Date: 2025-09-05Category: Not ApplicableState: Union GovernmentCountry: 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
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.
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:
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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.
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