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Date: 2025-09-05 Category: Not Applicable State: Union Government Country: Europe

Council Implementing Regulation (EU) 2025/1789 of 5 September 2025 implementing Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses

Issued by Council of the European Union · Not Applicable

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Executive Summary & Key Takeaways

Executive Summary: Council Implementing Regulation (EU) 2025/1789 of September 5, 2025, amends Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses. This regulation adds two individuals to the list of those subject to restrictive measures due to their involvement in human rights violations in Crimea. The regulation entered into force upon its publication in the Official Journal of the European Union on September 5, 2025. Key Points / Main Content: Amendment to Annex I of Regulation (EU) 2020/1998: * Annex I of Council Regulation (EU) 2020/1998 is amended to include two additional natural persons under heading A (Natural persons). Listing of Additional Individuals: * Vadim Viktorovich Bulgakov, Head of the Directorate of the Russian Federal Penal Enforcement Service for the Republic of Crimea and the City of Sevastopol, is added to the list due to his responsibility for the widespread and systematic denial of adequate medical care to detainees and prisoners, amounting to cruel, inhuman, or degrading treatment. * Aleksei Nikolaevich Pikin, Deputy Head of the Directorate of the Russian Federal Penal Enforcement Service for the Republic of Crimea and the City of Sevastopol, is added to the list for similar reasons related to human rights violations within the Crimean penal system, including the denial of medical care and mistreatment of prisoners. Entry into Force: * The regulation entered into force on September 5, 2025, the date of its publication in the Official Journal of the European Union. Impact Analysis: Member States: * Impact: Member states are obligated to implement the restrictive measures outlined in Regulation (EU) 2020/1998, as amended by this regulation, concerning the listed individuals. * Action Required: Member states must ensure that the restrictive measures are enforced within their jurisdiction. Vadim Viktorovich Bulgakov and Aleksei Nikolaevich Pikin: * Impact: Subject to restrictive measures as outlined in Regulation (EU) 2020/1998. * Action Required: Compliance with sanctions and restrictions. European Union: * Impact: Reinforces the EU's commitment to addressing serious human rights violations globally through the EU Global Human Rights Sanctions Regime. * Action Required: Continue monitoring and enforcing human rights sanctions.

Key Entities Referenced

European Union: A political and economic union of member states located primarily in Europe. Council of the European Union: A part of the government of the European Union. Treaty on the Functioning of the European Union: One of the primary treaties of the European Union. Regulation EU 2020/1998: A Council Regulation concerning restrictive measures against serious human rights violations and abuses. EU Global Human Rights Sanctions Regime: A framework established by the European Union to address serious human rights violations and abuses worldwide. Russian Federation: The formal name of Russia, a country spanning Eastern Europe and Northern Asia. Republic of Crimea: A region that was illegally annexed by the Russian Federation from Ukraine in 2014. Vadim Viktorovich Bulgakov: Head of the Directorate of the Russian Federal Penal Enforcement Service for the Republic of Crimea and the City of Sevastopol, sanctioned for human rights violations.
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Official Journal EN of the European Union L series 2025/1789 5.9.2025 COUNCIL IMPLEMENTING REGULATION (EU) 2025/1789 of 5 September 2025 implementing Regulation (EU) 2020/1998 concerning restrictive measures against serious human rights violations and abuses THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Council Regulation (EU) 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses(1), and in particular Article 14(1) thereof, Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy, Whereas: (1) On 7 December 2020, the Council adopted Regulation (EU) 2020/1998. (2) On 8 December 2020, by way of the Declaration by the High Representative of the Union for Foreign Affairs and Security Policy (the ‘High Representative’), on behalf of the European Union regarding the EU Global Human Rights Sanctions Regime, the Union and its Member States reaffirmed their strong commitment to the promotion and protection of human rights around the world. The EU Global Human Rights Sanctions Regime underscores the Union’s determination to enhance its role in addressing serious human rights violations and abuses worldwide. Achieving the effective enjoyment of human rights for every person is a strategic goal of the Union. Respect for human dignity, freedom, democracy, equality, the rule of law and human rights is a fundamental value of the Union and its common foreign and security policy. (3) Since the illegal annexation of Crimea and Sevastopol by the Russian Federation in 2014, the human rights situation in the Crimean peninsula has significantly deteriorated. Residents of the peninsula face systematic restrictions on their fundamental freedoms, and serious human rights violations occur in Crimean detention centres, including cruel, inhuman, and degrading treatment of detainees. (4) In that context, two persons should be included in the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex I to Regulation (EU) 2020/1998. (5) Regulation (EU) 2020/1998 should therefore be amended accordingly, HAS ADOPTED THIS REGULATION: Article 1 Annex I to Council Regulation (EU) 2020/1998 is amended in accordance with the Annex to this Regulation. (1) OJ L 410 I, 7.12.2020, p. 1, ELI: http://data.europa.eu/eli/reg/2020/1998/oj. ELI: http://data.europa.eu/eli/reg_impl/2025/1789/oj 1/4EN OJ L, 5.9.2025 Article 2 This Regulation shall enter into force on the date of its publication in the Official Journal of the European Union. This Regulation shall be binding in its entirety and directly applicable in all Member States. Done at Brussels, 5 September 2025. For the Council The President M. BJERRE 2/4 ELI: http://data.europa.eu/eli/reg_impl/2025/1789/ojANNEX In Annex I to Regulation (EU) 2020/1998, the following entries are added to the list of natural and legal persons, entities and bodies under heading ‘A. Natural persons’: Names (Transliteration into Names Identifying information Reasons for listing Date of listing Latin script) ‘134. Vadim Viktorovich Вадим Викторович Position: Head of the Directorate of Since November 2014, Vadim Bulgakov is the Head of the Directorate of the 5.9.2025 BULGAKOV БУЛГАКОВ the Russian Federal Penal Russian Federal Penal Enforcement Service for the “Republic of Crimea and Enforcement Service for the the City of Sevastopol”. He holds sole authority over the Directorate’s activities a.k.a. (Russian spelling) “Republic of Crimea and the City of and, as such, bears personal responsibility for, among other things, the proper Vadym Viktorovych Sevastopol” provision of medical services to detainees and prisoners in Crimea. In this BULHAKOV capacity, he is accountable for the widespread and systematic denial of DOB: 30.1.1969 adequate medical care and treatment to detainees and prisoners, in particular POB: Simferopol, Ukraine political prisoners. This amounts to cruel, inhuman or degrading treatment. Nationality: Ukrainian, Russian Since his appointment as Head of the Directorate in 2014, widespread and systematic human rights violations in Crimean detention centres have been Tax ID Ukraine (ДРФО): documented by the United Nations and the European Court of Human Rights. 2523214611 In particular, the administrative practice of ill-treatment and denial of medical care to political prisoners, which constitutes an act of cruel, inhuman, or Tax ID Russia (ИНН): degrading treatment or punishment, has repeatedly occurred at the 910218275068 Simferopol detention centre in Crimea since his appointment. He is, in Gender: male particular, responsible for the ill-treatment of human rights defenders Iryna Danylovych and Amet Suleymanov, who were denied proper medical care for Address: Simferopol, Autonomous several months during their imprisonment in the Simferopol detention centre. Republic of Crimea, Ukraine Therefore, Vadim Bulgakov is responsible for serious human rights violations Associated individuals: Arkady or abuses, namely cruel, inhuman or degrading treatment or punishment, in Alexandrovich Gostev, Director of particular in relation to political prisoners held in detention centres in Crimea. the Russian Federal Penitentiary Service Aleksei Nikolaevich Pikin, Deputy Head of the Directorate of the Russian Federal Penal Enforcement Service for the “Republic of Crimea and the City of Sevastopol” ELI: http://data.europa.eu/eli/reg_impl/2025/1789/oj 3/4 OJ L, 5.9.2025 ENNames (Transliteration into Names Identifying information Reasons for listing Date of listing Latin script) 135. Aleksei Nikolaevich Алексей Николаевич Position: Deputy Head of the Aleksei Pikin is the Deputy Head of the Directorate of the Russian Federal 5.9.2025’ PIKIN ПИКИН Directorate of the Russian Federal Penal Enforcement Service for the “Republic of Crimea and the City of Penal Enforcement Service for the Sevastopol” since May 2016. Within that structure, he holds responsibility for a.k.a. (Russian spelling) “Republic of Crimea and the City of the management and coordination of the regional penal system in Crimea and Alexey Nikolaevich Sevastopol” Sevastopol, including staff conduct, inmate welfare, and the prevention of law PIKIN violations within detention facilities. Given this mandate, he bears DOB: 9.8.1975 responsibility for any human rights violations committed against individuals Nationality: Russian sentenced to imprisonment in Crimea, including abuses by staff, unlawful disciplinary measures, or failure to prevent torture, mistreatment, or denial of Gender: male basic rights within the penal system. He is accountable for widespread and systematic denial of adequate medical care and treatment provision to Address: Voronezh, Voronezh detainees and prisoners, in particular political prisoners. This amounts to Region, Russia cruel, inhuman or degrading treatment. Associated individuals: Arkady Since his appointment as Deputy Head in 2016, widespread and systematic Alexandrovich Gostev, Director of human rights violations in Crimean detention centres have been documented the Russian Federal Penitentiary by the United Nations and the European Court of Human Rights. In particular, Service Vadim Viktorovich the administrative practice of ill-treatment and denial of medical care to Bulgakov, Head of the Directorate of political prisoners, which constitutes an act of cruel, inhuman, or degrading the Russian Federal Penal treatment or punishment, has repeatedly occurred under his authority at the Enforcement Service for the Simferopol detention centre in Crimea since his appointment. He is, in “Republic of Crimea and the City of particular, responsible for the ill-treatment of human rights defenders Iryna Sevastopol” Danylovych and Amet Suleymanov, who were denied proper medical care for several months during their imprisonment in the Simferopol detention centre. Therefore, Aleksei Pikin is responsible for serious human rights violations or abuses, namely cruel, inhuman or degrading treatment or punishment, in particular in relation to political prisoners held in detention centres in Crimea. 4/4 ELI: http://data.europa.eu/eli/reg_impl/2025/1789/oj EN OJ L, 5.9.2025

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