Sanctions 2025

FRANCE Law and Practice Contributed by: William Julié, Amélie Beauchemin, Camille Gosson and Elena Moreno, WJ Avocats

WJ Avocats 55 rue de Prony 75017 Paris France

Tel: +33 1 88 33 51 80 Fax: +33 1 88 33 51 81 Email: info@wjavocats.com Web: www.wjavocats.com/en/

1. Trends and Overview 1.1 Sanctions Market

• persons who have facilitated transfers of owner - ship, control or economic benefits for sanctioned businesses, especially those linked to individuals designated under criterion (g) of Article 3 (m) of Council Regulation 269/2014 (since 13 May 2025). Regarding ancillary proceedings to sanctions, report - ing obligations have become stricter, as detailed in the following. In addition, challenges to listings have started to reach the stage of examination of appeals by the European Court of Justice (CJEU), which will likely produce important case law more precisely defining the framework of sanctions against Russia and Belarus. 1.2 Key Trends The top trends in France concerning sanctions in the last 12 months were all due to the expansion and development of tools regarding EU sanctions, includ - ing: • new listings and listing criteria; • expansion of energy-related sanctions; • further reporting obligations; and • new definitions and rules arising from the published decisions of the General Court and the CJEU. In addition, on 8 October 2024, the EU adopted a new sanctions regime targeting Russian actors involved in destabilisation, with the first package of sanctions being approved on 16 December 2024. The aim of these sanctions is to counter Russia’s hybrid actions, which threaten democracy, the rule of law, stability

As an EU member state, France implements the sanc - tions imposed by the Council of the EU into its legal system. The sanctions have continued to expand over the last 12 months due to the numerous new sanc - tions packages (the 14th, 15th, 16th, 17th and 18th sanctions packages) imposed by the EU in the context of the war in Ukraine. Energy-related sanctions have been expanded, particularly targeting liquefied natural gas (LNG) along with a prohibition on recognising or enforcing judgments issued by Russian courts based on Article 248 of Russia’s Arbitration Procedure Code, the suspension of certain media outlets’ broadcasting activities within or directed at the EU and the listing of hundreds of new Russian and Belarusian individu - als and entities under amended or newly introduced criteria. In particular, recent listing criteria introduced under the Russian sanctions regime now allow for restrictive measures against: • persons who own, control, manage or operate ves - sels transporting crude oil or petroleum products originating in or exported from Russia (since 24 February 2025) (Article 3 (k) of Council Regulation 269/2014); • persons involved in, supporting or benefitting from Russia’s military-industrial complex (since 24 February 2025) (Article 3 (l) of Council Regulation 269/2014); and

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