a prominent Russian political analyst, foreign-policy commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential foreign-policy journals, and serves as Research Director of the Valdai Discussion Club, a platform strongly linked to the Russian leadership and frequently used to promote official narratives. He is also a member of the Russian International Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin at Valdai forums.Through his writing, interviews and public appearances, Lukyanov consistently amplifies Kremlin propaganda, portraying Russia’s war of aggression against Ukraine as a defensive reaction to Western policies. He repeatedly blames the Union, NATO and the United States for “provoking” the conflict, describes Ukraine as a Western proxy rather than a sovereign state, and justifies Russian military actions as “necessary” to stop NATO expansion. His arguments are frequently cited in pro-Kremlin media and shape the intellectual framework used to legitimise Russia’s aggression.He is a key opinion leader providing ideological cover for Russian aggression. His work at Valdai and Russia in Global Affairs directly supports Kremlin foreign-policy narratives abroad. He contributes to systematic disinformation campaigns that shift blame for the war onto Ukraine and the West.Therefore, Fyodor Lukyanov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating a violent conflict in a third country. 15.12.2025 52. Ivan Nikolaevich TIMOFEEV Function: political scientist, foreign-policy analyst and policy strategist; Director-General of the Russian International Affairs Council (RIAC); Programme Director of the Valdai Discussion ClubDOB: 1983POB: USSR (now Russian Federation)Nationality: RussianGender: male Ivan Timofeev is a prominent Russian political scientist and foreign-policy analyst closely associated with Kremlin-aligned institutions. He serves as the Director-General of the Russian International Affairs Council (RIAC) – an organisation established by the Russian Foreign Ministry – and as a Programme Director of the Valdai Discussion Club, a high-profile platform used by the Russian leadership, including President Vladimir Putin, to promote official state narratives to domestic and international audiences. Timofeev is also a frequent contributor to Russia in Global Affairs and a commentator for state media such as TASS and Izvestia.Through his writing, interviews and appearances at Valdai forums, Timofeev consistently amplifies Kremlin propaganda. He portrays Russia’s invasion of Ukraine as a defensive response to Western provocation, describes Ukraine as a Western “proxy,” and blames the United States and NATO for escalating the conflict. His analyses routinely legitimise Russian military aggression and normalise confrontation with the West, while discrediting Western sanctions and portraying them as acts of hostility.Therefore, Ivan Timofeev is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country (Ukraine), or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025 53. Andrey Georgievich BYSTRITSKYI(Russian: Андрей Георгиевич БЫСТРИЦКИЙ) Function: journalist, media manager, academic and think-tank executive; Chairman of the Board of the Valdai Discussion Club FoundationDOB: 21.7.1960POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male Andrei Bystritskyi’s leadership in Valdai and his media/academic background suggest he actively supports and disseminates the official Russian narrative regarding international relations, media control and Russia’s role in global affairs. The Valdai Club is used as a tool of Russian public diplomacy and soft power; by managing this body, Bystritskyi contributes to the infrastructure of state narrative production and dissemination. As dean of a major university faculty (communications/media) and a seasoned media-manager, he is in a position to shape curricula, research and public discourse around media, communications and state narratives – which can facilitate coordinated information or interference campaigns. His quotes and speeches reflect and promote Russian diplomatic narratives – such as those about a multipolar world or the Global South cooperating with Russia, which align with Kremlin strategic messaging.Therefore, Andrei Bystritskyi is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States or in a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025 54. Vladislav Yevgenevich BOROVKOV(Russian: Владислав Евгеньевич БОРОВКОВ) Function: officer (Senior Lieutenant) of GRU Unit 29155DOB: 7.10.1997POB: Russian FederationNationality: RussianGender: male Vladislav Borovkov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Borovkov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Vladislav Borovkov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and Ukraine by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025 55. Denis Igorevich DENISENKO(Russian: Денис Игоревич ДЕНИСЕНКО) Function: officer of GRU Unit 29155DOB: 14.5.1997POB: Russian FederationNationality: RussianGender: male Denis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Denisenko took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Denis Denisenko is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025 56. Dmitry Iurevich GOLOSHUBOV(Russian: Дмитрий Юрьевич ГОЛОШУБОВ) Function: officer of GRU Unit 29155DOB: 10.10.1998POB: Russian FederationNationality: RussianGender: male Dmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Goloshubov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Unionand members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Dmitry Goloshubov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025 57. Jacques BAUD Function: former colonel in the Swiss army; former strategic analyst, intelligence and terrorism specialistDOB: 1.4.1955Nationality: SwissGender: male Jacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest on pro-Russian television and radio programmes. He acts as a mouthpiece for pro-Russian propaganda and makes conspiracy theories, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Jacques Baud is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025 58. Xavier MOREAU Function: former military officer and Franco-Russian businessman; founder of the Stratpol websiteDOB: 25.10.1971Nationality: FrenchGender: male Xavier Moreau is a businessman and founder of the Stratpol website, and a former military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Xavier Moreau is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025 59. Diana Vitaliivna PANCHENKO (Ukrainian: Діана Віталіївна ПАНЧЕНКО)(Russian: Диана Витальевна ПАНЧЕНКО) DOB: 21.5.1988POB: Mykolaïv, Ukrainian SSR (now Ukraine)Nationality: Ukrainian, RussianGender: female Diana Panchenko is a Ukrainian-born journalist and propagandist. She produces and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.In her videos, she deliberately mimics news-broadcast formats, in order to legitimise the Kremlin’s narratives. She manipulates information to portray Ukrainian authorities as “Nazis” and accuses them of betraying their own people, while justifying Russia’s military aggression and crimes.She has produced work in occupied Ukrainian regions (including in Mariupol and Donetsk) which has been described as propaganda justifying war crimes by the Ukrainian Security Service (SBU). Her content was broadcasted on Ukrainian televisions during a Russian cyber attack that disrupted television programming.Panchenko also amplifies conspiratorial and anti-Ukrainian rhetoric on her Telegram channel (402k subscribers) and on X (148k followers). On her X account, she tries to increase her English-speaking audience by using clickbait content and inauthentic activity and by promoting pro-Russian accounts.Therefore, Diana Panchenko is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025’
Name Identifying information Statement of Reasons Date of listing
‘48. John Mark DOUGAN Function: former Florida deputy sheriffDOB: 15.12.1976POB: Wilmington, Delaware, United States of AmericaNationality: American, RussianGender: male John Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is publicly accused of participating in pro-Kremlin digital information operations from Moscow by operating the CopyCop network of fake news websites and supporting Storm-1516 activities. The inauthentic websites mimic legitimate media outlets and spread fabricated stories and AI-generated deepfake content. Reports from Western authorities and independent investigative sources link Dougan’s activities to Russia’s military intelligence agency (GRU) and the Moscow-based think tank the Center for Geopolitical Expertise, suggesting he receives Russian support and direction to influence elections, discredit political figures and manipulate public discourse in Western countries.Therefore, John Dougan is responsible for, implementing, supporting or benefitting from actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union and in third countries by planning, directing, engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
49. Andrey Andreievich SUSHENTSOV(Russian: Андрей Андреевич СУШЕНЦОВ) Function: Director of the Institute for International Studies (IIS), Moscow State Institute of International Relations (MGIMO University) – a diplomatic academy under the Ministry of Foreign Affairs of the Russian Federation; Programme Director of the Valdai Discussion Club; member of the Council on Foreign and Defence Policy (SVOP); frequent commentator for Russian state media and author for Russia in Global Affairs and other Kremlin-aligned outletsDOB: 8.6.1983POB: Orenburg, USSR (now Russian Federation)Nationality: RussianGender: maleINN: 400407010797 Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating within the state-academic and think-tank system. His institute (IIS MGIMO) is directly subordinated to the Russian Ministry of Foreign Affairs and closely integrated with official diplomatic and strategic planning structures. Sushentsov regularly appears in Russian and international media, presenting Russia’s foreign-policy worldview in line with Kremlin messaging. His commentary consistently promotes the following narratives: the West provoked the conflict in Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are defensive and aimed at restoring “strategic balance” in the international system; the “unipolar world order” led by the US is collapsing, and Russia, together with China and the “Global South”, is constructing a fairer multipolar world; and Western sanctions are illegitimate and self-destructive, used as tools of coercion against sovereign states. He frequently represents the Russian perspective at Valdai panels attended by President Vladimir Putin and senior officials, serving as both an organiser and a spokesperson for Kremlin-approved messaging.Therefore, Andrey Sushentsov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
50. Dmitry Vyacheslavovich SUSLOV(Russian: Дмитрий Вячеславович СУСЛОВ) Function: Deputy Director, Centre for Comprehensive European and International Studies (CCEIS), Higher School of Economics (HSE University), Moscow; Deputy Director for Research Programmes at the Council on Foreign and Defence Policy (SVOP); expert and frequent speaker at the Valdai Discussion Club; contributor to Russia in Global Affairs and other Kremlin-aligned publicationsDOB: 15.2.1979POB: Leningrad, USSR (now Saint Petersburg, Russian Federation)Nationality: RussianGender: male Dmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE University, the Council on Foreign and Defence Policy, and the Valdai Discussion Club, he regularly participates in high-level discussions shaping and disseminating Russia’s foreign-policy narratives. He frequently appears as an “independent expert” in Russian state and international media, where he advances positions consistent with official Kremlin lines: portraying NATO and the United States as responsible for provoking the war in Ukraine, framing Western military support to Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian coercive actions as defensive or inevitable responses to Western aggression.In 2024, Suslov publicly suggested that Russia should consider a “demonstrative nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement widely reported by Reuters and other outlets. Such remarks normalise the idea of nuclear signalling and coercion, directly contributing to the climate of intimidation surrounding Russia’s war policy.Therefore, Dmitry Suslov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating or otherwise facilitating a violent conflict in a third country. 15.12.2025
51. Fyodor Aleksandrovich LUKYANOV(Russian: Фёдор Александрович ЛУКЬЯНОВ) Function: journalist, TV presenter and political scientist; Editor-in-Chief of Russia in Global Affairs; Research Director of the Valdai Discussion Club; member of the Russian International Affairs Council (RIAC)DOB: 1.2.1967POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male Fyodor Lukyanov is a prominent Russian political analyst, foreign-policy commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential foreign-policy journals, and serves as Research Director of the Valdai Discussion Club, a platform strongly linked to the Russian leadership and frequently used to promote official narratives. He is also a member of the Russian International Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin at Valdai forums.Through his writing, interviews and public appearances, Lukyanov consistently amplifies Kremlin propaganda, portraying Russia’s war of aggression against Ukraine as a defensive reaction to Western policies. He repeatedly blames the Union, NATO and the United States for “provoking” the conflict, describes Ukraine as a Western proxy rather than a sovereign state, and justifies Russian military actions as “necessary” to stop NATO expansion. His arguments are frequently cited in pro-Kremlin media and shape the intellectual framework used to legitimise Russia’s aggression.He is a key opinion leader providing ideological cover for Russian aggression. His work at Valdai and Russia in Global Affairs directly supports Kremlin foreign-policy narratives abroad. He contributes to systematic disinformation campaigns that shift blame for the war onto Ukraine and the West.Therefore, Fyodor Lukyanov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating a violent conflict in a third country. 15.12.2025
52. Ivan Nikolaevich TIMOFEEV Function: political scientist, foreign-policy analyst and policy strategist; Director-General of the Russian International Affairs Council (RIAC); Programme Director of the Valdai Discussion ClubDOB: 1983POB: USSR (now Russian Federation)Nationality: RussianGender: male Ivan Timofeev is a prominent Russian political scientist and foreign-policy analyst closely associated with Kremlin-aligned institutions. He serves as the Director-General of the Russian International Affairs Council (RIAC) – an organisation established by the Russian Foreign Ministry – and as a Programme Director of the Valdai Discussion Club, a high-profile platform used by the Russian leadership, including President Vladimir Putin, to promote official state narratives to domestic and international audiences. Timofeev is also a frequent contributor to Russia in Global Affairs and a commentator for state media such as TASS and Izvestia.Through his writing, interviews and appearances at Valdai forums, Timofeev consistently amplifies Kremlin propaganda. He portrays Russia’s invasion of Ukraine as a defensive response to Western provocation, describes Ukraine as a Western “proxy,” and blames the United States and NATO for escalating the conflict. His analyses routinely legitimise Russian military aggression and normalise confrontation with the West, while discrediting Western sanctions and portraying them as acts of hostility.Therefore, Ivan Timofeev is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country (Ukraine), or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
53. Andrey Georgievich BYSTRITSKYI(Russian: Андрей Георгиевич БЫСТРИЦКИЙ) Function: journalist, media manager, academic and think-tank executive; Chairman of the Board of the Valdai Discussion Club FoundationDOB: 21.7.1960POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male Andrei Bystritskyi’s leadership in Valdai and his media/academic background suggest he actively supports and disseminates the official Russian narrative regarding international relations, media control and Russia’s role in global affairs. The Valdai Club is used as a tool of Russian public diplomacy and soft power; by managing this body, Bystritskyi contributes to the infrastructure of state narrative production and dissemination. As dean of a major university faculty (communications/media) and a seasoned media-manager, he is in a position to shape curricula, research and public discourse around media, communications and state narratives – which can facilitate coordinated information or interference campaigns. His quotes and speeches reflect and promote Russian diplomatic narratives – such as those about a multipolar world or the Global South cooperating with Russia, which align with Kremlin strategic messaging.Therefore, Andrei Bystritskyi is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States or in a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
54. Vladislav Yevgenevich BOROVKOV(Russian: Владислав Евгеньевич БОРОВКОВ) Function: officer (Senior Lieutenant) of GRU Unit 29155DOB: 7.10.1997POB: Russian FederationNationality: RussianGender: male Vladislav Borovkov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Borovkov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Vladislav Borovkov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and Ukraine by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025
55. Denis Igorevich DENISENKO(Russian: Денис Игоревич ДЕНИСЕНКО) Function: officer of GRU Unit 29155DOB: 14.5.1997POB: Russian FederationNationality: RussianGender: male Denis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Denisenko took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Denis Denisenko is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025
56. Dmitry Iurevich GOLOSHUBOV(Russian: Дмитрий Юрьевич ГОЛОШУБОВ) Function: officer of GRU Unit 29155DOB: 10.10.1998POB: Russian FederationNationality: RussianGender: male Dmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Goloshubov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Unionand members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Dmitry Goloshubov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025
57. Jacques BAUD Function: former colonel in the Swiss army; former strategic analyst, intelligence and terrorism specialistDOB: 1.4.1955Nationality: SwissGender: male Jacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest on pro-Russian television and radio programmes. He acts as a mouthpiece for pro-Russian propaganda and makes conspiracy theories, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Jacques Baud is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025
58. Xavier MOREAU Function: former military officer and Franco-Russian businessman; founder of the Stratpol websiteDOB: 25.10.1971Nationality: FrenchGender: male Xavier Moreau is a businessman and founder of the Stratpol website, and a former military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Xavier Moreau is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025
59. Diana Vitaliivna PANCHENKO (Ukrainian: Діана Віталіївна ПАНЧЕНКО)(Russian: Диана Витальевна ПАНЧЕНКО) DOB: 21.5.1988POB: Mykolaïv, Ukrainian SSR (now Ukraine)Nationality: Ukrainian, RussianGender: female Diana Panchenko is a Ukrainian-born journalist and propagandist. She produces and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.In her videos, she deliberately mimics news-broadcast formats, in order to legitimise the Kremlin’s narratives. She manipulates information to portray Ukrainian authorities as “Nazis” and accuses them of betraying their own people, while justifying Russia’s military aggression and crimes.She has produced work in occupied Ukrainian regions (including in Mariupol and Donetsk) which has been described as propaganda justifying war crimes by the Ukrainian Security Service (SBU). Her content was broadcasted on Ukrainian televisions during a Russian cyber attack that disrupted television programming.Panchenko also amplifies conspiratorial and anti-Ukrainian rhetoric on her Telegram channel (402k subscribers) and on X (148k followers). On her X account, she tries to increase her English-speaking audience by using clickbait content and inauthentic activity and by promoting pro-Russian accounts.Therefore, Diana Panchenko is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025’
Name Identifying information Statement of Reasons Date of listing
‘48. John Mark DOUGAN Function: former Florida deputy sheriffDOB: 15.12.1976POB: Wilmington, Delaware, United States of AmericaNationality: American, RussianGender: male John Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is publicly accused of participating in pro-Kremlin digital information operations from Moscow by operating the CopyCop network of fake news websites and supporting Storm-1516 activities. The inauthentic websites mimic legitimate media outlets and spread fabricated stories and AI-generated deepfake content. Reports from Western authorities and independent investigative sources link Dougan’s activities to Russia’s military intelligence agency (GRU) and the Moscow-based think tank the Center for Geopolitical Expertise, suggesting he receives Russian support and direction to influence elections, discredit political figures and manipulate public discourse in Western countries.Therefore, John Dougan is responsible for, implementing, supporting or benefitting from actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union and in third countries by planning, directing, engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
49. Andrey Andreievich SUSHENTSOV(Russian: Андрей Андреевич СУШЕНЦОВ) Function: Director of the Institute for International Studies (IIS), Moscow State Institute of International Relations (MGIMO University) – a diplomatic academy under the Ministry of Foreign Affairs of the Russian Federation; Programme Director of the Valdai Discussion Club; member of the Council on Foreign and Defence Policy (SVOP); frequent commentator for Russian state media and author for Russia in Global Affairs and other Kremlin-aligned outletsDOB: 8.6.1983POB: Orenburg, USSR (now Russian Federation)Nationality: RussianGender: maleINN: 400407010797 Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating within the state-academic and think-tank system. His institute (IIS MGIMO) is directly subordinated to the Russian Ministry of Foreign Affairs and closely integrated with official diplomatic and strategic planning structures. Sushentsov regularly appears in Russian and international media, presenting Russia’s foreign-policy worldview in line with Kremlin messaging. His commentary consistently promotes the following narratives: the West provoked the conflict in Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are defensive and aimed at restoring “strategic balance” in the international system; the “unipolar world order” led by the US is collapsing, and Russia, together with China and the “Global South”, is constructing a fairer multipolar world; and Western sanctions are illegitimate and self-destructive, used as tools of coercion against sovereign states. He frequently represents the Russian perspective at Valdai panels attended by President Vladimir Putin and senior officials, serving as both an organiser and a spokesperson for Kremlin-approved messaging.Therefore, Andrey Sushentsov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
50. Dmitry Vyacheslavovich SUSLOV(Russian: Дмитрий Вячеславович СУСЛОВ) Function: Deputy Director, Centre for Comprehensive European and International Studies (CCEIS), Higher School of Economics (HSE University), Moscow; Deputy Director for Research Programmes at the Council on Foreign and Defence Policy (SVOP); expert and frequent speaker at the Valdai Discussion Club; contributor to Russia in Global Affairs and other Kremlin-aligned publicationsDOB: 15.2.1979POB: Leningrad, USSR (now Saint Petersburg, Russian Federation)Nationality: RussianGender: male Dmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE University, the Council on Foreign and Defence Policy, and the Valdai Discussion Club, he regularly participates in high-level discussions shaping and disseminating Russia’s foreign-policy narratives. He frequently appears as an “independent expert” in Russian state and international media, where he advances positions consistent with official Kremlin lines: portraying NATO and the United States as responsible for provoking the war in Ukraine, framing Western military support to Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian coercive actions as defensive or inevitable responses to Western aggression.In 2024, Suslov publicly suggested that Russia should consider a “demonstrative nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement widely reported by Reuters and other outlets. Such remarks normalise the idea of nuclear signalling and coercion, directly contributing to the climate of intimidation surrounding Russia’s war policy.Therefore, Dmitry Suslov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating or otherwise facilitating a violent conflict in a third country. 15.12.2025
51. Fyodor Aleksandrovich LUKYANOV(Russian: Фёдор Александрович ЛУКЬЯНОВ) Function: journalist, TV presenter and political scientist; Editor-in-Chief of Russia in Global Affairs; Research Director of the Valdai Discussion Club; member of the Russian International Affairs Council (RIAC)DOB: 1.2.1967POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male Fyodor Lukyanov is a prominent Russian political analyst, foreign-policy commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential foreign-policy journals, and serves as Research Director of the Valdai Discussion Club, a platform strongly linked to the Russian leadership and frequently used to promote official narratives. He is also a member of the Russian International Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin at Valdai forums.Through his writing, interviews and public appearances, Lukyanov consistently amplifies Kremlin propaganda, portraying Russia’s war of aggression against Ukraine as a defensive reaction to Western policies. He repeatedly blames the Union, NATO and the United States for “provoking” the conflict, describes Ukraine as a Western proxy rather than a sovereign state, and justifies Russian military actions as “necessary” to stop NATO expansion. His arguments are frequently cited in pro-Kremlin media and shape the intellectual framework used to legitimise Russia’s aggression.He is a key opinion leader providing ideological cover for Russian aggression. His work at Valdai and Russia in Global Affairs directly supports Kremlin foreign-policy narratives abroad. He contributes to systematic disinformation campaigns that shift blame for the war onto Ukraine and the West.Therefore, Fyodor Lukyanov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating a violent conflict in a third country. 15.12.2025
52. Ivan Nikolaevich TIMOFEEV Function: political scientist, foreign-policy analyst and policy strategist; Director-General of the Russian International Affairs Council (RIAC); Programme Director of the Valdai Discussion ClubDOB: 1983POB: USSR (now Russian Federation)Nationality: RussianGender: male Ivan Timofeev is a prominent Russian political scientist and foreign-policy analyst closely associated with Kremlin-aligned institutions. He serves as the Director-General of the Russian International Affairs Council (RIAC) – an organisation established by the Russian Foreign Ministry – and as a Programme Director of the Valdai Discussion Club, a high-profile platform used by the Russian leadership, including President Vladimir Putin, to promote official state narratives to domestic and international audiences. Timofeev is also a frequent contributor to Russia in Global Affairs and a commentator for state media such as TASS and Izvestia.Through his writing, interviews and appearances at Valdai forums, Timofeev consistently amplifies Kremlin propaganda. He portrays Russia’s invasion of Ukraine as a defensive response to Western provocation, describes Ukraine as a Western “proxy,” and blames the United States and NATO for escalating the conflict. His analyses routinely legitimise Russian military aggression and normalise confrontation with the West, while discrediting Western sanctions and portraying them as acts of hostility.Therefore, Ivan Timofeev is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country (Ukraine), or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
53. Andrey Georgievich BYSTRITSKYI(Russian: Андрей Георгиевич БЫСТРИЦКИЙ) Function: journalist, media manager, academic and think-tank executive; Chairman of the Board of the Valdai Discussion Club FoundationDOB: 21.7.1960POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male Andrei Bystritskyi’s leadership in Valdai and his media/academic background suggest he actively supports and disseminates the official Russian narrative regarding international relations, media control and Russia’s role in global affairs. The Valdai Club is used as a tool of Russian public diplomacy and soft power; by managing this body, Bystritskyi contributes to the infrastructure of state narrative production and dissemination. As dean of a major university faculty (communications/media) and a seasoned media-manager, he is in a position to shape curricula, research and public discourse around media, communications and state narratives – which can facilitate coordinated information or interference campaigns. His quotes and speeches reflect and promote Russian diplomatic narratives – such as those about a multipolar world or the Global South cooperating with Russia, which align with Kremlin strategic messaging.Therefore, Andrei Bystritskyi is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States or in a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025
54. Vladislav Yevgenevich BOROVKOV(Russian: Владислав Евгеньевич БОРОВКОВ) Function: officer (Senior Lieutenant) of GRU Unit 29155DOB: 7.10.1997POB: Russian FederationNationality: RussianGender: male Vladislav Borovkov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Borovkov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Vladislav Borovkov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and Ukraine by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025
55. Denis Igorevich DENISENKO(Russian: Денис Игоревич ДЕНИСЕНКО) Function: officer of GRU Unit 29155DOB: 14.5.1997POB: Russian FederationNationality: RussianGender: male Denis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Denisenko took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Denis Denisenko is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025
56. Dmitry Iurevich GOLOSHUBOV(Russian: Дмитрий Юрьевич ГОЛОШУБОВ) Function: officer of GRU Unit 29155DOB: 10.10.1998POB: Russian FederationNationality: RussianGender: male Dmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Goloshubov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Unionand members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Dmitry Goloshubov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. 15.12.2025
57. Jacques BAUD Function: former colonel in the Swiss army; former strategic analyst, intelligence and terrorism specialistDOB: 1.4.1955Nationality: SwissGender: male Jacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest on pro-Russian television and radio programmes. He acts as a mouthpiece for pro-Russian propaganda and makes conspiracy theories, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Jacques Baud is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025
58. Xavier MOREAU Function: former military officer and Franco-Russian businessman; founder of the Stratpol websiteDOB: 25.10.1971Nationality: FrenchGender: male Xavier Moreau is a businessman and founder of the Stratpol website, and a former military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Xavier Moreau is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025
59. Diana Vitaliivna PANCHENKO (Ukrainian: Діана Віталіївна ПАНЧЕНКО)(Russian: Диана Витальевна ПАНЧЕНКО) DOB: 21.5.1988POB: Mykolaïv, Ukrainian SSR (now Ukraine)Nationality: Ukrainian, RussianGender: female Diana Panchenko is a Ukrainian-born journalist and propagandist. She produces and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.In her videos, she deliberately mimics news-broadcast formats, in order to legitimise the Kremlin’s narratives. She manipulates information to portray Ukrainian authorities as “Nazis” and accuses them of betraying their own people, while justifying Russia’s military aggression and crimes.She has produced work in occupied Ukrainian regions (including in Mariupol and Donetsk) which has been described as propaganda justifying war crimes by the Ukrainian Security Service (SBU). Her content was broadcasted on Ukrainian televisions during a Russian cyber attack that disrupted television programming.Panchenko also amplifies conspiratorial and anti-Ukrainian rhetoric on her Telegram channel (402k subscribers) and on X (148k followers). On her X account, she tries to increase her English-speaking audience by using clickbait content and inauthentic activity and by promoting pro-Russian accounts.Therefore, Diana Panchenko is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. 15.12.2025’
(2) the following entries are added under the heading ‘B. Legal persons, entities and bodies’:NameIdentifying informationStatement of ReasonsDate of listing‘16.142nd Separate Electronic Warfare Battalion142-й батальон радиоэлектронной борьбы142-й батальон РЭБ142-й отдельный батальон радиоэлектронной борьбы236000, Posyolok Kumachevo, Kaliningrad region, Russian FederationThe 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is part of electronic warfare and plays an important role in ensuring the security and defence of the region. The battalion is responsible for using technology to disorganise any system of shortwave communication, conducting electronic warfare exercises to disrupt enemy navigation and radio communications as well as for the collection and analysis of intelligence information obtained by observing electromagnetic radiation in the short and ultrashort wave ranges.Recently, several European countries have experienced GPS signal failures, which have been attributed to electronic warfare activities by Russia, specifically from Kaliningrad. This includes deliberate jamming and “spoofing” of GPS signals, primarily affecting the Baltic States. Interference and manipulation of GPS signals has led to obstacles for landing civil planes.The 142nd Separate Electronic Warfare Battalion in Kaliningrad has received jamming equipment and conducted exercises using advanced systems capable of disrupting communications over large areas.Therefore, the 142nd Separate Electronic Warfare Battalion, as part of Russia’s military forces enabling the (mis)use of the radio frequency sector, is responsible for actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Member States of the Union by engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference or actions aimed at interfering with, damaging or destroying critical infrastructure through malicious cyber activities as part of hybrid activities.15.12.202517.International Russophile Movement(Russian: Международное движение русофилов)(French: Mouvement International Russophile)The International Russophile Movement is a movement responsible for amplifying destabilising narratives globally, on behalf of the Government of the Russian Federation. The movement has strong ties with the Russian Ministry of Foreign Affairs, receiving endorsements for their work. Russian foreign minister Sergey Lavrov has given keynote speeches in congress meetings of the movement. The movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin and media oligarch Konstantin Malofeev. The Government of the Russian Federation uses the movement as a cover for manipulating the public opinion of other countries, promoting anti-Western sentiment and echoing other Kremlin speaking points.Therefore, the International Russophile Movement is supporting or implementing actions attributable to the Government of the Russian Federation which undermine or threaten stability or security in the Union or in a third country (Ukraine) by engaging in, supporting or otherwise facilitating the use of information manipulation and interference.15.12.2025’ Name Identifying information Statement of Reasons Date of listing ‘16. 142nd Separate Electronic Warfare Battalion142-й батальон радиоэлектронной борьбы142-й батальон РЭБ142-й отдельный батальон радиоэлектронной борьбы 236000, Posyolok Kumachevo, Kaliningrad region, Russian Federation The 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is part of electronic warfare and plays an important role in ensuring the security and defence of the region. The battalion is responsible for using technology to disorganise any system of shortwave communication, conducting electronic warfare exercises to disrupt enemy navigation and radio communications as well as for the collection and analysis of intelligence information obtained by observing electromagnetic radiation in the short and ultrashort wave ranges.Recently, several European countries have experienced GPS signal failures, which have been attributed to electronic warfare activities by Russia, specifically from Kaliningrad. This includes deliberate jamming and “spoofing” of GPS signals, primarily affecting the Baltic States. Interference and manipulation of GPS signals has led to obstacles for landing civil planes.The 142nd Separate Electronic Warfare Battalion in Kaliningrad has received jamming equipment and conducted exercises using advanced systems capable of disrupting communications over large areas.Therefore, the 142nd Separate Electronic Warfare Battalion, as part of Russia’s military forces enabling the (mis)use of the radio frequency sector, is responsible for actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Member States of the Union by engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference or actions aimed at interfering with, damaging or destroying critical infrastructure through malicious cyber activities as part of hybrid activities. 15.12.2025 17. International Russophile Movement(Russian: Международное движение русофилов)(French: Mouvement International Russophile) The International Russophile Movement is a movement responsible for amplifying destabilising narratives globally, on behalf of the Government of the Russian Federation. The movement has strong ties with the Russian Ministry of Foreign Affairs, receiving endorsements for their work. Russian foreign minister Sergey Lavrov has given keynote speeches in congress meetings of the movement. The movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin and media oligarch Konstantin Malofeev. The Government of the Russian Federation uses the movement as a cover for manipulating the public opinion of other countries, promoting anti-Western sentiment and echoing other Kremlin speaking points.Therefore, the International Russophile Movement is supporting or implementing actions attributable to the Government of the Russian Federation which undermine or threaten stability or security in the Union or in a third country (Ukraine) by engaging in, supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025’
Name Identifying information Statement of Reasons Date of listing
‘16. 142nd Separate Electronic Warfare Battalion142-й батальон радиоэлектронной борьбы142-й батальон РЭБ142-й отдельный батальон радиоэлектронной борьбы 236000, Posyolok Kumachevo, Kaliningrad region, Russian Federation The 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is part of electronic warfare and plays an important role in ensuring the security and defence of the region. The battalion is responsible for using technology to disorganise any system of shortwave communication, conducting electronic warfare exercises to disrupt enemy navigation and radio communications as well as for the collection and analysis of intelligence information obtained by observing electromagnetic radiation in the short and ultrashort wave ranges.Recently, several European countries have experienced GPS signal failures, which have been attributed to electronic warfare activities by Russia, specifically from Kaliningrad. This includes deliberate jamming and “spoofing” of GPS signals, primarily affecting the Baltic States. Interference and manipulation of GPS signals has led to obstacles for landing civil planes.The 142nd Separate Electronic Warfare Battalion in Kaliningrad has received jamming equipment and conducted exercises using advanced systems capable of disrupting communications over large areas.Therefore, the 142nd Separate Electronic Warfare Battalion, as part of Russia’s military forces enabling the (mis)use of the radio frequency sector, is responsible for actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Member States of the Union by engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference or actions aimed at interfering with, damaging or destroying critical infrastructure through malicious cyber activities as part of hybrid activities. 15.12.2025
17. International Russophile Movement(Russian: Международное движение русофилов)(French: Mouvement International Russophile) The International Russophile Movement is a movement responsible for amplifying destabilising narratives globally, on behalf of the Government of the Russian Federation. The movement has strong ties with the Russian Ministry of Foreign Affairs, receiving endorsements for their work. Russian foreign minister Sergey Lavrov has given keynote speeches in congress meetings of the movement. The movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin and media oligarch Konstantin Malofeev. The Government of the Russian Federation uses the movement as a cover for manipulating the public opinion of other countries, promoting anti-Western sentiment and echoing other Kremlin speaking points.Therefore, the International Russophile Movement is supporting or implementing actions attributable to the Government of the Russian Federation which undermine or threaten stability or security in the Union or in a third country (Ukraine) by engaging in, supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025’
Name Identifying information Statement of Reasons Date of listing
‘16. 142nd Separate Electronic Warfare Battalion142-й батальон радиоэлектронной борьбы142-й батальон РЭБ142-й отдельный батальон радиоэлектронной борьбы 236000, Posyolok Kumachevo, Kaliningrad region, Russian Federation The 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is part of electronic warfare and plays an important role in ensuring the security and defence of the region. The battalion is responsible for using technology to disorganise any system of shortwave communication, conducting electronic warfare exercises to disrupt enemy navigation and radio communications as well as for the collection and analysis of intelligence information obtained by observing electromagnetic radiation in the short and ultrashort wave ranges.Recently, several European countries have experienced GPS signal failures, which have been attributed to electronic warfare activities by Russia, specifically from Kaliningrad. This includes deliberate jamming and “spoofing” of GPS signals, primarily affecting the Baltic States. Interference and manipulation of GPS signals has led to obstacles for landing civil planes.The 142nd Separate Electronic Warfare Battalion in Kaliningrad has received jamming equipment and conducted exercises using advanced systems capable of disrupting communications over large areas.Therefore, the 142nd Separate Electronic Warfare Battalion, as part of Russia’s military forces enabling the (mis)use of the radio frequency sector, is responsible for actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Member States of the Union by engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference or actions aimed at interfering with, damaging or destroying critical infrastructure through malicious cyber activities as part of hybrid activities. 15.12.2025
17. International Russophile Movement(Russian: Международное движение русофилов)(French: Mouvement International Russophile) The International Russophile Movement is a movement responsible for amplifying destabilising narratives globally, on behalf of the Government of the Russian Federation. The movement has strong ties with the Russian Ministry of Foreign Affairs, receiving endorsements for their work. Russian foreign minister Sergey Lavrov has given keynote speeches in congress meetings of the movement. The movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin and media oligarch Konstantin Malofeev. The Government of the Russian Federation uses the movement as a cover for manipulating the public opinion of other countries, promoting anti-Western sentiment and echoing other Kremlin speaking points.Therefore, the International Russophile Movement is supporting or implementing actions attributable to the Government of the Russian Federation which undermine or threaten stability or security in the Union or in a third country (Ukraine) by engaging in, supporting or otherwise facilitating the use of information manipulation and interference. 15.12.2025’
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 8 October 2024, the Council adopted Decision (CFSP) 2024/2643(1).
(2) On 18 July 2025, the High Representative of the Union for Foreign Affairs and Security Policy (‘the High Representative’) published a statement on behalf of the Union in which she strongly condemned the persistent malicious activities posed by Russia, which form part of broader, coordinated and long-standing hybrid campaigns aimed at threatening and undermining the security, resilience and democratic foundations of the Union, its Member States and its partners. The High Representative stressed that Russia’s malicious activities had escalated further since the beginning of the war of aggression against Ukraine and were highly likely to persist in the foreseeable future.
(3) The Union remains unwavering in its condemnation of Russia’s malicious activities directed against the Union, its Member States, international organisations and third countries.
(4) In view of the gravity of the situation, the Council considers that 12 natural persons and two entities should be added to the list of natural and legal persons, entities and bodies set out in Annex I to Decision (CFSP) 2024/2643.
(5) Decision (CFSP) 2024/2643 should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:

Article 1
Annex I to Decision (CFSP) 2024/2643 is amended in accordance with the Annex to this Decision.

Article 2
This Decision shall enter into force on the date of its publication in theOfficial Journal of the European Union.

THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 8 October 2024, the Council adopted Decision (CFSP) 2024/2643(1).
(2) On 18 July 2025, the High Representative of the Union for Foreign Affairs and Security Policy (‘the High Representative’) published a statement on behalf of the Union in which she strongly condemned the persistent malicious activities posed by Russia, which form part of broader, coordinated and long-standing hybrid campaigns aimed at threatening and undermining the security, resilience and democratic foundations of the Union, its Member States and its partners. The High Representative stressed that Russia’s malicious activities had escalated further since the beginning of the war of aggression against Ukraine and were highly likely to persist in the foreseeable future.
(3) The Union remains unwavering in its condemnation of Russia’s malicious activities directed against the Union, its Member States, international organisations and third countries.
(4) In view of the gravity of the situation, the Council considers that 12 natural persons and two entities should be added to the list of natural and legal persons, entities and bodies set out in Annex I to Decision (CFSP) 2024/2643.
(5) Decision (CFSP) 2024/2643 should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:
Annex I to Decision (CFSP) 2024/2643 is amended in accordance with the Annex to this Decision.
This Decision shall enter into force on the date of its publication in theOfficial Journal of the European Union.
ANNEXAnnex I to Decision (CFSP) 2024/2643 is amended as follows:

(1) | the following entries are added under the heading ‘A. Natural persons’:NameIdentifying informationStatement of ReasonsDate of listing‘48.John Mark DOUGANFunction: former Florida deputy sheriffDOB: 15.12.1976POB: Wilmington, Delaware, United States of AmericaNationality: American, RussianGender: maleJohn Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is publicly accused of participating in pro-Kremlin digital information operations from Moscow by operating the CopyCop network of fake news websites and supporting Storm-1516 activities. The inauthentic websites mimic legitimate media outlets and spread fabricated stories and AI-generated deepfake content. Reports from Western authorities and independent investigative sources link Dougan’s activities to Russia’s military intelligence agency (GRU) and the Moscow-based think tank the Center for Geopolitical Expertise, suggesting he receives Russian support and direction to influence elections, discredit political figures and manipulate public discourse in Western countries.Therefore, John Dougan is responsible for, implementing, supporting or benefitting from actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union and in third countries by planning, directing, engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference.15.12.202549.Andrey Andreievich SUSHENTSOV(Russian: Андрей Андреевич СУШЕНЦОВ)Function: Director of the Institute for International Studies (IIS), Moscow State Institute of International Relations (MGIMO University) – a diplomatic academy under the Ministry of Foreign Affairs of the Russian Federation; Programme Director of the Valdai Discussion Club; member of the Council on Foreign and Defence Policy (SVOP); frequent commentator for Russian state media and author for Russia in Global Affairs and other Kremlin-aligned outletsDOB: 8.6.1983POB: Orenburg, USSR (now Russian Federation)Nationality: RussianGender: maleINN: 400407010797Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating within the state-academic and think-tank system. His institute (IIS MGIMO) is directly subordinated to the Russian Ministry of Foreign Affairs and closely integrated with official diplomatic and strategic planning structures. Sushentsov regularly appears in Russian and international media, presenting Russia’s foreign-policy worldview in line with Kremlin messaging. His commentary consistently promotes the following narratives: the West provoked the conflict in Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are defensive and aimed at restoring “strategic balance” in the international system; the “unipolar world order” led by the US is collapsing, and Russia, together with China and the “Global South”, is constructing a fairer multipolar world; and Western sanctions are illegitimate and self-destructive, used as tools of coercion against sovereign states. He frequently represents the Russian perspective at Valdai panels attended by President Vladimir Putin and senior officials, serving as both an organiser and a spokesperson for Kremlin-approved messaging.Therefore, Andrey Sushentsov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference.15.12.202550.Dmitry Vyacheslavovich SUSLOV(Russian: Дмитрий Вячеславович СУСЛОВ)Function: Deputy Director, Centre for Comprehensive European and International Studies (CCEIS), Higher School of Economics (HSE University), Moscow; Deputy Director for Research Programmes at the Council on Foreign and Defence Policy (SVOP); expert and frequent speaker at the Valdai Discussion Club; contributor to Russia in Global Affairs and other Kremlin-aligned publicationsDOB: 15.2.1979POB: Leningrad, USSR (now Saint Petersburg, Russian Federation)Nationality: RussianGender: maleDmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE University, the Council on Foreign and Defence Policy, and the Valdai Discussion Club, he regularly participates in high-level discussions shaping and disseminating Russia’s foreign-policy narratives. He frequently appears as an “independent expert” in Russian state and international media, where he advances positions consistent with official Kremlin lines: portraying NATO and the United States as responsible for provoking the war in Ukraine, framing Western military support to Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian coercive actions as defensive or inevitable responses to Western aggression.In 2024, Suslov publicly suggested that Russia should consider a “demonstrative nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement widely reported by Reuters and other outlets. Such remarks normalise the idea of nuclear signalling and coercion, directly contributing to the climate of intimidation surrounding Russia’s war policy.Therefore, Dmitry Suslov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating or otherwise facilitating a violent conflict in a third country.15.12.202551.Fyodor Aleksandrovich LUKYANOV(Russian: Фёдор Александрович ЛУКЬЯНОВ)Function: journalist, TV presenter and political scientist; Editor-in-Chief of Russia in Global Affairs; Research Director of the Valdai Discussion Club; member of the Russian International Affairs Council (RIAC)DOB: 1.2.1967POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: maleFyodor Lukyanov is a prominent Russian political analyst, foreign-policy commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential foreign-policy journals, and serves as Research Director of the Valdai Discussion Club, a platform strongly linked to the Russian leadership and frequently used to promote official narratives. He is also a member of the Russian International Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin at Valdai forums.Through his writing, interviews and public appearances, Lukyanov consistently amplifies Kremlin propaganda, portraying Russia’s war of aggression against Ukraine as a defensive reaction to Western policies. He repeatedly blames the Union, NATO and the United States for “provoking” the conflict, describes Ukraine as a Western proxy rather than a sovereign state, and justifies Russian military actions as “necessary” to stop NATO expansion. His arguments are frequently cited in pro-Kremlin media and shape the intellectual framework used to legitimise Russia’s aggression.He is a key opinion leader providing ideological cover for Russian aggression. His work at Valdai and Russia in Global Affairs directly supports Kremlin foreign-policy narratives abroad. He contributes to systematic disinformation campaigns that shift blame for the war onto Ukraine and the West.Therefore, Fyodor Lukyanov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating a violent conflict in a third country.15.12.202552.Ivan Nikolaevich TIMOFEEVFunction: political scientist, foreign-policy analyst and policy strategist; Director-General of the Russian International Affairs Council (RIAC); Programme Director of the Valdai Discussion ClubDOB: 1983POB: USSR (now Russian Federation)Nationality: RussianGender: maleIvan Timofeev is a prominent Russian political scientist and foreign-policy analyst closely associated with Kremlin-aligned institutions. He serves as the Director-General of the Russian International Affairs Council (RIAC) – an organisation established by the Russian Foreign Ministry – and as a Programme Director of the Valdai Discussion Club, a high-profile platform used by the Russian leadership, including President Vladimir Putin, to promote official state narratives to domestic and international audiences. Timofeev is also a frequent contributor to Russia in Global Affairs and a commentator for state media such as TASS and Izvestia.Through his writing, interviews and appearances at Valdai forums, Timofeev consistently amplifies Kremlin propaganda. He portrays Russia’s invasion of Ukraine as a defensive response to Western provocation, describes Ukraine as a Western “proxy,” and blames the United States and NATO for escalating the conflict. His analyses routinely legitimise Russian military aggression and normalise confrontation with the West, while discrediting Western sanctions and portraying them as acts of hostility.Therefore, Ivan Timofeev is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country (Ukraine), or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference.15.12.202553.Andrey Georgievich BYSTRITSKYI(Russian: Андрей Георгиевич БЫСТРИЦКИЙ)Function: journalist, media manager, academic and think-tank executive; Chairman of the Board of the Valdai Discussion Club FoundationDOB: 21.7.1960POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: maleAndrei Bystritskyi’s leadership in Valdai and his media/academic background suggest he actively supports and disseminates the official Russian narrative regarding international relations, media control and Russia’s role in global affairs. The Valdai Club is used as a tool of Russian public diplomacy and soft power; by managing this body, Bystritskyi contributes to the infrastructure of state narrative production and dissemination. As dean of a major university faculty (communications/media) and a seasoned media-manager, he is in a position to shape curricula, research and public discourse around media, communications and state narratives – which can facilitate coordinated information or interference campaigns. His quotes and speeches reflect and promote Russian diplomatic narratives – such as those about a multipolar world or the Global South cooperating with Russia, which align with Kremlin strategic messaging.Therefore, Andrei Bystritskyi is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States or in a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference.15.12.202554.Vladislav Yevgenevich BOROVKOV(Russian: Владислав Евгеньевич БОРОВКОВ)Function: officer (Senior Lieutenant) of GRU Unit 29155DOB: 7.10.1997POB: Russian FederationNationality: RussianGender: maleVladislav Borovkov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Borovkov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Vladislav Borovkov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and Ukraine by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155.15.12.202555.Denis Igorevich DENISENKO(Russian: Денис Игоревич ДЕНИСЕНКО)Function: officer of GRU Unit 29155DOB: 14.5.1997POB: Russian FederationNationality: RussianGender: maleDenis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Denisenko took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Denis Denisenko is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155.15.12.202556.Dmitry Iurevich GOLOSHUBOV(Russian: Дмитрий Юрьевич ГОЛОШУБОВ)Function: officer of GRU Unit 29155DOB: 10.10.1998POB: Russian FederationNationality: RussianGender: maleDmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Goloshubov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Unionand members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Dmitry Goloshubov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155.15.12.202557.Jacques BAUDFunction: former colonel in the Swiss army; former strategic analyst, intelligence and terrorism specialistDOB: 1.4.1955Nationality: SwissGender: maleJacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest on pro-Russian television and radio programmes. He acts as a mouthpiece for pro-Russian propaganda and makes conspiracy theories, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Jacques Baud is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference.15.12.202558.Xavier MOREAUFunction: former military officer and Franco-Russian businessman; founder of the Stratpol websiteDOB: 25.10.1971Nationality: FrenchGender: maleXavier Moreau is a businessman and founder of the Stratpol website, and a former military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Xavier Moreau is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference.15.12.202559.Diana Vitaliivna PANCHENKO (Ukrainian: Діана Віталіївна ПАНЧЕНКО)(Russian: Диана Витальевна ПАНЧЕНКО)DOB: 21.5.1988POB: Mykolaïv, Ukrainian SSR (now Ukraine)Nationality: Ukrainian, RussianGender: femaleDiana Panchenko is a Ukrainian-born journalist and propagandist. She produces and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.In her videos, she deliberately mimics news-broadcast formats, in order to legitimise the Kremlin’s narratives. She manipulates information to portray Ukrainian authorities as “Nazis” and accuses them of betraying their own people, while justifying Russia’s military aggression and crimes.She has produced work in occupied Ukrainian regions (including in Mariupol and Donetsk) which has been described as propaganda justifying war crimes by the Ukrainian Security Service (SBU). Her content was broadcasted on Ukrainian televisions during a Russian cyber attack that disrupted television programming.Panchenko also amplifies conspiratorial and anti-Ukrainian rhetoric on her Telegram channel (402k subscribers) and on X (148k followers). On her X account, she tries to increase her English-speaking audience by using clickbait content and inauthentic activity and by promoting pro-Russian accounts.Therefore, Diana Panchenko is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference.15.12.2025’ | | Name | Identifying information | Statement of Reasons | Date of listing | ‘48. | John Mark DOUGAN | Function: former Florida deputy sheriffDOB: 15.12.1976POB: Wilmington, Delaware, United States of AmericaNationality: American, RussianGender: male | John Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is publicly accused of participating in pro-Kremlin digital information operations from Moscow by operating the CopyCop network of fake news websites and supporting Storm-1516 activities. The inauthentic websites mimic legitimate media outlets and spread fabricated stories and AI-generated deepfake content. Reports from Western authorities and independent investigative sources link Dougan’s activities to Russia’s military intelligence agency (GRU) and the Moscow-based think tank the Center for Geopolitical Expertise, suggesting he receives Russian support and direction to influence elections, discredit political figures and manipulate public discourse in Western countries.Therefore, John Dougan is responsible for, implementing, supporting or benefitting from actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union and in third countries by planning, directing, engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025 | 49. | Andrey Andreievich SUSHENTSOV(Russian: Андрей Андреевич СУШЕНЦОВ) | Function: Director of the Institute for International Studies (IIS), Moscow State Institute of International Relations (MGIMO University) – a diplomatic academy under the Ministry of Foreign Affairs of the Russian Federation; Programme Director of the Valdai Discussion Club; member of the Council on Foreign and Defence Policy (SVOP); frequent commentator for Russian state media and author for Russia in Global Affairs and other Kremlin-aligned outletsDOB: 8.6.1983POB: Orenburg, USSR (now Russian Federation)Nationality: RussianGender: maleINN: 400407010797 | Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating within the state-academic and think-tank system. His institute (IIS MGIMO) is directly subordinated to the Russian Ministry of Foreign Affairs and closely integrated with official diplomatic and strategic planning structures. Sushentsov regularly appears in Russian and international media, presenting Russia’s foreign-policy worldview in line with Kremlin messaging. His commentary consistently promotes the following narratives: the West provoked the conflict in Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are defensive and aimed at restoring “strategic balance” in the international system; the “unipolar world order” led by the US is collapsing, and Russia, together with China and the “Global South”, is constructing a fairer multipolar world; and Western sanctions are illegitimate and self-destructive, used as tools of coercion against sovereign states. He frequently represents the Russian perspective at Valdai panels attended by President Vladimir Putin and senior officials, serving as both an organiser and a spokesperson for Kremlin-approved messaging.Therefore, Andrey Sushentsov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025 | 50. | Dmitry Vyacheslavovich SUSLOV(Russian: Дмитрий Вячеславович СУСЛОВ) | Function: Deputy Director, Centre for Comprehensive European and International Studies (CCEIS), Higher School of Economics (HSE University), Moscow; Deputy Director for Research Programmes at the Council on Foreign and Defence Policy (SVOP); expert and frequent speaker at the Valdai Discussion Club; contributor to Russia in Global Affairs and other Kremlin-aligned publicationsDOB: 15.2.1979POB: Leningrad, USSR (now Saint Petersburg, Russian Federation)Nationality: RussianGender: male | Dmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE University, the Council on Foreign and Defence Policy, and the Valdai Discussion Club, he regularly participates in high-level discussions shaping and disseminating Russia’s foreign-policy narratives. He frequently appears as an “independent expert” in Russian state and international media, where he advances positions consistent with official Kremlin lines: portraying NATO and the United States as responsible for provoking the war in Ukraine, framing Western military support to Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian coercive actions as defensive or inevitable responses to Western aggression.In 2024, Suslov publicly suggested that Russia should consider a “demonstrative nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement widely reported by Reuters and other outlets. Such remarks normalise the idea of nuclear signalling and coercion, directly contributing to the climate of intimidation surrounding Russia’s war policy.Therefore, Dmitry Suslov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating or otherwise facilitating a violent conflict in a third country. | 15.12.2025 | 51. | Fyodor Aleksandrovich LUKYANOV(Russian: Фёдор Александрович ЛУКЬЯНОВ) | Function: journalist, TV presenter and political scientist; Editor-in-Chief of Russia in Global Affairs; Research Director of the Valdai Discussion Club; member of the Russian International Affairs Council (RIAC)DOB: 1.2.1967POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male | Fyodor Lukyanov is a prominent Russian political analyst, foreign-policy commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential foreign-policy journals, and serves as Research Director of the Valdai Discussion Club, a platform strongly linked to the Russian leadership and frequently used to promote official narratives. He is also a member of the Russian International Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin at Valdai forums.Through his writing, interviews and public appearances, Lukyanov consistently amplifies Kremlin propaganda, portraying Russia’s war of aggression against Ukraine as a defensive reaction to Western policies. He repeatedly blames the Union, NATO and the United States for “provoking” the conflict, describes Ukraine as a Western proxy rather than a sovereign state, and justifies Russian military actions as “necessary” to stop NATO expansion. His arguments are frequently cited in pro-Kremlin media and shape the intellectual framework used to legitimise Russia’s aggression.He is a key opinion leader providing ideological cover for Russian aggression. His work at Valdai and Russia in Global Affairs directly supports Kremlin foreign-policy narratives abroad. He contributes to systematic disinformation campaigns that shift blame for the war onto Ukraine and the West.Therefore, Fyodor Lukyanov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating a violent conflict in a third country. | 15.12.2025 | 52. | Ivan Nikolaevich TIMOFEEV | Function: political scientist, foreign-policy analyst and policy strategist; Director-General of the Russian International Affairs Council (RIAC); Programme Director of the Valdai Discussion ClubDOB: 1983POB: USSR (now Russian Federation)Nationality: RussianGender: male | Ivan Timofeev is a prominent Russian political scientist and foreign-policy analyst closely associated with Kremlin-aligned institutions. He serves as the Director-General of the Russian International Affairs Council (RIAC) – an organisation established by the Russian Foreign Ministry – and as a Programme Director of the Valdai Discussion Club, a high-profile platform used by the Russian leadership, including President Vladimir Putin, to promote official state narratives to domestic and international audiences. Timofeev is also a frequent contributor to Russia in Global Affairs and a commentator for state media such as TASS and Izvestia.Through his writing, interviews and appearances at Valdai forums, Timofeev consistently amplifies Kremlin propaganda. He portrays Russia’s invasion of Ukraine as a defensive response to Western provocation, describes Ukraine as a Western “proxy,” and blames the United States and NATO for escalating the conflict. His analyses routinely legitimise Russian military aggression and normalise confrontation with the West, while discrediting Western sanctions and portraying them as acts of hostility.Therefore, Ivan Timofeev is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country (Ukraine), or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025 | 53. | Andrey Georgievich BYSTRITSKYI(Russian: Андрей Георгиевич БЫСТРИЦКИЙ) | Function: journalist, media manager, academic and think-tank executive; Chairman of the Board of the Valdai Discussion Club FoundationDOB: 21.7.1960POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male | Andrei Bystritskyi’s leadership in Valdai and his media/academic background suggest he actively supports and disseminates the official Russian narrative regarding international relations, media control and Russia’s role in global affairs. The Valdai Club is used as a tool of Russian public diplomacy and soft power; by managing this body, Bystritskyi contributes to the infrastructure of state narrative production and dissemination. As dean of a major university faculty (communications/media) and a seasoned media-manager, he is in a position to shape curricula, research and public discourse around media, communications and state narratives – which can facilitate coordinated information or interference campaigns. His quotes and speeches reflect and promote Russian diplomatic narratives – such as those about a multipolar world or the Global South cooperating with Russia, which align with Kremlin strategic messaging.Therefore, Andrei Bystritskyi is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States or in a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025 | 54. | Vladislav Yevgenevich BOROVKOV(Russian: Владислав Евгеньевич БОРОВКОВ) | Function: officer (Senior Lieutenant) of GRU Unit 29155DOB: 7.10.1997POB: Russian FederationNationality: RussianGender: male | Vladislav Borovkov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Borovkov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Vladislav Borovkov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and Ukraine by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. | 15.12.2025 | 55. | Denis Igorevich DENISENKO(Russian: Денис Игоревич ДЕНИСЕНКО) | Function: officer of GRU Unit 29155DOB: 14.5.1997POB: Russian FederationNationality: RussianGender: male | Denis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Denisenko took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Denis Denisenko is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. | 15.12.2025 | 56. | Dmitry Iurevich GOLOSHUBOV(Russian: Дмитрий Юрьевич ГОЛОШУБОВ) | Function: officer of GRU Unit 29155DOB: 10.10.1998POB: Russian FederationNationality: RussianGender: male | Dmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Goloshubov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Unionand members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Dmitry Goloshubov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. | 15.12.2025 | 57. | Jacques BAUD | Function: former colonel in the Swiss army; former strategic analyst, intelligence and terrorism specialistDOB: 1.4.1955Nationality: SwissGender: male | Jacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest on pro-Russian television and radio programmes. He acts as a mouthpiece for pro-Russian propaganda and makes conspiracy theories, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Jacques Baud is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. | 15.12.2025 | 58. | Xavier MOREAU | Function: former military officer and Franco-Russian businessman; founder of the Stratpol websiteDOB: 25.10.1971Nationality: FrenchGender: male | Xavier Moreau is a businessman and founder of the Stratpol website, and a former military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Xavier Moreau is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. | 15.12.2025 | 59. | Diana Vitaliivna PANCHENKO (Ukrainian: Діана Віталіївна ПАНЧЕНКО)(Russian: Диана Витальевна ПАНЧЕНКО) | DOB: 21.5.1988POB: Mykolaïv, Ukrainian SSR (now Ukraine)Nationality: Ukrainian, RussianGender: female | Diana Panchenko is a Ukrainian-born journalist and propagandist. She produces and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.In her videos, she deliberately mimics news-broadcast formats, in order to legitimise the Kremlin’s narratives. She manipulates information to portray Ukrainian authorities as “Nazis” and accuses them of betraying their own people, while justifying Russia’s military aggression and crimes.She has produced work in occupied Ukrainian regions (including in Mariupol and Donetsk) which has been described as propaganda justifying war crimes by the Ukrainian Security Service (SBU). Her content was broadcasted on Ukrainian televisions during a Russian cyber attack that disrupted television programming.Panchenko also amplifies conspiratorial and anti-Ukrainian rhetoric on her Telegram channel (402k subscribers) and on X (148k followers). On her X account, she tries to increase her English-speaking audience by using clickbait content and inauthentic activity and by promoting pro-Russian accounts.Therefore, Diana Panchenko is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. | 15.12.2025’
| Name | Identifying information | Statement of Reasons | Date of listing
‘48. | John Mark DOUGAN | Function: former Florida deputy sheriffDOB: 15.12.1976POB: Wilmington, Delaware, United States of AmericaNationality: American, RussianGender: male | John Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is publicly accused of participating in pro-Kremlin digital information operations from Moscow by operating the CopyCop network of fake news websites and supporting Storm-1516 activities. The inauthentic websites mimic legitimate media outlets and spread fabricated stories and AI-generated deepfake content. Reports from Western authorities and independent investigative sources link Dougan’s activities to Russia’s military intelligence agency (GRU) and the Moscow-based think tank the Center for Geopolitical Expertise, suggesting he receives Russian support and direction to influence elections, discredit political figures and manipulate public discourse in Western countries.Therefore, John Dougan is responsible for, implementing, supporting or benefitting from actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union and in third countries by planning, directing, engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025
49. | Andrey Andreievich SUSHENTSOV(Russian: Андрей Андреевич СУШЕНЦОВ) | Function: Director of the Institute for International Studies (IIS), Moscow State Institute of International Relations (MGIMO University) – a diplomatic academy under the Ministry of Foreign Affairs of the Russian Federation; Programme Director of the Valdai Discussion Club; member of the Council on Foreign and Defence Policy (SVOP); frequent commentator for Russian state media and author for Russia in Global Affairs and other Kremlin-aligned outletsDOB: 8.6.1983POB: Orenburg, USSR (now Russian Federation)Nationality: RussianGender: maleINN: 400407010797 | Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating within the state-academic and think-tank system. His institute (IIS MGIMO) is directly subordinated to the Russian Ministry of Foreign Affairs and closely integrated with official diplomatic and strategic planning structures. Sushentsov regularly appears in Russian and international media, presenting Russia’s foreign-policy worldview in line with Kremlin messaging. His commentary consistently promotes the following narratives: the West provoked the conflict in Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are defensive and aimed at restoring “strategic balance” in the international system; the “unipolar world order” led by the US is collapsing, and Russia, together with China and the “Global South”, is constructing a fairer multipolar world; and Western sanctions are illegitimate and self-destructive, used as tools of coercion against sovereign states. He frequently represents the Russian perspective at Valdai panels attended by President Vladimir Putin and senior officials, serving as both an organiser and a spokesperson for Kremlin-approved messaging.Therefore, Andrey Sushentsov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025
50. | Dmitry Vyacheslavovich SUSLOV(Russian: Дмитрий Вячеславович СУСЛОВ) | Function: Deputy Director, Centre for Comprehensive European and International Studies (CCEIS), Higher School of Economics (HSE University), Moscow; Deputy Director for Research Programmes at the Council on Foreign and Defence Policy (SVOP); expert and frequent speaker at the Valdai Discussion Club; contributor to Russia in Global Affairs and other Kremlin-aligned publicationsDOB: 15.2.1979POB: Leningrad, USSR (now Saint Petersburg, Russian Federation)Nationality: RussianGender: male | Dmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE University, the Council on Foreign and Defence Policy, and the Valdai Discussion Club, he regularly participates in high-level discussions shaping and disseminating Russia’s foreign-policy narratives. He frequently appears as an “independent expert” in Russian state and international media, where he advances positions consistent with official Kremlin lines: portraying NATO and the United States as responsible for provoking the war in Ukraine, framing Western military support to Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian coercive actions as defensive or inevitable responses to Western aggression.In 2024, Suslov publicly suggested that Russia should consider a “demonstrative nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement widely reported by Reuters and other outlets. Such remarks normalise the idea of nuclear signalling and coercion, directly contributing to the climate of intimidation surrounding Russia’s war policy.Therefore, Dmitry Suslov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States, in an international organisation or in a third country, or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating or otherwise facilitating a violent conflict in a third country. | 15.12.2025
51. | Fyodor Aleksandrovich LUKYANOV(Russian: Фёдор Александрович ЛУКЬЯНОВ) | Function: journalist, TV presenter and political scientist; Editor-in-Chief of Russia in Global Affairs; Research Director of the Valdai Discussion Club; member of the Russian International Affairs Council (RIAC)DOB: 1.2.1967POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male | Fyodor Lukyanov is a prominent Russian political analyst, foreign-policy commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential foreign-policy journals, and serves as Research Director of the Valdai Discussion Club, a platform strongly linked to the Russian leadership and frequently used to promote official narratives. He is also a member of the Russian International Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin at Valdai forums.Through his writing, interviews and public appearances, Lukyanov consistently amplifies Kremlin propaganda, portraying Russia’s war of aggression against Ukraine as a defensive reaction to Western policies. He repeatedly blames the Union, NATO and the United States for “provoking” the conflict, describes Ukraine as a Western proxy rather than a sovereign state, and justifies Russian military actions as “necessary” to stop NATO expansion. His arguments are frequently cited in pro-Kremlin media and shape the intellectual framework used to legitimise Russia’s aggression.He is a key opinion leader providing ideological cover for Russian aggression. His work at Valdai and Russia in Global Affairs directly supports Kremlin foreign-policy narratives abroad. He contributes to systematic disinformation campaigns that shift blame for the war onto Ukraine and the West.Therefore, Fyodor Lukyanov is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference or by instigating a violent conflict in a third country. | 15.12.2025
52. | Ivan Nikolaevich TIMOFEEV | Function: political scientist, foreign-policy analyst and policy strategist; Director-General of the Russian International Affairs Council (RIAC); Programme Director of the Valdai Discussion ClubDOB: 1983POB: USSR (now Russian Federation)Nationality: RussianGender: male | Ivan Timofeev is a prominent Russian political scientist and foreign-policy analyst closely associated with Kremlin-aligned institutions. He serves as the Director-General of the Russian International Affairs Council (RIAC) – an organisation established by the Russian Foreign Ministry – and as a Programme Director of the Valdai Discussion Club, a high-profile platform used by the Russian leadership, including President Vladimir Putin, to promote official state narratives to domestic and international audiences. Timofeev is also a frequent contributor to Russia in Global Affairs and a commentator for state media such as TASS and Izvestia.Through his writing, interviews and appearances at Valdai forums, Timofeev consistently amplifies Kremlin propaganda. He portrays Russia’s invasion of Ukraine as a defensive response to Western provocation, describes Ukraine as a Western “proxy,” and blames the United States and NATO for escalating the conflict. His analyses routinely legitimise Russian military aggression and normalise confrontation with the West, while discrediting Western sanctions and portraying them as acts of hostility.Therefore, Ivan Timofeev is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in a third country (Ukraine), or which undermine or threaten the sovereignty or independence of a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025
53. | Andrey Georgievich BYSTRITSKYI(Russian: Андрей Георгиевич БЫСТРИЦКИЙ) | Function: journalist, media manager, academic and think-tank executive; Chairman of the Board of the Valdai Discussion Club FoundationDOB: 21.7.1960POB: Moscow, USSR (now Russian Federation)Nationality: RussianGender: male | Andrei Bystritskyi’s leadership in Valdai and his media/academic background suggest he actively supports and disseminates the official Russian narrative regarding international relations, media control and Russia’s role in global affairs. The Valdai Club is used as a tool of Russian public diplomacy and soft power; by managing this body, Bystritskyi contributes to the infrastructure of state narrative production and dissemination. As dean of a major university faculty (communications/media) and a seasoned media-manager, he is in a position to shape curricula, research and public discourse around media, communications and state narratives – which can facilitate coordinated information or interference campaigns. His quotes and speeches reflect and promote Russian diplomatic narratives – such as those about a multipolar world or the Global South cooperating with Russia, which align with Kremlin strategic messaging.Therefore, Andrei Bystritskyi is responsible for or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten democracy, the rule of law, stability or security in the Union or in several of its Member States or in a third country (Ukraine) by supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025
54. | Vladislav Yevgenevich BOROVKOV(Russian: Владислав Евгеньевич БОРОВКОВ) | Function: officer (Senior Lieutenant) of GRU Unit 29155DOB: 7.10.1997POB: Russian FederationNationality: RussianGender: male | Vladislav Borovkov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Borovkov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Vladislav Borovkov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and Ukraine by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. | 15.12.2025
55. | Denis Igorevich DENISENKO(Russian: Денис Игоревич ДЕНИСЕНКО) | Function: officer of GRU Unit 29155DOB: 14.5.1997POB: Russian FederationNationality: RussianGender: male | Denis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Denisenko took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Union and members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Denis Denisenko is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. | 15.12.2025
56. | Dmitry Iurevich GOLOSHUBOV(Russian: Дмитрий Юрьевич ГОЛОШУБОВ) | Function: officer of GRU Unit 29155DOB: 10.10.1998POB: Russian FederationNationality: RussianGender: male | Dmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert with other Cadet Blizzard members. Furthermore, between December 2020 and August 2024, Goloshubov took part in cyber attacks against government organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the compromised systems, causing significant damage to Ukraine’s systems. Furthermore the group also targeted Member States of the Unionand members of NATO with the aim of gaining sensitive information and destabilising their political situation.Therefore, Dmitry Goloshubov is responsible for or implementing actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Union, several of its Member States, NATO and a third country (Ukraine) by engaging in actions targeted at the functioning of services of public interest or aimed at damaging or destroying their critical infrastructure through malicious cyber activities. He is also a person associated with the entity GRU Unit 29155. | 15.12.2025
57. | Jacques BAUD | Function: former colonel in the Swiss army; former strategic analyst, intelligence and terrorism specialistDOB: 1.4.1955Nationality: SwissGender: male | Jacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest on pro-Russian television and radio programmes. He acts as a mouthpiece for pro-Russian propaganda and makes conspiracy theories, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Jacques Baud is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. | 15.12.2025
58. | Xavier MOREAU | Function: former military officer and Franco-Russian businessman; founder of the Stratpol websiteDOB: 25.10.1971Nationality: FrenchGender: male | Xavier Moreau is a businessman and founder of the Stratpol website, and a former military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for example accusing Ukraine of orchestrating its own invasion in order to join NATO.Therefore, Xavier Moreau is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. | 15.12.2025
59. | Diana Vitaliivna PANCHENKO (Ukrainian: Діана Віталіївна ПАНЧЕНКО)(Russian: Диана Витальевна ПАНЧЕНКО) | DOB: 21.5.1988POB: Mykolaïv, Ukrainian SSR (now Ukraine)Nationality: Ukrainian, RussianGender: female | Diana Panchenko is a Ukrainian-born journalist and propagandist. She produces and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.In her videos, she deliberately mimics news-broadcast formats, in order to legitimise the Kremlin’s narratives. She manipulates information to portray Ukrainian authorities as “Nazis” and accuses them of betraying their own people, while justifying Russia’s military aggression and crimes.She has produced work in occupied Ukrainian regions (including in Mariupol and Donetsk) which has been described as propaganda justifying war crimes by the Ukrainian Security Service (SBU). Her content was broadcasted on Ukrainian televisions during a Russian cyber attack that disrupted television programming.Panchenko also amplifies conspiratorial and anti-Ukrainian rhetoric on her Telegram channel (402k subscribers) and on X (148k followers). On her X account, she tries to increase her English-speaking audience by using clickbait content and inauthentic activity and by promoting pro-Russian accounts.Therefore, Diana Panchenko is responsible for, implementing or supporting actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in a third country (Ukraine) by engaging in the use of information manipulation and interference. | 15.12.2025’
(2) | the following entries are added under the heading ‘B. Legal persons, entities and bodies’:NameIdentifying informationStatement of ReasonsDate of listing‘16.142nd Separate Electronic Warfare Battalion142-й батальон радиоэлектронной борьбы142-й батальон РЭБ142-й отдельный батальон радиоэлектронной борьбы236000, Posyolok Kumachevo, Kaliningrad region, Russian FederationThe 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is part of electronic warfare and plays an important role in ensuring the security and defence of the region. The battalion is responsible for using technology to disorganise any system of shortwave communication, conducting electronic warfare exercises to disrupt enemy navigation and radio communications as well as for the collection and analysis of intelligence information obtained by observing electromagnetic radiation in the short and ultrashort wave ranges.Recently, several European countries have experienced GPS signal failures, which have been attributed to electronic warfare activities by Russia, specifically from Kaliningrad. This includes deliberate jamming and “spoofing” of GPS signals, primarily affecting the Baltic States. Interference and manipulation of GPS signals has led to obstacles for landing civil planes.The 142nd Separate Electronic Warfare Battalion in Kaliningrad has received jamming equipment and conducted exercises using advanced systems capable of disrupting communications over large areas.Therefore, the 142nd Separate Electronic Warfare Battalion, as part of Russia’s military forces enabling the (mis)use of the radio frequency sector, is responsible for actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Member States of the Union by engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference or actions aimed at interfering with, damaging or destroying critical infrastructure through malicious cyber activities as part of hybrid activities.15.12.202517.International Russophile Movement(Russian: Международное движение русофилов)(French: Mouvement International Russophile)The International Russophile Movement is a movement responsible for amplifying destabilising narratives globally, on behalf of the Government of the Russian Federation. The movement has strong ties with the Russian Ministry of Foreign Affairs, receiving endorsements for their work. Russian foreign minister Sergey Lavrov has given keynote speeches in congress meetings of the movement. The movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin and media oligarch Konstantin Malofeev. The Government of the Russian Federation uses the movement as a cover for manipulating the public opinion of other countries, promoting anti-Western sentiment and echoing other Kremlin speaking points.Therefore, the International Russophile Movement is supporting or implementing actions attributable to the Government of the Russian Federation which undermine or threaten stability or security in the Union or in a third country (Ukraine) by engaging in, supporting or otherwise facilitating the use of information manipulation and interference.15.12.2025’ | | Name | Identifying information | Statement of Reasons | Date of listing | ‘16. | 142nd Separate Electronic Warfare Battalion142-й батальон радиоэлектронной борьбы142-й батальон РЭБ142-й отдельный батальон радиоэлектронной борьбы | 236000, Posyolok Kumachevo, Kaliningrad region, Russian Federation | The 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is part of electronic warfare and plays an important role in ensuring the security and defence of the region. The battalion is responsible for using technology to disorganise any system of shortwave communication, conducting electronic warfare exercises to disrupt enemy navigation and radio communications as well as for the collection and analysis of intelligence information obtained by observing electromagnetic radiation in the short and ultrashort wave ranges.Recently, several European countries have experienced GPS signal failures, which have been attributed to electronic warfare activities by Russia, specifically from Kaliningrad. This includes deliberate jamming and “spoofing” of GPS signals, primarily affecting the Baltic States. Interference and manipulation of GPS signals has led to obstacles for landing civil planes.The 142nd Separate Electronic Warfare Battalion in Kaliningrad has received jamming equipment and conducted exercises using advanced systems capable of disrupting communications over large areas.Therefore, the 142nd Separate Electronic Warfare Battalion, as part of Russia’s military forces enabling the (mis)use of the radio frequency sector, is responsible for actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Member States of the Union by engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference or actions aimed at interfering with, damaging or destroying critical infrastructure through malicious cyber activities as part of hybrid activities. | 15.12.2025 | 17. | International Russophile Movement(Russian: Международное движение русофилов)(French: Mouvement International Russophile) | | The International Russophile Movement is a movement responsible for amplifying destabilising narratives globally, on behalf of the Government of the Russian Federation. The movement has strong ties with the Russian Ministry of Foreign Affairs, receiving endorsements for their work. Russian foreign minister Sergey Lavrov has given keynote speeches in congress meetings of the movement. The movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin and media oligarch Konstantin Malofeev. The Government of the Russian Federation uses the movement as a cover for manipulating the public opinion of other countries, promoting anti-Western sentiment and echoing other Kremlin speaking points.Therefore, the International Russophile Movement is supporting or implementing actions attributable to the Government of the Russian Federation which undermine or threaten stability or security in the Union or in a third country (Ukraine) by engaging in, supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025’
| Name | Identifying information | Statement of Reasons | Date of listing
‘16. | 142nd Separate Electronic Warfare Battalion142-й батальон радиоэлектронной борьбы142-й батальон РЭБ142-й отдельный батальон радиоэлектронной борьбы | 236000, Posyolok Kumachevo, Kaliningrad region, Russian Federation | The 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is part of electronic warfare and plays an important role in ensuring the security and defence of the region. The battalion is responsible for using technology to disorganise any system of shortwave communication, conducting electronic warfare exercises to disrupt enemy navigation and radio communications as well as for the collection and analysis of intelligence information obtained by observing electromagnetic radiation in the short and ultrashort wave ranges.Recently, several European countries have experienced GPS signal failures, which have been attributed to electronic warfare activities by Russia, specifically from Kaliningrad. This includes deliberate jamming and “spoofing” of GPS signals, primarily affecting the Baltic States. Interference and manipulation of GPS signals has led to obstacles for landing civil planes.The 142nd Separate Electronic Warfare Battalion in Kaliningrad has received jamming equipment and conducted exercises using advanced systems capable of disrupting communications over large areas.Therefore, the 142nd Separate Electronic Warfare Battalion, as part of Russia’s military forces enabling the (mis)use of the radio frequency sector, is responsible for actions or policies attributable to the Government of the Russian Federation which undermine or threaten stability or security in, or the sovereignty of, the Member States of the Union by engaging in, directly or indirectly, supporting or otherwise facilitating the use of information manipulation and interference or actions aimed at interfering with, damaging or destroying critical infrastructure through malicious cyber activities as part of hybrid activities. | 15.12.2025
17. | International Russophile Movement(Russian: Международное движение русофилов)(French: Mouvement International Russophile) | | The International Russophile Movement is a movement responsible for amplifying destabilising narratives globally, on behalf of the Government of the Russian Federation. The movement has strong ties with the Russian Ministry of Foreign Affairs, receiving endorsements for their work. Russian foreign minister Sergey Lavrov has given keynote speeches in congress meetings of the movement. The movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin and media oligarch Konstantin Malofeev. The Government of the Russian Federation uses the movement as a cover for manipulating the public opinion of other countries, promoting anti-Western sentiment and echoing other Kremlin speaking points.Therefore, the International Russophile Movement is supporting or implementing actions attributable to the Government of the Russian Federation which undermine or threaten stability or security in the Union or in a third country (Ukraine) by engaging in, supporting or otherwise facilitating the use of information manipulation and interference. | 15.12.2025’

Council Decision (CFSP) 2025/2561 of 15 December 2025 amending Decision (CFSP) 2022/2319 concerning restrictive measures in view of the situation in Haiti

Official Journalof the European Union ENL series
2025/2561 15.12.2025
(1) On 25 November 2022, the Council adopted Decision (CFSP) 2022/2319(1).
(2) On 28 July 2023, the Council adopted Decision (CFSP) 2023/1574(2), which amended Decision (CFSP) 2022/2319, thereby establishing a dedicated framework for targeted restrictive measures against natural or legal persons, entities or bodies responsible for actions that threaten the peace, stability and security of Haiti and for actions that undermine democracy or the rule of law in Haiti, as well as against natural or legal persons, entities or bodies associated with them.
(3) In its conclusions of 17 October 2024, the European Council stated that it remained extremely concerned about the situation in Haiti and called for new targeted sanctions against individuals and entities responsible for violence, with the objective of helping to restore peace, security, stability, democracy and the rule of law in Haiti.
(4) In view of the deteriorating political, economic, security and humanitarian situation in Haiti, including the results of the escalating gang violence, the unremitting serious human rights abuses committed by gangs, and the continuing impunity for the perpetrators, three individuals and one entity should be added to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex II to Decision (CFSP) 2022/2319.
(5) Decision (CFSP) 2022/2319 should therefore be amended accordingly,
(1) under the heading ‘A. List of natural persons referred to in Article 2a(1) and in Article 3a(1)’, the following entries are added:NameIdentifying informationStatement of reasonsDate of listing‘7.Michel Joseph MARTELLYa.k.a. Sweet MickyFunction: former President of Haiti (2011-2016); former President of the CARICOM (January 2023-July 2023)Michel Martelly, the former President of the Republic of Haiti (2011-2016), participated directly in the creation of the gang Base 257. He financed, sponsored and supported several gangs, in particular Base 257, but also Village de Dieu, Ti Bois and Grand Ravine, to defend his economic interests, advance his political agenda and control territories, notably by providing them with firearms and guns. By financing those groups, he is also responsible for the abuses they have committed and has therefore contributed financially to insecurity and instability in Haiti.Therefore, Michel Martelly is responsible for actions that threaten the peace, stability and security of Haiti.15.12.20258.Youri LATORTUEFunction: former advisor to the President Michel Martelly (2011-2016); former President of the Senate (2017-2018); former senator of the Artibonite department; coordinator of the party “L’Ayiti an Aksyon” (AAA), previously known as “L’Artibonite en Action” (LAAA)Youri Latortue is the founder of the political party “L’Ayiti an Aksyon” (AAA), a former senator of the Artibonite department, and a former advisor to the President Michel Martelly during his presidency (2011-2016). He also served as president of the Senate from 13 January 2017 to 9 January 2018.Youri Latortue has armed and financed the “Raboteau” and “Kokorat San Ras” gangs, to promote his political agenda and defend his personal and economic interests, notably in the Artibonite department. Those gangs are still active today, engaging in kidnapping and racketeering, among other activities.Therefore, Youri Latortue is indirectly responsible for actions that threaten the peace, stability and security of Haiti.15.12.20259.Rony CELESTINa.k.a. Rony APPOLONFunction: former deputy (2011-2017); former senator (2017-2023)Rony Celestin, a former senator of Haiti, is involved in violence linked to armed groups and smuggling. He has notably been held responsible for orchestrating the murder of the journalist Néhémie Joseph, who exposed his illegal activities and corruption.Therefore, Rony Celestin is indirectly responsible for actions that threaten the peace, stability and security of Haiti.15.12.2025’ Name Identifying information Statement of reasons Date of listing ‘7. Michel Joseph MARTELLYa.k.a. Sweet Micky Function: former President of Haiti (2011-2016); former President of the CARICOM (January 2023-July 2023) Michel Martelly, the former President of the Republic of Haiti (2011-2016), participated directly in the creation of the gang Base 257. He financed, sponsored and supported several gangs, in particular Base 257, but also Village de Dieu, Ti Bois and Grand Ravine, to defend his economic interests, advance his political agenda and control territories, notably by providing them with firearms and guns. By financing those groups, he is also responsible for the abuses they have committed and has therefore contributed financially to insecurity and instability in Haiti.Therefore, Michel Martelly is responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025 8. Youri LATORTUE Function: former advisor to the President Michel Martelly (2011-2016); former President of the Senate (2017-2018); former senator of the Artibonite department; coordinator of the party “L’Ayiti an Aksyon” (AAA), previously known as “L’Artibonite en Action” (LAAA) Youri Latortue is the founder of the political party “L’Ayiti an Aksyon” (AAA), a former senator of the Artibonite department, and a former advisor to the President Michel Martelly during his presidency (2011-2016). He also served as president of the Senate from 13 January 2017 to 9 January 2018.Youri Latortue has armed and financed the “Raboteau” and “Kokorat San Ras” gangs, to promote his political agenda and defend his personal and economic interests, notably in the Artibonite department. Those gangs are still active today, engaging in kidnapping and racketeering, among other activities.Therefore, Youri Latortue is indirectly responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025 9. Rony CELESTINa.k.a. Rony APPOLON Function: former deputy (2011-2017); former senator (2017-2023) Rony Celestin, a former senator of Haiti, is involved in violence linked to armed groups and smuggling. He has notably been held responsible for orchestrating the murder of the journalist Néhémie Joseph, who exposed his illegal activities and corruption.Therefore, Rony Celestin is indirectly responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025’
Name Identifying information Statement of reasons Date of listing
‘7. Michel Joseph MARTELLYa.k.a. Sweet Micky Function: former President of Haiti (2011-2016); former President of the CARICOM (January 2023-July 2023) Michel Martelly, the former President of the Republic of Haiti (2011-2016), participated directly in the creation of the gang Base 257. He financed, sponsored and supported several gangs, in particular Base 257, but also Village de Dieu, Ti Bois and Grand Ravine, to defend his economic interests, advance his political agenda and control territories, notably by providing them with firearms and guns. By financing those groups, he is also responsible for the abuses they have committed and has therefore contributed financially to insecurity and instability in Haiti.Therefore, Michel Martelly is responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025
8. Youri LATORTUE Function: former advisor to the President Michel Martelly (2011-2016); former President of the Senate (2017-2018); former senator of the Artibonite department; coordinator of the party “L’Ayiti an Aksyon” (AAA), previously known as “L’Artibonite en Action” (LAAA) Youri Latortue is the founder of the political party “L’Ayiti an Aksyon” (AAA), a former senator of the Artibonite department, and a former advisor to the President Michel Martelly during his presidency (2011-2016). He also served as president of the Senate from 13 January 2017 to 9 January 2018.Youri Latortue has armed and financed the “Raboteau” and “Kokorat San Ras” gangs, to promote his political agenda and defend his personal and economic interests, notably in the Artibonite department. Those gangs are still active today, engaging in kidnapping and racketeering, among other activities.Therefore, Youri Latortue is indirectly responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025
9. Rony CELESTINa.k.a. Rony APPOLON Function: former deputy (2011-2017); former senator (2017-2023) Rony Celestin, a former senator of Haiti, is involved in violence linked to armed groups and smuggling. He has notably been held responsible for orchestrating the murder of the journalist Néhémie Joseph, who exposed his illegal activities and corruption.Therefore, Rony Celestin is indirectly responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025’
Name Identifying information Statement of reasons Date of listing
‘7. Michel Joseph MARTELLYa.k.a. Sweet Micky Function: former President of Haiti (2011-2016); former President of the CARICOM (January 2023-July 2023) Michel Martelly, the former President of the Republic of Haiti (2011-2016), participated directly in the creation of the gang Base 257. He financed, sponsored and supported several gangs, in particular Base 257, but also Village de Dieu, Ti Bois and Grand Ravine, to defend his economic interests, advance his political agenda and control territories, notably by providing them with firearms and guns. By financing those groups, he is also responsible for the abuses they have committed and has therefore contributed financially to insecurity and instability in Haiti.Therefore, Michel Martelly is responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025
8. Youri LATORTUE Function: former advisor to the President Michel Martelly (2011-2016); former President of the Senate (2017-2018); former senator of the Artibonite department; coordinator of the party “L’Ayiti an Aksyon” (AAA), previously known as “L’Artibonite en Action” (LAAA) Youri Latortue is the founder of the political party “L’Ayiti an Aksyon” (AAA), a former senator of the Artibonite department, and a former advisor to the President Michel Martelly during his presidency (2011-2016). He also served as president of the Senate from 13 January 2017 to 9 January 2018.Youri Latortue has armed and financed the “Raboteau” and “Kokorat San Ras” gangs, to promote his political agenda and defend his personal and economic interests, notably in the Artibonite department. Those gangs are still active today, engaging in kidnapping and racketeering, among other activities.Therefore, Youri Latortue is indirectly responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025
9. Rony CELESTINa.k.a. Rony APPOLON Function: former deputy (2011-2017); former senator (2017-2023) Rony Celestin, a former senator of Haiti, is involved in violence linked to armed groups and smuggling. He has notably been held responsible for orchestrating the murder of the journalist Néhémie Joseph, who exposed his illegal activities and corruption.Therefore, Rony Celestin is indirectly responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025’
(2) under the heading ‘B. List of legal persons, entities and bodies referred to in Article 3a(1)’, the following table and entry are added:NameIdentifying informationStatement of reasonsDate of listing‘1.5 Segond gangHaitian gang based in the “Village de Dieu” neighbourhood in Port-au-PrinceThe 5 Segond gang is a powerful gang in Haiti, based in the Village de Dieu neighbourhood in Port-au-Prince. Its leader is Johnson André, a.k.a “Izo”. The 5 Segond gang was officially part of the G-Pèp gang alliance. In 2024, G-Pèp and its former rivals, G9 Family and Allies, formed a new coalition, Viv Ansanm, a.k.a. Living Together. Together, they increased attacks against state institutions and contributed to instability. The 5 Segond gang also commits theft, rape, kidnapping, murder, piracy, and extortion, obstructs humanitarian aid and engages in arms and drugs trafficking.Therefore, the 5 Segond gang is responsible for actions that threaten the peace, stability and security of Haiti.15.12.2025’ Name Identifying information Statement of reasons Date of listing ‘1. 5 Segond gang Haitian gang based in the “Village de Dieu” neighbourhood in Port-au-Prince The 5 Segond gang is a powerful gang in Haiti, based in the Village de Dieu neighbourhood in Port-au-Prince. Its leader is Johnson André, a.k.a “Izo”. The 5 Segond gang was officially part of the G-Pèp gang alliance. In 2024, G-Pèp and its former rivals, G9 Family and Allies, formed a new coalition, Viv Ansanm, a.k.a. Living Together. Together, they increased attacks against state institutions and contributed to instability. The 5 Segond gang also commits theft, rape, kidnapping, murder, piracy, and extortion, obstructs humanitarian aid and engages in arms and drugs trafficking.Therefore, the 5 Segond gang is responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025’
Name Identifying information Statement of reasons Date of listing
‘1. 5 Segond gang Haitian gang based in the “Village de Dieu” neighbourhood in Port-au-Prince The 5 Segond gang is a powerful gang in Haiti, based in the Village de Dieu neighbourhood in Port-au-Prince. Its leader is Johnson André, a.k.a “Izo”. The 5 Segond gang was officially part of the G-Pèp gang alliance. In 2024, G-Pèp and its former rivals, G9 Family and Allies, formed a new coalition, Viv Ansanm, a.k.a. Living Together. Together, they increased attacks against state institutions and contributed to instability. The 5 Segond gang also commits theft, rape, kidnapping, murder, piracy, and extortion, obstructs humanitarian aid and engages in arms and drugs trafficking.Therefore, the 5 Segond gang is responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025’
Name Identifying information Statement of reasons Date of listing
‘1. 5 Segond gang Haitian gang based in the “Village de Dieu” neighbourhood in Port-au-Prince The 5 Segond gang is a powerful gang in Haiti, based in the Village de Dieu neighbourhood in Port-au-Prince. Its leader is Johnson André, a.k.a “Izo”. The 5 Segond gang was officially part of the G-Pèp gang alliance. In 2024, G-Pèp and its former rivals, G9 Family and Allies, formed a new coalition, Viv Ansanm, a.k.a. Living Together. Together, they increased attacks against state institutions and contributed to instability. The 5 Segond gang also commits theft, rape, kidnapping, murder, piracy, and extortion, obstructs humanitarian aid and engages in arms and drugs trafficking.Therefore, the 5 Segond gang is responsible for actions that threaten the peace, stability and security of Haiti. 15.12.2025’
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 25 November 2022, the Council adopted Decision (CFSP) 2022/2319(1).
(2) On 28 July 2023, the Council adopted Decision (CFSP) 2023/1574(2), which amended Decision (CFSP) 2022/2319, thereby establishing a dedicated framework for targeted restrictive measures against natural or legal persons, entities or bodies responsible for actions that threaten the peace, stability and security of Haiti and for actions that undermine democracy or the rule of law in Haiti, as well as against natural or legal persons, entities or bodies associated with them.
(3) In its conclusions of 17 October 2024, the European Council stated that it remained extremely concerned about the situation in Haiti and called for new targeted sanctions against individuals and entities responsible for violence, with the objective of helping to restore peace, security, stability, democracy and the rule of law in Haiti.
(4) In view of the deteriorating political, economic, security and humanitarian situation in Haiti, including the results of the escalating gang violence, the unremitting serious human rights abuses committed by gangs, and the continuing impunity for the perpetrators, three individuals and one entity should be added to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex II to Decision (CFSP) 2022/2319.
(5) Decision (CFSP) 2022/2319 should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:

Article 1
Annex II to Decision (CFSP) 2022/2319 is amended in accordance with the Annex to this Decision.

Article 2
This Decision shall enter into force on the date of its publication in theOfficial Journal of the European Union.

THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 25 November 2022, the Council adopted Decision (CFSP) 2022/2319(1).
(2) On 28 July 2023, the Council adopted Decision (CFSP) 2023/1574(2), which amended Decision (CFSP) 2022/2319, thereby establishing a dedicated framework for targeted restrictive measures against natural or legal persons, entities or bodies responsible for actions that threaten the peace, stability and security of Haiti and for actions that undermine democracy or the rule of law in Haiti, as well as against natural or legal persons, entities or bodies associated with them.
(3) In its conclusions of 17 October 2024, the European Council stated that it remained extremely concerned about the situation in Haiti and called for new targeted sanctions against individuals and entities responsible for violence, with the objective of helping to restore peace, security, stability, democracy and the rule of law in Haiti.
(4) In view of the deteriorating political, economic, security and humanitarian situation in Haiti, including the results of the escalating gang violence, the unremitting serious human rights abuses committed by gangs, and the continuing impunity for the perpetrators, three individuals and one entity should be added to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex II to Decision (CFSP) 2022/2319.
(5) Decision (CFSP) 2022/2319 should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:
Annex II to Decision (CFSP) 2022/2319 is amended in accordance with the Annex to this Decision.
This Decision shall enter into force on the date of its publication in theOfficial Journal of the European Union.
ANNEXAnnex II to Decision (CFSP) 2022/2319 is amended as follows:

(1) | under the heading ‘A. List of natural persons referred to in Article 2a(1) and in Article 3a(1)’, the following entries are added:NameIdentifying informationStatement of reasonsDate of listing‘7.Michel Joseph MARTELLYa.k.a. Sweet MickyFunction: former President of Haiti (2011-2016); former President of the CARICOM (January 2023-July 2023)Michel Martelly, the former President of the Republic of Haiti (2011-2016), participated directly in the creation of the gang Base 257. He financed, sponsored and supported several gangs, in particular Base 257, but also Village de Dieu, Ti Bois and Grand Ravine, to defend his economic interests, advance his political agenda and control territories, notably by providing them with firearms and guns. By financing those groups, he is also responsible for the abuses they have committed and has therefore contributed financially to insecurity and instability in Haiti.Therefore, Michel Martelly is responsible for actions that threaten the peace, stability and security of Haiti.15.12.20258.Youri LATORTUEFunction: former advisor to the President Michel Martelly (2011-2016); former President of the Senate (2017-2018); former senator of the Artibonite department; coordinator of the party “L’Ayiti an Aksyon” (AAA), previously known as “L’Artibonite en Action” (LAAA)Youri Latortue is the founder of the political party “L’Ayiti an Aksyon” (AAA), a former senator of the Artibonite department, and a former advisor to the President Michel Martelly during his presidency (2011-2016). He also served as president of the Senate from 13 January 2017 to 9 January 2018.Youri Latortue has armed and financed the “Raboteau” and “Kokorat San Ras” gangs, to promote his political agenda and defend his personal and economic interests, notably in the Artibonite department. Those gangs are still active today, engaging in kidnapping and racketeering, among other activities.Therefore, Youri Latortue is indirectly responsible for actions that threaten the peace, stability and security of Haiti.15.12.20259.Rony CELESTINa.k.a. Rony APPOLONFunction: former deputy (2011-2017); former senator (2017-2023)Rony Celestin, a former senator of Haiti, is involved in violence linked to armed groups and smuggling. He has notably been held responsible for orchestrating the murder of the journalist Néhémie Joseph, who exposed his illegal activities and corruption.Therefore, Rony Celestin is indirectly responsible for actions that threaten the peace, stability and security of Haiti.15.12.2025’ | | Name | Identifying information | Statement of reasons | Date of listing | ‘7. | Michel Joseph MARTELLYa.k.a. Sweet Micky | Function: former President of Haiti (2011-2016); former President of the CARICOM (January 2023-July 2023) | Michel Martelly, the former President of the Republic of Haiti (2011-2016), participated directly in the creation of the gang Base 257. He financed, sponsored and supported several gangs, in particular Base 257, but also Village de Dieu, Ti Bois and Grand Ravine, to defend his economic interests, advance his political agenda and control territories, notably by providing them with firearms and guns. By financing those groups, he is also responsible for the abuses they have committed and has therefore contributed financially to insecurity and instability in Haiti.Therefore, Michel Martelly is responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025 | 8. | Youri LATORTUE | Function: former advisor to the President Michel Martelly (2011-2016); former President of the Senate (2017-2018); former senator of the Artibonite department; coordinator of the party “L’Ayiti an Aksyon” (AAA), previously known as “L’Artibonite en Action” (LAAA) | Youri Latortue is the founder of the political party “L’Ayiti an Aksyon” (AAA), a former senator of the Artibonite department, and a former advisor to the President Michel Martelly during his presidency (2011-2016). He also served as president of the Senate from 13 January 2017 to 9 January 2018.Youri Latortue has armed and financed the “Raboteau” and “Kokorat San Ras” gangs, to promote his political agenda and defend his personal and economic interests, notably in the Artibonite department. Those gangs are still active today, engaging in kidnapping and racketeering, among other activities.Therefore, Youri Latortue is indirectly responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025 | 9. | Rony CELESTINa.k.a. Rony APPOLON | Function: former deputy (2011-2017); former senator (2017-2023) | Rony Celestin, a former senator of Haiti, is involved in violence linked to armed groups and smuggling. He has notably been held responsible for orchestrating the murder of the journalist Néhémie Joseph, who exposed his illegal activities and corruption.Therefore, Rony Celestin is indirectly responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025’
| Name | Identifying information | Statement of reasons | Date of listing
‘7. | Michel Joseph MARTELLYa.k.a. Sweet Micky | Function: former President of Haiti (2011-2016); former President of the CARICOM (January 2023-July 2023) | Michel Martelly, the former President of the Republic of Haiti (2011-2016), participated directly in the creation of the gang Base 257. He financed, sponsored and supported several gangs, in particular Base 257, but also Village de Dieu, Ti Bois and Grand Ravine, to defend his economic interests, advance his political agenda and control territories, notably by providing them with firearms and guns. By financing those groups, he is also responsible for the abuses they have committed and has therefore contributed financially to insecurity and instability in Haiti.Therefore, Michel Martelly is responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025
8. | Youri LATORTUE | Function: former advisor to the President Michel Martelly (2011-2016); former President of the Senate (2017-2018); former senator of the Artibonite department; coordinator of the party “L’Ayiti an Aksyon” (AAA), previously known as “L’Artibonite en Action” (LAAA) | Youri Latortue is the founder of the political party “L’Ayiti an Aksyon” (AAA), a former senator of the Artibonite department, and a former advisor to the President Michel Martelly during his presidency (2011-2016). He also served as president of the Senate from 13 January 2017 to 9 January 2018.Youri Latortue has armed and financed the “Raboteau” and “Kokorat San Ras” gangs, to promote his political agenda and defend his personal and economic interests, notably in the Artibonite department. Those gangs are still active today, engaging in kidnapping and racketeering, among other activities.Therefore, Youri Latortue is indirectly responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025
9. | Rony CELESTINa.k.a. Rony APPOLON | Function: former deputy (2011-2017); former senator (2017-2023) | Rony Celestin, a former senator of Haiti, is involved in violence linked to armed groups and smuggling. He has notably been held responsible for orchestrating the murder of the journalist Néhémie Joseph, who exposed his illegal activities and corruption.Therefore, Rony Celestin is indirectly responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025’
(2) | under the heading ‘B. List of legal persons, entities and bodies referred to in Article 3a(1)’, the following table and entry are added:NameIdentifying informationStatement of reasonsDate of listing‘1.5 Segond gangHaitian gang based in the “Village de Dieu” neighbourhood in Port-au-PrinceThe 5 Segond gang is a powerful gang in Haiti, based in the Village de Dieu neighbourhood in Port-au-Prince. Its leader is Johnson André, a.k.a “Izo”. The 5 Segond gang was officially part of the G-Pèp gang alliance. In 2024, G-Pèp and its former rivals, G9 Family and Allies, formed a new coalition, Viv Ansanm, a.k.a. Living Together. Together, they increased attacks against state institutions and contributed to instability. The 5 Segond gang also commits theft, rape, kidnapping, murder, piracy, and extortion, obstructs humanitarian aid and engages in arms and drugs trafficking.Therefore, the 5 Segond gang is responsible for actions that threaten the peace, stability and security of Haiti.15.12.2025’ | | Name | Identifying information | Statement of reasons | Date of listing | ‘1. | 5 Segond gang | Haitian gang based in the “Village de Dieu” neighbourhood in Port-au-Prince | The 5 Segond gang is a powerful gang in Haiti, based in the Village de Dieu neighbourhood in Port-au-Prince. Its leader is Johnson André, a.k.a “Izo”. The 5 Segond gang was officially part of the G-Pèp gang alliance. In 2024, G-Pèp and its former rivals, G9 Family and Allies, formed a new coalition, Viv Ansanm, a.k.a. Living Together. Together, they increased attacks against state institutions and contributed to instability. The 5 Segond gang also commits theft, rape, kidnapping, murder, piracy, and extortion, obstructs humanitarian aid and engages in arms and drugs trafficking.Therefore, the 5 Segond gang is responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025’
| Name | Identifying information | Statement of reasons | Date of listing
‘1. | 5 Segond gang | Haitian gang based in the “Village de Dieu” neighbourhood in Port-au-Prince | The 5 Segond gang is a powerful gang in Haiti, based in the Village de Dieu neighbourhood in Port-au-Prince. Its leader is Johnson André, a.k.a “Izo”. The 5 Segond gang was officially part of the G-Pèp gang alliance. In 2024, G-Pèp and its former rivals, G9 Family and Allies, formed a new coalition, Viv Ansanm, a.k.a. Living Together. Together, they increased attacks against state institutions and contributed to instability. The 5 Segond gang also commits theft, rape, kidnapping, murder, piracy, and extortion, obstructs humanitarian aid and engages in arms and drugs trafficking.Therefore, the 5 Segond gang is responsible for actions that threaten the peace, stability and security of Haiti. | 15.12.2025’

Council Decision (CFSP) 2025/2586 of 15 December 2025 amending Decision (CFSP) 2017/2074 concerning restrictive measures in view of the situation in Venezuela

Official Journalof the European Union ENL series
2025/2586 16.12.2025
(1) On 13 November 2017, the Council adopted Decision (CFSP) 2017/2074(1).
(2) Considering the deepening political crisis in Venezuela, as well as the persistent actions undermining democracy and the rule of law, continued human rights violations and the repression of civil society and democratic opposition, including in relation to the conduct of and developments following the presidential elections of 28 July 2024, in that country, and on the basis of a review of Decision (CFSP) 2017/2074, the restrictive measures set out in that Decision should be renewed until 10 January 2027.
(3) Moreover, the entries for four natural persons set out in Annex I to Decision (CFSP) 2017/2074 should be updated.
(4) Decision (CFSP) 2017/2074 should therefore be amended accordingly,
(1) in Article 13, in the first paragraph, the date ‘10 January 2026’ is replaced by that of ‘10 January 2027’;
(2) Annex I is amended in accordance with the Annex to this Decision.
Name Identifying information Reasons Date of listing
‘2. Gustavo Enrique GONZÁLEZ LÓPEZ DOB: 2.11.1960Gender: male President of Petróleos de Venezuela (PDVSA). General Director of the Bolivarian National Intelligence Service (SEBIN) between April 2019 and October 2024. Security and Intelligence Adviser to President Maduro since January 2019, and General Director of SEBIN from February 2014 to October 2018. During the times he has served as SEBIN director, officials under his ultimate authority committed acts of arbitrary detention, torture and cruel and inhuman treatment, including sexual violence, in El Helicoide detention centre. As General Director of SEBIN, he is responsible for serious human rights violations, including arbitrary detention, inhuman and degrading treatment, and torture, and the repression of civil society and the democratic opposition in Venezuela. 22.1.2018
11. Iván HERNÁNDEZ DALA DOB: 18.5.1966Gender: male President of the National Telephone Company of Venezuela (Cantv). Major-General in FANB. Director-General of the Directorate-General for Military Counterintelligence (DGCIM) between January 2014 and October 2024 and Head of the Presidential Guard between September 2015 and October 2024. As Head of the DGCIM, Iván Hernández Dala is responsible for the repression of civil society and democratic opposition and for serious human rights violations committed by members of the DGCIM under his command, including torture, the use of excessive force and the ill-treatment of detainees. 25.6.2018
31. Jorge Elieser MÁRQUEZ MONSALVE DOB: 20.2.1971POB: Caracas, VenezuelaID number: V-8714253Gender: male Minister of Electricity and Vice-President of Public Works and Utilities since 23 April 2024. Former Minister of the Office of the Presidency and Director-General of the National Commission of Telecommunications (CONATEL) since 7 August 2017. His actions have undermined democracy or the rule of law in Venezuela, including by severely limiting the rights of the Venezuelan people to a free press, free speech and information. He used the special powers of CONATEL to silence criticism and dissidents of the regime by blocking, filtering and obstructing internet websites, by revoking existing licences for radio and television stations and by refusing to grant new ones. 29.6.2020
37. Remigio CEBALLOS ICHASO DOB: 1.5.1963ID-number: V-6557495Gender: male Venezuela’s Ambassador to China. Former Minister of the Interior and Justice of Venezuela (August 2021 – August 2024) and Vice-President of the Government for Citizen Security. Former Commander of the Operational and Strategic Command of the Bolivarian National Armed Forces of Venezuela (Comando Estratégico Operacional Fuerzas Armadas Nacionales Bolivarianas (CEOFANB)), the highest organ in the Venezuelan Armed Forces (June 2017 – July 2021). CEOFANB controls the Bolivarian National Armed Forces (FANB) and the Bolivarian National Guard. CEOFANB is also responsible for coordinating FANB interventions in demonstrations. In his position as Commander of CEOFANB, he was responsible for serious human rights violations, including the use of excessive force and inhuman and degrading treatment by officials of the FANB and by subordinate forces under his command, including the Bolivarian National Guard. Various sources, including the Independent International Fact-Finding Mission on the Bolivarian Republic of Venezuela, attribute human rights violations to FANB and the Bolivarian National Guard. 22.2.2021’
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 13 November 2017, the Council adopted Decision (CFSP) 2017/2074(1).
(2) Considering the deepening political crisis in Venezuela, as well as the persistent actions undermining democracy and the rule of law, continued human rights violations and the repression of civil society and democratic opposition, including in relation to the conduct of and developments following the presidential elections of 28 July 2024, in that country, and on the basis of a review of Decision (CFSP) 2017/2074, the restrictive measures set out in that Decision should be renewed until 10 January 2027.
(3) Moreover, the entries for four natural persons set out in Annex I to Decision (CFSP) 2017/2074 should be updated.
(4) Decision (CFSP) 2017/2074 should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:
Decision (CFSP) 2017/2074 is amended as follows:
(1)
in Article 13, in the first paragraph, the date ‘10 January 2026’ is replaced by that of ‘10 January 2027’;
(2)
Annex I is amended in accordance with the Annex to this Decision.
This Decision shall enter into force on the day following that of its publication in theOfficial Journal of the European Union.
ANNEXIn Annex I to Decision (CFSP) 2017/2074, in the list of natural and legal persons, entities and bodies, entries 2, 11, 31 and 37 are replaced by the following:

Name
Identifying information
Reasons
Date of listing
‘2. Gustavo Enrique GONZÁLEZ LÓPEZ
DOB: 2.11.1960
Gender: male
President of Petróleos de Venezuela (PDVSA). General Director of the Bolivarian National Intelligence Service (SEBIN) between April 2019 and October 2024. Security and Intelligence Adviser to President Maduro since January 2019, and General Director of SEBIN from February 2014 to October 2018. During the times he has served as SEBIN director, officials under his ultimate authority committed acts of arbitrary detention, torture and cruel and inhuman treatment, including sexual violence, in El Helicoide detention centre. As General Director of SEBIN, he is responsible for serious human rights violations, including arbitrary detention, inhuman and degrading treatment, and torture, and the repression of civil society and the democratic opposition in Venezuela.
22.1.2018 11. Iván HERNÁNDEZ DALA
DOB: 18.5.1966
Gender: male
President of the National Telephone Company of Venezuela (Cantv). Major-General in FANB. Director-General of the Directorate-General for Military Counterintelligence (DGCIM) between January 2014 and October 2024 and Head of the Presidential Guard between September 2015 and October 2024. As Head of the DGCIM, Iván Hernández Dala is responsible for the repression of civil society and democratic opposition and for serious human rights violations committed by members of the DGCIM under his command, including torture, the use of excessive force and the ill-treatment of detainees.
25.6.2018 31. Jorge Elieser MÁRQUEZ MONSALVE
DOB: 20.2.1971
POB: Caracas, Venezuela
ID number: V-8714253
Gender: male
Minister of Electricity and Vice-President of Public Works and Utilities since 23 April 2024. Former Minister of the Office of the Presidency and Director-General of the National Commission of Telecommunications (CONATEL) since 7 August 2017. His actions have undermined democracy or the rule of law in Venezuela, including by severely limiting the rights of the Venezuelan people to a free press, free speech and information. He used the special powers of CONATEL to silence criticism and dissidents of the regime by blocking, filtering and obstructing internet websites, by revoking existing licences for radio and television stations and by refusing to grant new ones.
29.6.2020 37. Remigio CEBALLOS ICHASO
DOB: 1.5.1963
ID-number: V-6557495
Gender: male
Venezuela’s Ambassador to China. Former Minister of the Interior and Justice of Venezuela (August 2021 – August 2024) and Vice-President of the Government for Citizen Security. Former Commander of the Operational and Strategic Command of the Bolivarian National Armed Forces of Venezuela (Comando Estratégico Operacional Fuerzas Armadas Nacionales Bolivarianas (CEOFANB)), the highest organ in the Venezuelan Armed Forces (June 2017 – July 2021). CEOFANB controls the Bolivarian National Armed Forces (FANB) and the Bolivarian National Guard. CEOFANB is also responsible for coordinating FANB interventions in demonstrations. In his position as Commander of CEOFANB, he was responsible for serious human rights violations, including the use of excessive force and inhuman and degrading treatment by officials of the FANB and by subordinate forces under his command, including the Bolivarian National Guard. Various sources, including the Independent International Fact-Finding Mission on the Bolivarian Republic of Venezuela, attribute human rights violations to FANB and the Bolivarian National Guard.
22.2.2021’

Council Decision (CFSP) 2025/2587 of 15 December 2025 in support of the South-Eastern and Eastern Europe Clearinghouse for the Control of Small Arms and Light Weapons (SEESAC) for the implementation of the Regional Roadmap on combating illicit arms trafficking in the Western Balkans and in support of disarmament and arms control activities in South-East and East Europe

Official Journalof the European Union ENL series
2025/2587 16.12.2025
(1) On 19 November 2018, the Council adopted the EU Strategy against Illicit Firearms, Small Arms & Light Weapons and their Ammunition, entitled ‘Securing Arms, Protecting Citizens’ (the ‘EU SALW Strategy’), which sets the guidelines for Union action in the field of small arms and light weapons (SALW). The EU SALW Strategy states that the Union gives particular prominence to regional cooperation as an efficient means of small arms control. The EU SALW Strategy mentions the Western Balkans as a priority region for support.
(2) On 17 May 2018, at the EU-Western Balkans Summit in Sofia, the leaders of the Union agreed on the Sofia Declaration, to which the Western Balkans partners aligned themselves, and which includes a commitment to enhance significantly operational cooperation in the fight against international organised crime in priority areas such as firearms, drugs, migrant smuggling and trafficking in human beings.
(3) The Western Balkans region remains one of the sources of illicit arms trafficking into the Union.
(4) On 10 July 2018, the United Kingdom of Great Britain and Northern Ireland hosted the 5th Western Balkans Summit in London, which adopted the ‘Regional Roadmap for a sustainable solution to the illegal possession, misuse and trafficking of SALW/firearms and their ammunition in the Western Balkans by 2024’ (the ‘Roadmap’).
(5) The Roadmap has since been updated and extended until 2030.
(6) The United Nations (UN) 2030 Agenda for Sustainable Development, adopted on 25 September 2015, affirmed that sustainable development cannot be realised without peace and security and that illicit arms flows are amongst the factors which give rise to violence, insecurity and injustice.
(7) At the Fourth Review Conference on the implementation of the UN Programme of Action to Prevent, Combat and Eradicate the Illicit Trade in Small Arms and Light Weapons in All Its Aspects, held in June 2024 in New York, UN Member States reaffirmed the importance of reinforcing regional and subregional cooperation, through improved coordination, consultation, information exchange and operational cooperation, as appropriate, with relevant regional and subregional organisations, mechanisms, road maps and other initiatives as well as law enforcement, border control and export and import licensing authorities.
(8) The goals of the Roadmap agreed by the Western Balkans partners are consistent with the efforts within the Union and the UN to combat the illicit accumulation and trafficking of SALW and their ammunition. Therefore, the Union should support the Western Balkans in implementing the Roadmap.
(9) The Union previously supported the implementation of the Roadmap by means of Council Decisions (CFSP) 2018/1788(1)and (CFSP) 2022/2321(2).
(10) The South Eastern and Eastern Europe Clearinghouse for the Control of Small Arms and Light Weapons (SEESAC) was established in Belgrade in 2002 and functions under the joint mandate of the UN Development Programme (UNDP) and the Regional Cooperation Council (RCC). SEESAC is the successor to the Stability Pact for South-Eastern Europe, assists national and regional stakeholders in controlling and reducing the spread and misuse of SALW and ammunition, and thus contributes to enhanced stability, security and development in South-Eastern and Eastern Europe. SEESAC places particular emphasis on the development of regional projects to address the reality of cross-border flows of weapons.
(11) The Union considers SEESAC to be the preferred implementing partner for the implementation of the Roadmap in the Western Balkans, because of its proven experience and established network, the proven quality of its work and its coordinating role in the preparation of the Roadmap.
12. In addition, the Union action should provide support for countering illicit arms trafficking in the Republic of Moldova and in Ukraine, states which are dealing with similar SALW control challenges. It should do so through the transfer of knowledge and experience gained and best practices developed in the Western Balkans since 2001,
— coordinating the regional approach and monitoring of the implementation of the Roadmap,
— strengthening of knowledge exchange and inter-regional cooperation on SALW control,
— strengthening the capacities of law enforcement services in Moldova and Ukraine to counter illegal possession, misuse and trafficking,
— strengthening the capacities of law enforcement and customs services in the Western Balkans for countering illicit trafficking.
— coordinated implementation and monitoring of the implementation of the Roadmap for a sustainable solution to the illegal possession, misuse and trafficking of small arms and light weapons, their ammunition and explosives in the Western Balkans by 2030;
— strengthened interregional cooperation, knowledge management and knowledge sharing on arms control;
— strengthened capacities of law enforcement services of Moldova and Ukraine for countering illicit trafficking, misuse and possession of firearms, ammunition and explosives;
— strengthened capacities of law enforcement and customs services of the Western Balkans for countering illicit trafficking.
— provision of expert and technical support to Roadmap coordination including regional Roadmap coordination meetings focusing on taking stock of progress and information exchange;
— the provision of expert and technical support to local Roadmap coordination meetings monitoring the implementation of partners' action plans;
— the development of biannual monitoring and evaluation reports documenting progress, challenges and needs in the implementation of the Roadmap based on the commonly agreed KPIs;
— the mid term review of the implementation of the Roadmap;
— Roadmap outreach and visibility activities (including the maintenance of an online platform, stakeholder engagement and awareness raising).
— Organization of up to three regional Roadmap coordination meetings;
— Taking stock of progress, facilitation of information exchange, knowledge transfer and standardization;
— Organization of local coordination meetings (up to 36 in total);
— Development of biannual regional monitoring reports (up to six);
— Mid term review of the Roadmap;
— Maintenance of an online platform to ensure proper outreach and visibility of the Roadmap.
— Provision of technical and advisory support
— Organization of meetings, workshops, study visits
— Technical and advisory support provided
— Meetings, workshops or study visits organized
— Provision of advisory support, technical assistance, training, equipment for law enforcement services in countering illicit arms trafficking in the Republic of Moldova and Ukraine
— Support for participation in specialized regional platforms on SALW control
— Advisory and technical support provided
— Equipment for suppression of arms trafficking procured
— Capacity development activities implemented
— Security upgrade of one storage of SALW in Republic of Moldova planned and completed
— Procurement and delivery of specialized equipment for Customs Authorities
— Equipment provided.
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Articles 28(1) and 31(1) thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 19 November 2018, the Council adopted the EU Strategy against Illicit Firearms, Small Arms & Light Weapons and their Ammunition, entitled ‘Securing Arms, Protecting Citizens’ (the ‘EU SALW Strategy’), which sets the guidelines for Union action in the field of small arms and light weapons (SALW). The EU SALW Strategy states that the Union gives particular prominence to regional cooperation as an efficient means of small arms control. The EU SALW Strategy mentions the Western Balkans as a priority region for support.
(2) On 17 May 2018, at the EU-Western Balkans Summit in Sofia, the leaders of the Union agreed on the Sofia Declaration, to which the Western Balkans partners aligned themselves, and which includes a commitment to enhance significantly operational cooperation in the fight against international organised crime in priority areas such as firearms, drugs, migrant smuggling and trafficking in human beings.
(3) The Western Balkans region remains one of the sources of illicit arms trafficking into the Union.
(4) On 10 July 2018, the United Kingdom of Great Britain and Northern Ireland hosted the 5th Western Balkans Summit in London, which adopted the ‘Regional Roadmap for a sustainable solution to the illegal possession, misuse and trafficking of SALW/firearms and their ammunition in the Western Balkans by 2024’ (the ‘Roadmap’).
(5) The Roadmap has since been updated and extended until 2030.
(6) The United Nations (UN) 2030 Agenda for Sustainable Development, adopted on 25 September 2015, affirmed that sustainable development cannot be realised without peace and security and that illicit arms flows are amongst the factors which give rise to violence, insecurity and injustice.
(7) At the Fourth Review Conference on the implementation of the UN Programme of Action to Prevent, Combat and Eradicate the Illicit Trade in Small Arms and Light Weapons in All Its Aspects, held in June 2024 in New York, UN Member States reaffirmed the importance of reinforcing regional and subregional cooperation, through improved coordination, consultation, information exchange and operational cooperation, as appropriate, with relevant regional and subregional organisations, mechanisms, road maps and other initiatives as well as law enforcement, border control and export and import licensing authorities.
(8) The goals of the Roadmap agreed by the Western Balkans partners are consistent with the efforts within the Union and the UN to combat the illicit accumulation and trafficking of SALW and their ammunition. Therefore, the Union should support the Western Balkans in implementing the Roadmap.
(9) The Union previously supported the implementation of the Roadmap by means of Council Decisions (CFSP) 2018/1788(1)and (CFSP) 2022/2321(2).
(10) The South Eastern and Eastern Europe Clearinghouse for the Control of Small Arms and Light Weapons (SEESAC) was established in Belgrade in 2002 and functions under the joint mandate of the UN Development Programme (UNDP) and the Regional Cooperation Council (RCC). SEESAC is the successor to the Stability Pact for South-Eastern Europe, assists national and regional stakeholders in controlling and reducing the spread and misuse of SALW and ammunition, and thus contributes to enhanced stability, security and development in South-Eastern and Eastern Europe. SEESAC places particular emphasis on the development of regional projects to address the reality of cross-border flows of weapons.
(11) The Union considers SEESAC to be the preferred implementing partner for the implementation of the Roadmap in the Western Balkans, because of its proven experience and established network, the proven quality of its work and its coordinating role in the preparation of the Roadmap.
12. In addition, the Union action should provide support for countering illicit arms trafficking in the Republic of Moldova and in Ukraine, states which are dealing with similar SALW control challenges. It should do so through the transfer of knowledge and experience gained and best practices developed in the Western Balkans since 2001,
HAS ADOPTED THIS DECISION:
1. The Union shall support Western Balkans partners with the implementation of the ‘Regional Roadmap for a sustainable solution to the illegal possession, misuse and trafficking of SALW/firearms and their ammunition in the Western Balkans’.
2. The new phase of the Union’s support shall build upon the achievements under Decisions (CFSP) 2018/1788 and (CFSP) 2022/2321, and the project ‘Support for Enhancing the Fight Against the Illegal Possession, Misuse, and Trafficking of Small Arms and Light Weapons (SALW) in the Western Balkans’ funded through the Instrument for Pre-accession Assistance (IPA/2021/425-067), all implemented by SEESAC.
3. The new phase of the Union’s support shall be implemented in complementarity with Council Decision (CFSP) 2024/3006(3).
1. The focus shall be on four main areas, maintaining the holistic approach to tackling the threat posed by SALW in the region.
2. Those main areas address the strategic and policy levels, as well as the operational aspects, thus directly assisting at all levels of SALW control, with an emphasis on:
—
coordinating the regional approach and monitoring of the implementation of the Roadmap,
—
strengthening of knowledge exchange and inter-regional cooperation on SALW control,
—
strengthening the capacities of law enforcement services in Moldova and Ukraine to counter illegal possession, misuse and trafficking,
—
strengthening the capacities of law enforcement and customs services in the Western Balkans for countering illicit trafficking.
3. The action’s geographic scope shall be the Western Balkans, with direct project beneficiaries being Albania, Bosnia and Herzegovina, Kosovo(*1), Montenegro, Serbia and North Macedonia. In addition, for the goals set out in paragraph 1, the action shall provide support to the Republic of Moldova and to Ukraine.
4. A detailed description of the action is set out in the Annex to this Decision.
1. The High Representative of the Union for Foreign Affairs and Security Policy (the ‘High Representative’) shall be responsible for implementing this Decision.
2. The technical implementation of the action referred to in Article 1(1) shall be carried out by SEESAC, where necessary in coordination with the Driver of the European multidisciplinary platform against criminal threats (EMPACT) Firearms.
3. SEESAC shall perform its tasks under the responsibility of the High Representative. For that purpose, the High Representative shall enter into the necessary arrangements with UNDP, which shall act on behalf of SEESAC.
1. The financial reference amount for the implementation of the project financed by the Union referred to in Article 1(1) shall be EUR 3 499 363,97.
2. The expenditure financed by the reference amount set out in paragraph 1 shall be managed in accordance with the procedures and rules applicable to the Union budget.
3. The Commission shall supervise the proper management of the expenditure referred to in paragraph 2. For that purpose, it shall conclude the necessary agreement with UNDP, which shall act on behalf of SEESAC. The agreement shall stipulate that SEESAC has to ensure the visibility of the Union’s contribution, appropriate to its size.
4. The Commission shall endeavour to conclude the agreement referred to in paragraph 3 as soon as possible after the entry into force of this Decision. It shall inform the Council of any difficulties in that process and of the date of conclusion of the agreement.
1. The High Representative shall report to the Council on the implementation of this Decision on the basis of 6-monthly reports prepared by SEESAC. Those reports shall form the basis of the evaluation carried out by the Council.
2. The Commission shall report on the financial aspects of the project referred to in Article 1(1).
1. This Decision shall enter into force on the date of its adoption.
2. This Decision shall expire 36 months after the date of conclusion of the agreement referred to in Article 4(3). However, it shall expire six months after the date of its entry into force if no such agreement has been concluded within that six-month period.
ANNEX
PROJECT DOCUMENT
PROJECT ON SALW CONTROL ACTIVITIES IN IMPLEMENTING THE ROADMAP FOR A SUSTAINABLE SOLUTION TO THE ILLEGAL POSSESSION, MISUSE AND TRAFFICKING OF SALW/FIREARMS AND THEIR AMMUNITION IN THE WESTERN BALKANS AND DISARMAMENT AND ARMS CONTROL ACTIVITIES IN SOUTH-EAST AND EAST EUROPE 1. Introduction and objectives
Illicit firearms, small arms and light weapons continue to contribute to instability and violence in the European Union, in its immediate neighborhood, and in the rest of the world. This is recognized in the EU Strategy against illicit firearms, small arms and light weapons and their ammunition, with the Western Balkans and Eastern Neighborhood listed as priority areas of concern. The overall objective of this action is to further contribute to European and global peace and security by combatting the threat posed by the illicit possession, misuse and trafficking of small arms and light weapons and will enhance regional stability by working within the framework of the Regional Cooperation Council (RCC) and in partnership with other relevant international partners and initiatives.
Progress has continuously been made in South-East and East Europe with regards to combatting the illicit possession, misuse and trafficking of SALW, mainly due to the comprehensive and long-term support of the European Union. Nevertheless, according to the 2025 European Union Serious and Organized Crime Organized Threat Assessment, the Western Balkan continues to be a key source of illicit firearms trafficked into the EU (1). While there are no reports of firearms trafficking from Ukraine at the moment, a post conflict environment may similarly emerge as a significant source in the future. Thus, further strengthening of SALW control efforts in the EU’s neighboring regions (and ensuring the progress made until now is sustained) is extremely relevant for the security of the EU as well as and global peace and security.
In 2018, building on the South East Europe Regional Implementation Plan on Combatting the Proliferation and Impact of SALW, the authorities of the Western Balkans reinforced their commitment to address the remaining challenges regarding the illicit possession, misuse and trafficking of SALW by adopting the Roadmap for a sustainable solution to the illegal possession, misuse, and trafficking of small arms and light weapons, their ammunition and explosives in the Western Balkans by 2030
(2) (the ‘Roadmap’) at the Western Balkans Summit in London. (3) The Roadmap envisions the Western Balkans as a safer region and an exporter of security, where comprehensive and sustainable oversight and control mechanisms, fully harmonized with Union and other international standards, are in place to identify, prevent, prosecute and control the illegal possession, misuse and trafficking of firearms, ammunition and explosives. The South-Eastern and Eastern Europe Clearinghouse for the Control of Small Arms and Light Weapons (SEESAC) (4), supported the development of the Roadmap and is mandated by the Governments and the EU to
coordinate
,
monitor
and
support its implementation
.
Since 2018 progress has been made; jurisdictions in the Western Balkans have seized over 36 000 firearms; over 294 000 firearms have been voluntarily surrendered; 4 447 firearms legalized, and 5 064 deactivated. Furthermore, over 67 000 pieces of SALW have been destroyed. The Roadmap also contributed further to the harmonization of legislation with the EU acquis, thereby directly supporting their EU integration aspirations; enhancing operational cooperation, not only in the Western Balkans, but also with key EU platforms and bodies such as FRONTEX, EUROPOL and EMPACT. The Roadmap has also contributed to strengthening regional security and trust in a post conflict fragile environment, which are essential foundations for sustaining peace and development. Nevertheless, challenges remain. During the first phase of implementation of the Roadmap, 17 798 incidents with firearms have been recorded in the Western Balkans, with 794 people killed, 2 108 injured, 2 650 threatened and 333 committing suicide. The fact that almost 50 % of all recorded incidents represented weapons seizures, demonstrates a proactive approach of the law enforcement institutions in removing weapons from circulation.
The good practices implemented in the Western Balkans have influenced also the wider region. With EU finding and support of SEESAC, the Republic of Moldova has made progress in strengthening their physical security and stockpile efforts with security upgrades of 2 storages of SALW, and 4 evidence rooms; destruction of over 13 000 pieces of SALW since 2005, and by establishing the electronic weapons registry system. Efforts have also been made in strengthening the analytical capacities for firearms related investigations by establishing the Firearms Focal Point. Ukraine, on the other hand, has made progress by strengthening of coordination efforts at the national level by establishment of the Coordination Centre for Combating Illicit Trafficking in Firearms
(5), initiation of development of the SALW strategy, efforts to harmonize their legal framework with the EU acquis as well as by strengthening their capacities though various trainings. Both, representatives of Republic of Moldova and Ukraine are regularly taking part in SEESAC facilitated regional cooperation processes on SALW control in South East and East Europe.
Furthermore, the Western Balkans Roadmap, with a clear monitoring framework and a coordination mechanism, has inspired action across the globe, leading to the development of the
Caribbean Firearms Roadmap
and
Central America and Dominican Republic Roadmap
.
The impact of the Western Balkans SALW Control Roadmap and its relevance for regional cooperation and the security of the EU was acknowledged at several high-level meetings, with a clear commitment of the EU to continue to support its implementation.” (6) The new phase of the SEESAC project will build upon the achievements under EU Council Decisions (CFSP) 2018/1788 and 2022/2321 and the IPA/2021/425-067 Support for enhancing the fight against the illegal possession, misuse and trafficking of small arms and light weapons in the Western Balkans project, all implemented by SEESAC (the latter two expiring end of December 2025). It will be implemented in complementarity with EU Council Decision (CFSP) 2024/3006. The action will directly contribute to the implementation of the EU Security Strategy, the EU SALW Strategy, the EU Action Plan on Firearms Trafficking, the EU Policy Cycle for organized and serious international crime (EMPACT Firearms), the Arms Trade Treaty, the UN Programme of Action to Prevent, Combat and Eradicate the Illicit Trade in SALW in All Its Aspects, the International Tracing Instrument, the UN Firearms Protocol, UN Security Council Resolution 1325 (2000) on Women and peace and security, and the UN Disarmament Agenda which has been reinforced through the Pact for the Future, giving new political momentum and institutional backing to many of the original Agenda’s disarmament commitments. The action will further specifically enhance regional cooperation in combating the threat posed by the spread of SALW and their ammunition. The project results will also directly contribute to the implementation of Sustainable Development Goal 16 of the 2030 Agenda on peaceful and just societies, in particular targets 16.1 (significantly reduce all forms of violence and death rate everywhere) and 16.4 (significantly reduce illicit arms flows), and Goal 5 on gender equality. It will also contribute to the implementation of the South East Europe Regional Implementation Plan Combatting the Proliferation and Impact of SALW. The action will be implemented as part of UNDP Regional Programme Document for Europe and the Commonwealth of Independent States (2026-2029). 2. Selection of implementing agency and coordination with other relevant funding initiatives
SEESAC is a joint initiative of the United Nations Development Programme (UNDP) and the Regional Cooperation Council with core funding from the European Union and is the focal point for SALW-related activities in South-East Europe. As the executive arm of the South-East Europe Regional Implementation Plan on Combating the Proliferation of SALW, SEESAC has a key mandate to coordinate the implementation of SALW control efforts, monitor progress and provide the technical, advisory and project implementation support to the Governments in the region in combatting the illicit possession, misuse and trafficking of SALW. Regional ownership is ensured through the Regional Cooperation Council as well as through the Regional Steering Group, where representatives of all partners in South East Europe provide strategic guidance for SEESAC activities.
SEESAC has been working since 2002 with national and international stakeholders in South-East and East Europe on implementing a holistic approach to SALW control through the execution of a wide spectrum of activities including: the facilitation of strategic and operational regional cooperation, supporting policy development and capacity enhancement for institutions, awareness-raising and SALW collection campaigns, stockpile management, surplus reduction, and improved marking and tracing capabilities, detection and investigation capacities, as well as improved arms-exports control. In this way, SEESAC has acquired a unique capacity and experience implementing multi-stakeholder regional interventions against the shared political and economic background of the partners in the region, ensuring national and regional ownership and the long-term sustainability of its actions and establishing itself as the primary regional authority in the SALW control field.
SEESAC continues to maintain bilateral and multilateral channels of communication with all relevant actors and organizations. In that regard, SEESAC continues to serve as the Secretariat of the Regional Steering Group for SALW (RSG) and coordinates and monitors the implementation of the Western Balkans Roadmap in close cooperation with the EU, Germany and France. In this context, SEESAC also performs the Secretariat functions of the Western Balkans SALW Control Roadmap Multi Partner Trust Fund.
SEESAC regularly contributes to relevant regional fora. SEESAC regularly contributes to EU-Western Balkans Justice and Home Ministerial Meetings, meetings organized within the Berlin Process, the South East Europe Defence Ministerial process. SEESAC continues to maintain a wide network of formal and informal partnerships with organizations and initiatives, such as the Organization for Security and Cooperation (OSCE), North Atlantic Treaty Organization (NATO), and relevant UN agencies, in particular the UNODA, UNODC, UNIDIR and UNWOMEN and regional organizations such as the Regional Arms Control Verification and Implementation Assistance Centre (RACVIAC). SEESAC regularly contributes to UN Coordination Action on Small Arms (CASA) bringing together all the UN agencies working on disarmament and arms control; the SALW and mine action coordination meetings, an informal coordination mechanism on SALW control activities involving NATO, the Union and the Organization for Security and Cooperation in Europe and SEESAC. Further to this, SEESAC is regularly participating in coordination meetings on Ukraine, the Coordination Meeting of International Partners on SALW Control Efforts in Ukraine facilitated by OSCE and the Law Enforcement Sectoral Working Group Subgroup on Countering Crime and Ensuring Community Security in Ukraine, facilitated by EUAM.
SEESAC maintains close contact and provides support to relevant Union institutions for a more effective outreach to South East Europe counterparts, primarily to DG Home of the Commission, and Europol, as well as Union-led initiatives such as EMPACT Firearms and the European Firearm Experts (EFE) group.
SEESAC has pioneered an approach based on tackling shared problems through regional initiatives, which has yielded impressive results in South East and East Europe not only because of the crucial information-sharing and promotion of healthy regional competition which it sparks, but also because it helps achieve consistent and easily measurable results at national and regional level through a holistic implementation modality. The organization of the annual RSG meetings and participation by SEESAC in all relevant processes and initiatives provides timely and candid information exchange, strong situational awareness and the foresight necessary to ensure that implementation is not prone to overlap and is in line with the current needs of the governments and the regions as well as with developing trends.
SEESAC grounds all its activities in counterparts’ expressed needs and the collected baseline data and needs assessments and secures endorsement and political support from national stakeholders as a precondition for action. In addition, all efforts are framed in support of Union-led processes and achievement of Union standards and criteria. SEESAC implemented its previous Union-funded projects with a very high delivery rate of the envisaged activities, delivering sustainable project results by developing and fostering partners’ ownership of its projects and activities, and promoting regional coordination, experience and sharing of best practices, as well as regional research. Its SALW expertise and in-depth knowledge of regional affairs and relevant stakeholders make SEESAC the most suitable implementing partner for this particular action.
SEESAC will continue to work in combination with the ongoing international assistance efforts implemented under the UN framework, in particular the Western Balkans SALW Control Roadmap Multi-Partner Trust Fund (MPTF). The Roadmap Trust Fund is a key funding mechanism supporting the implementation of the Roadmap. The Trust Fund was established in March 2019 by UNDP and UNODC as Participating UN Organizations, to ensure a donor- and jurisdiction-coordinated funding approach in the implementation of the Roadmap. It strengthens coordination, planning and communication among all partners, fosters collaboration, and reduces risks to governments and financial contributors through a comprehensive risk and results-based management system. The Trust Fund has benefitted from a strong cooperation with Germany and France, as the initiators of the Roadmap, that were joined by the United Kingdom, Sweden, Norway, and the Netherlands. The Trust Fund mobilized approximately US$30 million in contributions. UNDP SEESAC functions as the Secretariat of the Trust Fund and is responsible for the overall coordination and monitoring of the Trust Fund, providing technical, management, planning and programming support to it. By September 2025, the Trust Fund supported 25 projects implemented by the Participating UN Organizations, whereby 16 completed their operations and nine are currently ongoing.
SEESAC’s work is also complemented by OSCE through the OSCE implementation of the EU COUNCIL DECISION (CFSP) 2024/3097 in support of the comprehensive programme on supporting efforts to prevent and combat illicit trafficking of SALW and Conventional Ammunition in South-Eastern Europe; and the OSCE implementation of the EU COUNCIL DECISION (CFSP) 2024/3003 in support of strengthening the capacities of the Ukrainian authorities to prevent and combat illicit trafficking in weapons, ammunition and explosives.
Other Union-supported actions in Southeast and East Europe, primarily those of Europol, Frontex and Interpol, and the operational action plans of EMPACT Firearms regularly liaise with SEESAC in order to secure complementarities of action, the relevance and timeliness of intervention. 3. Project description
The new phase of the SEESAC project will build upon the achievements made under the projects implemented through EU Council Decisions (CFSP) 2018/1788 and (CFSP) 2022/2321, as well as the Commission funded project implemented through IPA/2021/425-067, ‘Support for enhancing the fight against the illegal possession, misuse and trafficking of small arms and light weapons in the Western Balkans’. All these three projects were implemented by SEESAC. The latter two projects are expiring by the end of December 2025. The new phase of the SEESAC project will furthermore be implemented in complementarity with the ongoing project under EU Council Decision (CFSP) 2024/3006. It will focus on four main areas, maintaining the holistic approach to tackling the threat posed by SALW in the region. Those areas address the strategic/policy level as well as the operational aspects, thus directly assisting at all levels of SALW control, with a focus on: coordinating the regional approach and monitoring of the implementation of the Roadmap; strengthening of knowledge exchange and interregional cooperation on SALW control; and strengthening the capacities of law enforcement services in Moldova and Ukraine to counter illegal possession, misuse and trafficking; as well as those in the Western Balkans, primarily the law enforcement and customs services of the Western Balkans for countering illicit trafficking.
In particular, the project will result in:
—
coordinated implementation and monitoring of the implementation of the Roadmap for a sustainable solution to the illegal possession, misuse and trafficking of small arms and light weapons, their ammunition and explosives in the Western Balkans by 2030;
—
strengthened interregional cooperation, knowledge management and knowledge sharing on arms control;
—
strengthened capacities of law enforcement services of Moldova and Ukraine for countering illicit trafficking, misuse and possession of firearms, ammunition and explosives;
—
strengthened capacities of law enforcement and customs services of the Western Balkans for countering illicit trafficking.
The project’s strategy is grounded in SEESAC’s unique approach of fostering confidence and cooperation in the region as a prerequisite for achieving concrete and measurable transformational change. In particular, at the regional level, different cooperation processes facilitated by SEESAC, involving both policymakers and operational- level practitioners, represented the backbone of the approach, ensuring an enabling and competitive environment for knowledge transfer, expertise exchange and information-sharing. This has served not only to increase the capacities in the region, but more importantly to build confidence and foster direct cooperation among institutions and individual experts, which, among other, enabled the development and implementation of the Roadmap. The project will continue to foster regional cooperation and local ownership as the essential enabling elements for measurable results.
3.1. Coordination of the implementation of the Roadmap for a sustainable solution to the illegal possession, misuse and trafficking of small arms and light weapons, their ammunition and explosives in the Western Balkans by 2030
Objective
To ensure the effective coordination and monitoring of the implementation of the Roadmap.
Description
Building upon the Decisions CFSP/2018/1788 and CFSP/2022/2321, this component will ensure the coordination and monitoring of the implementation of the second phase of the Roadmap (2025-2030). The Roadmap was revised for the second phase of implementation through consultative meetings by Small Arms and Light Weapons Commissions in the region during 2023 and 2024, ensuring regional ownership and sustainability of results. Consultations included donors, regional and international partners, as well as civil society representatives. The revised text of the Roadmap was endorsed by the Western Balkans Ministers of Interior during the EU-Western Balkans Ministerial Forum on Justice and Home Affairs held in October 2024. The Roadmap continues contributing to the existing Union activities to counter the illicit possession, misuse and trafficking of SALW, specifically the EU SALW strategy, the EU Action plan on firearms trafficking that has integrated the Western Balkans Roadmap; and EMPACT work in the region. The Roadmap is a testimony to the consensus reached among all stakeholders in the region about the current challenges, the overall targets to be reached and the timeline of actions to be taken. It provides an overall platform for the achievement of commonly agreed KPIs at strategic, policy and operational level.
Covering the first phase of Roadmap implementation thirteen progress reports have been published providing a measurable and up to date account on the progress of implementation of the Roadmap. In addition, biannual local and regional coordination meetings have ensured an exemplary coordinated approach of implementation of efforts and resources among authorities, donors and implementing partners.
Specifically, the work under this component will continue to ensure the coordination and monitoring of the implementation of the Roadmap through:
—
provision of expert and technical support to Roadmap coordination including regional Roadmap coordination meetings focusing on taking stock of progress and information exchange;
—
the provision of expert and technical support to local Roadmap coordination meetings monitoring the implementation of partners’ action plans;
—
the development of biannual monitoring and evaluation reports documenting progress, challenges and needs in the implementation of the Roadmap based on the commonly agreed KPIs;
—
the mid term review of the implementation of the Roadmap;
—
Roadmap outreach and visibility activities (including the maintenance of an online platform, stakeholder engagement and awareness raising).
Project results/implementation indicators:
—
Organization of up to three regional Roadmap coordination meetings;
—
Taking stock of progress, facilitation of information exchange, knowledge transfer and standardization;
—
Organization of local coordination meetings (up to 36 in total);
—
Development of biannual regional monitoring reports (up to six);
—
Mid term review of the Roadmap;
—
Maintenance of an online platform to ensure proper outreach and visibility of the Roadmap.
3.2. Contribute to strengthened interregional cooperation, knowledge exchange and information-sharing on arms control
Objective
This component will facilitate the interregional information sharing, knowledge exchange, replication of good practices and lessons learnt though provision of technical advice, meetings, workshops and study visits.
Description
South East Europe has been implementing a comprehensive regional approach to SALW control for over two decades, covering all the functional areas of SALW control. As such, the region stood at the forefront of innovative solutions for SALW control that inspired action and were replicated in other parts of the world. SEESAC’s Regional Micro-Disarmament Standards and Guidelines that were developed in 2006 to standardize SALW control procedures, practices and norms at the operational level, influenced the development of the International Small Arms Control Standards which then later transferred into the Modular Small-arms-control Implementation Compendium (MOSAIC). Further, the Western Balkans Roadmap has been highlighted by numerous stakeholders as one of the most successful regional efforts for SALW Control globally. It has been described as a positive example by the UN Secretary General in his Reports on SALW Control to the Security Council and he has also called for elaboration and further development of Roadmaps in his Agenda for Peace.
The Roadmap has been replicated in the Caribbean, as well as in Central America and Dominican Republic, along with its coordination and monitoring mechanism, and it has also been integrated in the EU Action plan on firearms trafficking. SEESAC supported the development of the first SALW Control Strategy in the Kyrgyz Republic and facilitated interregional knowledge exchange though study visits from Kyrgyz Republic, Cambodia and Honduras to the Western Balkans with the aim for delegations to learn from best practices developed in the Western Balkans and share their experiences in SALW control.
Furthermore, SEESAC’s Armed Violence Monitoring Platform, an innovative online data platform providing in depth information as well as visualization of data on incidents with firearms across South-East Europe, is also being replicated by the EU. South East Europe has also been paving the way for the practical integration of gender in SALW control. Progress made in operationalization of Firearms Focal Points in South-East Europe is regularly shared with FFP’s from across the EU member states in joint meetings.
Most of these practices were developed and operationalized as part of implementation of EU Council Decisions in support of SEESAC’s disarmament and arms control efforts in South East Europe throughout the last two decades.
This component will facilitate further the information sharing, knowledge exchange, replication of good practices and lessons learnt among the regions.
It will do so through:
—
Provision of technical and advisory support
—
Organization of meetings, workshops, study visits
Project results/implementation indicators:
—
Technical and advisory support provided
—
Meetings, workshops or study visits organized
3.3. Capacity development of law enforcement services of the Republic of Moldova and Ukraine for countering illicit trafficking, misuse and possession of firearms, ammunition and explosives
Objective
To reduce the threat of illicit trafficking of firearms by enhancing the capacities of law-enforcement institutions including border police through advisory support and technical assistance based on identified needs.
Description
This component builds on SEESAC’s previous support to the Republic of Moldova and Ukraine. Representatives of both countries have been participating and contributing to the regional cooperation processes that SEESAC is facilitating at the strategic and operational levels. The transfer of knowledge and experiences gained, and best practices developed in the Western Balkans since 2001, has been particularly valuable in the context of ongoing war in Ukraine.
The representatives of Moldovan and Ukrainian institutions have been regularly taking part in meetings of SALW commissions and relevant institutions in South-East and East Europe; the meetings of the South-East Europe Firearms Experts Network, and thus benefitted from the information sharing and regional knowledge exchange at the strategic and operational levels. They have also benefitted from regional capacity building activities, such as those on harmonization of legislation with the EU acquis, online investigations and combatting arms trafficking on the darknet.
SEESAC has also been providing support for targeted SALW control measures at the national level. Advisory support has been provided to Ukraine in the establishment of the Coordination Centre on Combatting the Illicit Arms Trafficking under the Ministry of Internal Affairs, the development of the national legal framework on SALW control, and the development of the national strategy to prevent and Combat Illicit SALW. Tailor made trainings to enhance the investigation capacities of law enforcement institutions have been delivered.
SEESAC has also been providing support for targeted SALW control measures in the Republic of Moldova. Over the last two decades these included measures for physical security and stockpile management, including destruction of SALW and security upgrades of storages of weapons and ammunition, and evidence rooms. Support has also been provided for marking, record keeping and tracing; a marking machine has been procured and training for its use organized, and support for the establishment of the weapons registry system has been provided. SEESAC also provided the initial technical and advisory support in setting up the Firearms Focal Point. Additionally, awareness raising activities were supported on the dangers of misuse and illicit possession of firearms. Support has also been provided for the establishment of the national SALW commission; data collection has been supported to enhance the understanding of SALW control gaps, leading to the publication of the SALW survey for Republic of Moldova, while an up-to-date insight in to firearms incidents is provided through the Armed Violence Monitoring Platform. SEESAC also provided support for the development of the SALW National Programme on SALW Control for 2026–2030. Following a detailed needs assessment of the Criminal Police, support was provided for development of Standard Operating Procedures, training and equipment to enhance investigation capacities.
This component will further strengthen the capacities of institutions in the Republic of Moldova and Ukraine to combat the illegal possession, misuse and trafficking of firearms, ammunition and explosives, based on needs assessments and in line with international best practices.
It will do so through:
—
Provision of advisory support, technical assistance, training, equipment for law enforcement services in countering illicit arms trafficking in the Republic of Moldova and Ukraine
—
Support for participation in specialized regional platforms on SALW control
Project results/implementation indicators:
—
Advisory and technical support provided
—
Equipment for suppression of arms trafficking procured
—
Capacity development activities implemented
—
Security upgrade of one storage of SALW in Republic of Moldova planned and completed
3.4. Further capacity development of customs services of the Western Balkans for countering illicit trafficking
Objective
To reduce the threat of illicit trafficking of firearms by enhancing the capacities of customs services of the Western Balkans for countering illicit trafficking.
Description
In 2024, SEESAC completed the first region-wide Needs Assessment of Customs Administrations in the Western Balkans to evaluate their capacities to counter illicit firearms trafficking. The assessment was conducted using a methodology previously developed and applied by SEESAC for Border and Criminal Police Services, covering all relevant aspects, including legislation, administrative and institutional capacities, training needs, and technical equipment.
Assessment missions were carried out across all six jurisdictions, resulting in comprehensive reports, endorsed by the authorities. They set the basis for targeted support, ensuring that customs authorities are systematically integrated into regional and EU firearms control efforts. Strengthening customs capacities is needed to enable a coordinated, cross-border response with Border Police, in line with EU Integrated Border Management standards and the Western Balkans SALW Roadmap, thereby reinforcing the region’s collective ability to combat illicit firearms trafficking.
To date, customs administrations in most jurisdictions have not benefited from systematic capacity development in relation to the detection of firearms, essential components, ammunition, and explosives at border crossing points. This gap is critical, as effective firearms control requires a joint and coordinated response by both Border Police and Customs authorities. While Border and Criminal Police services have been supported through EU Council Decisions (2018/1788 and 2019/2111) implemented by SEESAC, comparable tailored support to customs—apart from participation in regional processes—has been largely absent. Building on lessons learned and best practices applied with Border and Criminal Police, a similar approach has now been envisaged for customs authorities.
Under the EU Council Decision 2024/3006, SEESAC has already initiated capacity development activities by supporting the development of Standard Operating Procedures for each Customs Administration in the Western Balkans. Furthermore, targeted training across all jurisdictions will take place until the end of 2025. The needs assessments identify lack of specialized equipment as one of key gaps. This gap will be addressed under this project.
This will be done through:
—
Procurement and delivery of specialized equipment for Customs Authorities
Project results/implementation indicators:
—
Equipment provided. 4. Beneficiaries
The direct beneficiaries of the project will be the institutions responsible for SALW control in South East and East Europe. The authorities responsible for home affairs, police services, border guards and customs authorities of Albania, BiH, Kosovo, Montenegro, North Macedonia, Republic of Moldova, Serbia and Ukraine will benefit from either advisory support, the coordination and monitoring efforts, or capacity development, knowledge advancement, improved procedures and cost-effective specialized equipment necessary for policy, operational and technical advancements in SALW control. The proposed activities are fully in line with the South East Europe Regional Implementation Plan on Combatting the Proliferation and Impact of SALW and the Western Balkans Roadmap, as well as partners’ priorities on SALW control. The general population of South East and East Europe and the Union, at risk from the illegal possession, misuse and proliferation of SALW, will benefit from this project indirectly. 5. Union visibility
SEESAC shall take all necessary measures to ensure the visibility of the European Union’s financial support. Such measures will be carried out in full compliance with the Communication and Visibility Requirements for European Union External Actions (2018) as well as the updated guidance Communicating and raising EU visibility: Guidance for external actions (2022). 6. Duration
Based on the experience of implementing Decisions 2002/842/CFSP, 2010/179/CFSP, 2013/730/CFSP, 2016/2356/CFSP, 2018/1788/CFSP and 2022/2321/CFSP and taking into consideration the regional scope of the project, the number of beneficiaries and the number and the complexity of planned activities, the timeframe for implementation is 36 months. 7. General set up
The technical implementation of this action has been entrusted to UNDP, acting on behalf of SEESAC, the regional initiative working under the mandate of UNDP and the RCC. As the executive arm of the Regional Implementation Plan on Combating the Proliferation of SALW, SEESAC acts as focal point for all SALW-related issues in the South East and East Europe, including facilitating the coordination of the implementation of the regional Roadmap. UNDP, acting on behalf of SEESAC, will have the overall responsibility for the implementation of project activities and accountability for project implementation. The project duration is three years (36 months). 8. Partners
SEESAC will directly implement the action in close cooperation with SALW commissions as well as with the relevant authorities for home affairs of Albania, BiH, Kosovo, Montenegro, Serbia, North Macedonia, the Republic of Moldova, and Ukraine. Other institutions will be closely involved in line with the established multi-stakeholder holistic approach to SALW control. 9. Reporting
Reporting, narrative as well as financial, shall cover the whole of the action described in the relevant contribution-specific agreement and its attached budget, regardless of whether this action is wholly financed or co-financed by the Commission. On a quarterly basis, narrative progress reports shall be submitted to record and monitor progress towards the completion of key results.

(1) According to SEESAC, the region is not only a source, but also a transit and destination for firearms trafficking.
(2) See: https://www.seesac.org/SALW-Control-Roadmap/

(3) The Roadmap has been extended beyond 2024 at the EU Western Balkans Ministerial Meeting on Justice and Home Affairs in October 2024.
(4) As the executive arm of the South East Europe Regional Implementation Plan on Combatting the Proliferation and Impact of SALW.

(5) Full name: Coordination Centre for Combating Illicit Trafficking in Firearms, Their Parts and Components and Ammunition.
(6) For example: the EU-Western Balkans Summit on 13 December 2023, the EU Western Balkans summit on 18 December 2024, the Berlin Process Summit on 14 October 2024.

Council Decision (CFSP) 2025/2580 of 15 December 2025 amending Decision (CFSP) 2016/849 concerning restrictive measures against the Democratic People’s Republic of Korea

Official Journalof the European Union ENL series
2025/2580 16.12.2025
(1) On 27 May 2016, the Council adopted Decision (CFSP) 2016/849(1).
(2) In accordance with Article 36(2) of Decision (CFSP) 2016/849, the Council has reviewed the lists of designated persons, entities and vessels set out in Annexes II, III, V and VI to that Decision.
(3) The restrictive measures against the persons and entities in the lists set out in Annexes II and III to Decision (CFSP) 2016/849 should be maintained. The entries for one person and three entities in those Annexes should be updated.
(4) Decision (CFSP) 2016/849 should therefore be amended accordingly,
(1) Annex II is amended as follows:(a)under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘A. Persons’, entry 10 is replaced by the following:NameAliasIdentifying informationDate of designationStatement of Reasons‘10.HONG Sung-Mu홍승무HONG Sung MuDOB: 1.1.1942Gender: male20.5.2016Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’(b)under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘B. Entities’, entry 4 is replaced by the following:NameAliasLocationDate of designationOther information‘4.Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소22.12.2009Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’ (a) under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘A. Persons’, entry 10 is replaced by the following:NameAliasIdentifying informationDate of designationStatement of Reasons‘10.HONG Sung-Mu홍승무HONG Sung MuDOB: 1.1.1942Gender: male20.5.2016Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’ Name Alias Identifying information Date of designation Statement of Reasons ‘10. HONG Sung-Mu홍승무 HONG Sung Mu DOB: 1.1.1942Gender: male 20.5.2016 Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’ (b) under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘B. Entities’, entry 4 is replaced by the following:NameAliasLocationDate of designationOther information‘4.Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소22.12.2009Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’ Name Alias Location Date of designation Other information ‘4. Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 22.12.2009 Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
(a) under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘A. Persons’, entry 10 is replaced by the following:NameAliasIdentifying informationDate of designationStatement of Reasons‘10.HONG Sung-Mu홍승무HONG Sung MuDOB: 1.1.1942Gender: male20.5.2016Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’ Name Alias Identifying information Date of designation Statement of Reasons ‘10. HONG Sung-Mu홍승무 HONG Sung Mu DOB: 1.1.1942Gender: male 20.5.2016 Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’
Name Alias Identifying information Date of designation Statement of Reasons
‘10. HONG Sung-Mu홍승무 HONG Sung Mu DOB: 1.1.1942Gender: male 20.5.2016 Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’
(b) under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘B. Entities’, entry 4 is replaced by the following:NameAliasLocationDate of designationOther information‘4.Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소22.12.2009Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’ Name Alias Location Date of designation Other information ‘4. Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 22.12.2009 Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
Name Alias Location Date of designation Other information
‘4. Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 22.12.2009 Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
(a) under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘A. Persons’, entry 10 is replaced by the following:NameAliasIdentifying informationDate of designationStatement of Reasons‘10.HONG Sung-Mu홍승무HONG Sung MuDOB: 1.1.1942Gender: male20.5.2016Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’ Name Alias Identifying information Date of designation Statement of Reasons ‘10. HONG Sung-Mu홍승무 HONG Sung Mu DOB: 1.1.1942Gender: male 20.5.2016 Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’
Name Alias Identifying information Date of designation Statement of Reasons
‘10. HONG Sung-Mu홍승무 HONG Sung Mu DOB: 1.1.1942Gender: male 20.5.2016 Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’
Name Alias Identifying information Date of designation Statement of Reasons
‘10. HONG Sung-Mu홍승무 HONG Sung Mu DOB: 1.1.1942Gender: male 20.5.2016 Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’
(b) under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘B. Entities’, entry 4 is replaced by the following:NameAliasLocationDate of designationOther information‘4.Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소22.12.2009Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’ Name Alias Location Date of designation Other information ‘4. Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 22.12.2009 Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
Name Alias Location Date of designation Other information
‘4. Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 22.12.2009 Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
Name Alias Location Date of designation Other information
‘4. Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 22.12.2009 Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
(2) In Annex III, under the heading ‘B. Entities’, entries 3 and 8 are replaced by the following:Name (and possible aliases)Identifying informationDate of designationReasons‘3.Maritime Administrative Bureaua.k.a. Maritime Administration of DPR Koreaa.k.a. DPRK National Maritime Supervision Bureau조선민주주의인민공화국 국가해사감독국Address: Ryonhwa-2Dong, Central District, Pyongyang, DPRKPO Box 416Telephone: 850-2-18111 Ex 8059Fax 850 2 381 4410Email: [email protected]: www.ma.gov.kp16.10.2017The Maritime Administrative Bureau has assisted in the evasion of sanctions imposed by the United Nations Security Council including by renaming and re-registering assets of designated entities and providing false documentation to vessels subject to United Nations sanctions.8.Korea Paekho Trading Corporation(Alias: Joson Paekho Muyok Hoesa)조선백호무역회사Address: Chongryu 3-dong, Taedonggang District, Pyongyang, Democratic People’s Republic of Korea21.4.2022Paekho Trading Corporation is an art company involved in constructing statues overseas, in exporting artwork statues produced by Paekho Art Studio, and facilitates illicit labour and access to international financial systems. It specifically targets development grants and loans, as well as foreign-direct investment earmarked for municipal projects. It is, thereby, engaged in the evasion of sanctions and responsible for supporting financially the DPRK’s nuclear and ballistic programmes. In July 2024, the company was seen participating in a trade fair of DPRK products in Vladivostok, Russia, and in November 2024, it was seen participating in the 16th Pyongyang Autumn International Trade Fair.’ Name (and possible aliases) Identifying information Date of designation Reasons ‘3. Maritime Administrative Bureaua.k.a. Maritime Administration of DPR Koreaa.k.a. DPRK National Maritime Supervision Bureau조선민주주의인민공화국 국가해사감독국 Address: Ryonhwa-2Dong, Central District, Pyongyang, DPRKPO Box 416Telephone: 850-2-18111 Ex 8059Fax 850 2 381 4410Email: [email protected]: www.ma.gov.kp 16.10.2017 The Maritime Administrative Bureau has assisted in the evasion of sanctions imposed by the United Nations Security Council including by renaming and re-registering assets of designated entities and providing false documentation to vessels subject to United Nations sanctions. 8. Korea Paekho Trading Corporation(Alias: Joson Paekho Muyok Hoesa)조선백호무역회사 Address: Chongryu 3-dong, Taedonggang District, Pyongyang, Democratic People’s Republic of Korea 21.4.2022 Paekho Trading Corporation is an art company involved in constructing statues overseas, in exporting artwork statues produced by Paekho Art Studio, and facilitates illicit labour and access to international financial systems. It specifically targets development grants and loans, as well as foreign-direct investment earmarked for municipal projects. It is, thereby, engaged in the evasion of sanctions and responsible for supporting financially the DPRK’s nuclear and ballistic programmes. In July 2024, the company was seen participating in a trade fair of DPRK products in Vladivostok, Russia, and in November 2024, it was seen participating in the 16th Pyongyang Autumn International Trade Fair.’
Name (and possible aliases) Identifying information Date of designation Reasons
‘3. Maritime Administrative Bureaua.k.a. Maritime Administration of DPR Koreaa.k.a. DPRK National Maritime Supervision Bureau조선민주주의인민공화국 국가해사감독국 Address: Ryonhwa-2Dong, Central District, Pyongyang, DPRKPO Box 416Telephone: 850-2-18111 Ex 8059Fax 850 2 381 4410Email: [email protected]: www.ma.gov.kp 16.10.2017 The Maritime Administrative Bureau has assisted in the evasion of sanctions imposed by the United Nations Security Council including by renaming and re-registering assets of designated entities and providing false documentation to vessels subject to United Nations sanctions.
8. Korea Paekho Trading Corporation(Alias: Joson Paekho Muyok Hoesa)조선백호무역회사 Address: Chongryu 3-dong, Taedonggang District, Pyongyang, Democratic People’s Republic of Korea 21.4.2022 Paekho Trading Corporation is an art company involved in constructing statues overseas, in exporting artwork statues produced by Paekho Art Studio, and facilitates illicit labour and access to international financial systems. It specifically targets development grants and loans, as well as foreign-direct investment earmarked for municipal projects. It is, thereby, engaged in the evasion of sanctions and responsible for supporting financially the DPRK’s nuclear and ballistic programmes. In July 2024, the company was seen participating in a trade fair of DPRK products in Vladivostok, Russia, and in November 2024, it was seen participating in the 16th Pyongyang Autumn International Trade Fair.’
Name (and possible aliases) Identifying information Date of designation Reasons
‘3. Maritime Administrative Bureaua.k.a. Maritime Administration of DPR Koreaa.k.a. DPRK National Maritime Supervision Bureau조선민주주의인민공화국 국가해사감독국 Address: Ryonhwa-2Dong, Central District, Pyongyang, DPRKPO Box 416Telephone: 850-2-18111 Ex 8059Fax 850 2 381 4410Email: [email protected]: www.ma.gov.kp 16.10.2017 The Maritime Administrative Bureau has assisted in the evasion of sanctions imposed by the United Nations Security Council including by renaming and re-registering assets of designated entities and providing false documentation to vessels subject to United Nations sanctions.
8. Korea Paekho Trading Corporation(Alias: Joson Paekho Muyok Hoesa)조선백호무역회사 Address: Chongryu 3-dong, Taedonggang District, Pyongyang, Democratic People’s Republic of Korea 21.4.2022 Paekho Trading Corporation is an art company involved in constructing statues overseas, in exporting artwork statues produced by Paekho Art Studio, and facilitates illicit labour and access to international financial systems. It specifically targets development grants and loans, as well as foreign-direct investment earmarked for municipal projects. It is, thereby, engaged in the evasion of sanctions and responsible for supporting financially the DPRK’s nuclear and ballistic programmes. In July 2024, the company was seen participating in a trade fair of DPRK products in Vladivostok, Russia, and in November 2024, it was seen participating in the 16th Pyongyang Autumn International Trade Fair.’
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 29 thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 27 May 2016, the Council adopted Decision (CFSP) 2016/849(1).
(2) In accordance with Article 36(2) of Decision (CFSP) 2016/849, the Council has reviewed the lists of designated persons, entities and vessels set out in Annexes II, III, V and VI to that Decision.
(3) The restrictive measures against the persons and entities in the lists set out in Annexes II and III to Decision (CFSP) 2016/849 should be maintained. The entries for one person and three entities in those Annexes should be updated.
(4) Decision (CFSP) 2016/849 should therefore be amended accordingly,
HAS ADOPTED THIS DECISION:
Annexes II and III to Decision (CFSP) 2016/849 are amended in accordance with the Annex to this Decision.
This Decision shall enter into force on the day following that of its publication in theOfficial Journal of the European Union.
ANNEXDecision (CFSP) 2016/849 is amended as follows:

(1) | Annex II is amended as follows:(a)under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘A. Persons’, entry 10 is replaced by the following:NameAliasIdentifying informationDate of designationStatement of Reasons‘10.HONG Sung-Mu홍승무HONG Sung MuDOB: 1.1.1942Gender: male20.5.2016Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’(b)under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘B. Entities’, entry 4 is replaced by the following:NameAliasLocationDate of designationOther information‘4.Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소22.12.2009Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’ | (a) | under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘A. Persons’, entry 10 is replaced by the following:NameAliasIdentifying informationDate of designationStatement of Reasons‘10.HONG Sung-Mu홍승무HONG Sung MuDOB: 1.1.1942Gender: male20.5.2016Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’ | | Name | Alias | Identifying information | Date of designation | Statement of Reasons | ‘10. | HONG Sung-Mu홍승무 | HONG Sung Mu | DOB: 1.1.1942Gender: male | 20.5.2016 | Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’ | (b) | under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘B. Entities’, entry 4 is replaced by the following:NameAliasLocationDate of designationOther information‘4.Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소22.12.2009Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’ | | Name | Alias | Location | Date of designation | Other information | ‘4. | Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 | | | 22.12.2009 | Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
(a) | under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘A. Persons’, entry 10 is replaced by the following:NameAliasIdentifying informationDate of designationStatement of Reasons‘10.HONG Sung-Mu홍승무HONG Sung MuDOB: 1.1.1942Gender: male20.5.2016Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’ | | Name | Alias | Identifying information | Date of designation | Statement of Reasons | ‘10. | HONG Sung-Mu홍승무 | HONG Sung Mu | DOB: 1.1.1942Gender: male | 20.5.2016 | Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’
| Name | Alias | Identifying information | Date of designation | Statement of Reasons
‘10. | HONG Sung-Mu홍승무 | HONG Sung Mu | DOB: 1.1.1942Gender: male | 20.5.2016 | Vice Director of the Munitions Industry Department (MID). The MID – designated by the UN Security Council on 2 March 2016 – is involved in key aspects of the DPRK’s missile programme. The MID is responsible for overseeing the development of the DPRK’s ballistic missiles, including research and development programmes. As such, Hong is responsible for the DPRK’s nuclear arms-related, ballistic-missile-related or other weapons of mass destruction-related programmes. He witnessed the launch of the Hwasong-15 intercontinental ballistic missile on 28 November 2017.He participated in a meeting of the Central Military Commission of the Korean Workers’ Party in July 2020 dedicated to “deterrence from war”, a euphemism used to refer to the DPRK nuclear programme. He was re-elected to Party Central Committee in January 2021. In March 2023, he was photographed with Kim Jong Un inspecting purported nuclear warheads ready for mounting on ballistic missiles, and in September 2024, he was photographed with Kim Jong Un inspecting a DPRK uranium enrichment facility.’
(b) | under the heading ‘I. Persons and entities responsible for the DPRK’s nuclear-related, ballistic-missile-related or other weapons of mass destruction-related programmes or persons or entities acting on their behalf or at their direction, or entities owned or controlled by them’, subheading ‘B. Entities’, entry 4 is replaced by the following:NameAliasLocationDate of designationOther information‘4.Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소22.12.2009Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’ | | Name | Alias | Location | Date of designation | Other information | ‘4. | Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 | | | 22.12.2009 | Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
| Name | Alias | Location | Date of designation | Other information
‘4. | Yongbyon Nuclear Scientific Research Centre녕변 원자력 연구소영변 원자력 연구소 | | | 22.12.2009 | Facilities capable of producing fissile material for military uses, including a 5MW (e) reactor, a plutonium reprocessing facility (radio-chemical laboratory), a Light Water Reactor (LWR) and a reported uranium enrichment facility. The Centre is maintained by the General Bureau of Atomic Energy (entity designated by the UNSC, 16.7.2009). In June 2024, the International Atomic Energy Agency (IAEA) stated that they had observed the intermittent discharge of water from the cooling system of the LWR at Yongbyon since December 2023, consistent with the operation of the LWR. The IAEA also detected ongoing indications of operation of the 5MW(e) reactor and of the reported centrifuge enrichment facility. The UN Panel of Experts, in its March 2024 report, also detected significant ongoing activity at Yongbyon. Satellite imagery taken throughout 2025 confirmed continued operations and the completion of several new construction projects.’
(2) | In Annex III, under the heading ‘B. Entities’, entries 3 and 8 are replaced by the following:Name (and possible aliases)Identifying informationDate of designationReasons‘3.Maritime Administrative Bureaua.k.a. Maritime Administration of DPR Koreaa.k.a. DPRK National Maritime Supervision Bureau조선민주주의인민공화국 국가해사감독국Address: Ryonhwa-2Dong, Central District, Pyongyang, DPRKPO Box 416Telephone: 850-2-18111 Ex 8059Fax 850 2 381 4410Email: [email protected]: www.ma.gov.kp16.10.2017The Maritime Administrative Bureau has assisted in the evasion of sanctions imposed by the United Nations Security Council including by renaming and re-registering assets of designated entities and providing false documentation to vessels subject to United Nations sanctions.8.Korea Paekho Trading Corporation(Alias: Joson Paekho Muyok Hoesa)조선백호무역회사Address: Chongryu 3-dong, Taedonggang District, Pyongyang, Democratic People’s Republic of Korea21.4.2022Paekho Trading Corporation is an art company involved in constructing statues overseas, in exporting artwork statues produced by Paekho Art Studio, and facilitates illicit labour and access to international financial systems. It specifically targets development grants and loans, as well as foreign-direct investment earmarked for municipal projects. It is, thereby, engaged in the evasion of sanctions and responsible for supporting financially the DPRK’s nuclear and ballistic programmes. In July 2024, the company was seen participating in a trade fair of DPRK products in Vladivostok, Russia, and in November 2024, it was seen participating in the 16th Pyongyang Autumn International Trade Fair.’ | | Name (and possible aliases) | Identifying information | Date of designation | Reasons | ‘3. | Maritime Administrative Bureaua.k.a. Maritime Administration of DPR Koreaa.k.a. DPRK National Maritime Supervision Bureau조선민주주의인민공화국 국가해사감독국 | Address: Ryonhwa-2Dong, Central District, Pyongyang, DPRKPO Box 416Telephone: 850-2-18111 Ex 8059Fax 850 2 381 4410Email: [email protected]: www.ma.gov.kp | 16.10.2017 | The Maritime Administrative Bureau has assisted in the evasion of sanctions imposed by the United Nations Security Council including by renaming and re-registering assets of designated entities and providing false documentation to vessels subject to United Nations sanctions. | 8. | Korea Paekho Trading Corporation(Alias: Joson Paekho Muyok Hoesa)조선백호무역회사 | Address: Chongryu 3-dong, Taedonggang District, Pyongyang, Democratic People’s Republic of Korea | 21.4.2022 | Paekho Trading Corporation is an art company involved in constructing statues overseas, in exporting artwork statues produced by Paekho Art Studio, and facilitates illicit labour and access to international financial systems. It specifically targets development grants and loans, as well as foreign-direct investment earmarked for municipal projects. It is, thereby, engaged in the evasion of sanctions and responsible for supporting financially the DPRK’s nuclear and ballistic programmes. In July 2024, the company was seen participating in a trade fair of DPRK products in Vladivostok, Russia, and in November 2024, it was seen participating in the 16th Pyongyang Autumn International Trade Fair.’
| Name (and possible aliases) | Identifying information | Date of designation | Reasons
‘3. | Maritime Administrative Bureaua.k.a. Maritime Administration of DPR Koreaa.k.a. DPRK National Maritime Supervision Bureau조선민주주의인민공화국 국가해사감독국 | Address: Ryonhwa-2Dong, Central District, Pyongyang, DPRKPO Box 416Telephone: 850-2-18111 Ex 8059Fax 850 2 381 4410Email: [email protected]: www.ma.gov.kp | 16.10.2017 | The Maritime Administrative Bureau has assisted in the evasion of sanctions imposed by the United Nations Security Council including by renaming and re-registering assets of designated entities and providing false documentation to vessels subject to United Nations sanctions.
8. | Korea Paekho Trading Corporation(Alias: Joson Paekho Muyok Hoesa)조선백호무역회사 | Address: Chongryu 3-dong, Taedonggang District, Pyongyang, Democratic People’s Republic of Korea | 21.4.2022 | Paekho Trading Corporation is an art company involved in constructing statues overseas, in exporting artwork statues produced by Paekho Art Studio, and facilitates illicit labour and access to international financial systems. It specifically targets development grants and loans, as well as foreign-direct investment earmarked for municipal projects. It is, thereby, engaged in the evasion of sanctions and responsible for supporting financially the DPRK’s nuclear and ballistic programmes. In July 2024, the company was seen participating in a trade fair of DPRK products in Vladivostok, Russia, and in November 2024, it was seen participating in the 16th Pyongyang Autumn International Trade Fair.’

Council Decision (CFSP) 2025/2579 of 15 December 2025 amending Decision (CFSP) 2020/1639 establishing the general conditions under which third States could exceptionally be invited to participate in individual PESCO projects

Official Journalof the European Union ENL series
2025/2579 16.12.2025
(1) On 5 November 2020, the Council adopted Decision (CFSP) 2020/1639(2)establishing the general conditions under which third States could exceptionally be invited to participate in individual PESCO projects.
(2) Article 7(2)(a) of that Decision provides that entities may only be involved in the implementation of PESCO projects after 31 December 2025 on the basis of contracts concluded or procurement procedures launched before that date.
(3) In the interest of the continued implementation of PESCO projects, it is necessary to amend those provisions to allow entities to be involved in the implementation of PESCO projects until 31 December 2030,
‘(a) entities may be involved in the implementation of PESCO projects after 31 December 2030 only on the basis of contracts concluded or procurement procedures launched by that date.’.
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on European Union, and in particular Article 46(6) thereof,
Having regard to Council Decision (CFSP) 2017/2315 of 11 December 2017 establishing permanent structured cooperation (PESCO) and determining the list of participating Member States(1), and in particular Article 4(2), point (g), thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
(1) On 5 November 2020, the Council adopted Decision (CFSP) 2020/1639(2)establishing the general conditions under which third States could exceptionally be invited to participate in individual PESCO projects.
(2) Article 7(2)(a) of that Decision provides that entities may only be involved in the implementation of PESCO projects after 31 December 2025 on the basis of contracts concluded or procurement procedures launched before that date.
(3) In the interest of the continued implementation of PESCO projects, it is necessary to amend those provisions to allow entities to be involved in the implementation of PESCO projects until 31 December 2030,
HAS ADOPTED THIS DECISION:
In Article 7(2) of Decision (CFSP) 2020/1639, point (a) is replaced by the following:
‘(a)
entities may be involved in the implementation of PESCO projects after 31 December 2030 only on the basis of contracts concluded or procurement procedures launched by that date.’.
This Decision shall enter into force on the date of its adoption.