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Date: 2025-11-20 Category: Not Applicable State: Union Government Country: Europe

Council Implementing Regulation (EU) 2025/2356 of 20 November 2025 implementing Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia

Issued by Council of the European Union · Not Applicable

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Executive Summary & Key Takeaways

**Executive Summary** Council Implementing Regulation (EU) 2025/2356, dated 20 November 2025, implements Regulation (EU) 2024/1485. This regulation amends Annex IV of Regulation (EU) 2024/1485 to include 10 additional natural persons to the list of those subject to restrictive measures in view of the situation in Russia. The regulation enters into force upon its publication in the Official Journal of the European Union. **Key Points / Main Content** * **Amendment to Regulation (EU) 2024/1485:** * Annex IV of Regulation (EU) 2024/1485 is amended to include additional individuals. * **New Listings:** * Ten (10) natural persons are added to Annex IV to Regulation (EU) 2024/1485. * The newly listed individuals are: * Andrey Viktorovich POLYAKOV * Andrey Vadimovich MIKHAILICHENKO * Andrey Sergeevich SAPITSKIY * Aleksandr Aleksandrovich SHTODA * Timur Savelevich VAKHRAMEEV * Artemy Alexeevich TELMINOV * Boris Ashirbaevich KOZHEVNIKOV * Maxim Alexandrovich PANIN * Marina Viktorovna USHAKOVA * Svetlana Sergeevna RYGALOVA * **Entry into Force:** * The Regulation enters into force upon publication in the Official Journal of the European Union on 20 November 2025. * The Regulation is binding in its entirety and directly applicable in all Member States. **Impact Analysis** **Member States** * **Impact:** The Regulation is binding and directly applicable in all Member States, requiring them to implement the restrictive measures against the newly listed individuals. * **Action Required:** Member States must ensure that the restrictive measures outlined in Regulation (EU) 2024/1485 are applied to the newly listed individuals as of the date of entry into force. **Listed Individuals** * **Impact:** The listed individuals are subject to restrictive measures, including but not limited to potential asset freezes and travel restrictions within the EU. * **Action Required:** The listed individuals may need to seek legal counsel to understand the implications of the restrictive measures and their options for challenging them. **European Union Institutions** * **Impact:** The Council and other relevant EU institutions are responsible for ensuring the consistent application and enforcement of the Regulation across all Member States. * **Action Required:** The Council must monitor the implementation of the Regulation and take necessary actions to address any instances of non-compliance.

Key Entities Referenced

Regulation (EU) 2024/1485: Council Regulation (EU) 2024/1485 concerns restrictive measures in view of the situation in Russia. Russia: The target location of the restrictive measures. Council Implementing Regulation (EU) 2025/2356: The regulation implementing restrictive measures against individuals in Russia. Brussels: Location where the regulation was adopted.
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Official Journal EN of the European Union L series 2025/2356 20.11.2025 COUNCIL IMPLEMENTING REGULATION (EU) 2025/2356 of 20 November 2025 implementing Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Council Regulation (EU) 2024/1485 of 27 May 2024 concerning restrictive measures in view of the situation in Russia(1), and in particular Article 17(1) thereof, Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy, Whereas: (1) On 27 May 2024, the Council adopted Regulation (EU) 2024/1485. (2) The Union remains unwavering in its condemnation of the human rights violations and repressions in Russia. (3) In view of the gravity of the situation, the Council considers that 10 natural persons should be added to the list of natural and legal persons, entities and bodies set out in Annex IV to Regulation (EU) 2024/1485. (4) Regulation (EU) 2024/1485 should therefore be amended accordingly, HAS ADOPTED THIS REGULATION: Article 1 Annex IV to Regulation (EU) 2024/1485 is amended in accordance with the Annex to this Regulation. 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, 20 November 2025. For the Council The President K. KALLAS (1) OJ L, 2024/1485, 27.5.2024, ELI: http://data.europa.eu/eli/reg/2024/1485/oj. ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj 1/11ANNEX The following entries are added to Annex IV to Regulation (EU) 2024/1485 under the heading ‘A. Natural persons’: Name Identifying information Statement of Reasons Date of listing ‘53. Andrey Viktorovich POLYAKOV Position: Head of the Main Directorate of the Andrey Polyakov is the Head of the Main Directorate of the Federal Penitentiary 20.11.2025 Federal Penitentiary Service of the Russian Service of the Russian Federation for the Rostov Oblast, including pre-trial detention (Андрей Викторович ПОЛЯКОВ) Federation for the Rostov Oblast, Major General centre in Taganrog (SIZO-2), pre-trial detention centre 1 in Rostov-on-Don (SIZO-1), of Internal Service and colony No. 12 in Kamensk Shakhtinsky. DOB: 17.6.1970 In his position, he is responsible for ensuring the protection of the rights of detainees and their safety and for the maintenance of law and order in the subordinate Nationality: Russian detention facilities he oversees. In the facilities under Polyakov’s authority, Ukrainian Gender: male detainees, both civilian and military, as well as other detainees were regularly subjected to beatings by guards, suffered from severe food shortages, and had little to Passport number: series 1815 No 112026 no access to medical care or legal assistance. During interrogations, they faced both psychological and physical coercion, including brutal beatings, electric shocks, and INN (Russian Tax ID): 343517128461 threats, with the aim of forcing them to confess to alleged war crimes, crimes of terrorism, or other offences. The documented instances of torture and ill-treatment include the case of the Ukrainian investigative journalist Victoria Volodymyrivna Roshchyna who died in September 2024 as a result of ill-treatment in Pre-Trial Detention Centre No. 2 of the Main Directorate of the Federal Penitentiary Service for the Rostov Oblast in Taganrog. Therefore, Andrey Polyakov is responsible for serious human rights violations, namely torture and other cruel, inhuman or degrading treatment, for the repression of civil society and for activities seriously undermining the rule of law in Russia. 2/11 ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj EN OJ L, 20.11.2025Name Identifying information Statement of Reasons Date of listing 54. Andrey Vadimovich Position: Deputy Director for Security and Andrey Mikhailichenko serves as Deputy Director for Security and Operational Work 20.11.2025 MIKHAILICHENKO Operational Work of Pre-Trial Detention Centre of Pre-Trial Detention Centre No. 2 of the Main Directorate of the Federal Penitentiary No. 2 of the Main Directorate of the Federal Service for the Rostov Oblast (SIZO-2) in Taganrog, Russia. As a member of the (Андрей Вадимович Penitentiary Service for the Rostov Oblast, management of SIZO-2 Mikhailichenko is responsible for widespread and systematic МИХАЙЛИЧЕНКО) Russian Federation torture and other cruel, inhuman and degrading treatment of Ukrainian detainees, both civilian and military, as well as other detainees held in that facility. DOB: 31.3.1992 Detainees in SIZO-2 are regularly subjected to beatings by guards, suffer from severe Nationality: Russian food shortages, and have little to no access to medical care or legal assistance. During Gender: male interrogations, detainees face both psychological and physical coercion, including brutal beatings, electric shocks, and threats, with the aim of forcing them to confess Passport number: Series 6012 No 175625 to alleged war crimes, crimes of terrorism, or other offences all intended to crush resistance to Russia’s aggression against Ukraine. This treatment represents a serious INN (Russian Tax ID): 615490520223 violation or abuse of human rights and is a violation of the principle of rule of law. At least 15 detainees have died as a result of ill-treatment in the facility, including Ukrainian investigative journalist Victoria Volodymyrivna Roshchyna. As Deputy Director for Security and Operational Work of SIZO-2, Andrey Mikhailichenko bears responsibility for the facility’s operations. He is therefore responsible for serious human rights violations, repression of civil society and for activities seriously undermining the rule of law in Russia. ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj 3/11 OJ L, 20.11.2025 ENName Identifying information Statement of Reasons Date of listing 55. Andrey Sergeevich SAPITSKIY Position: Deputy Director for Personnel and Andrey Sapitskiy, serves as Deputy Director for Personnel and Educational Work 20.11.2025 Educational Work Issues of Pre-Trial Detention Issues of Pre-Trial Detention Centre No. 2 of the Main Directorate of the Federal (Андрей Сергеевич САПИЦКИЙ) Centre No. 2 of the Main Directorate of the Penitentiary Service for the Rostov Oblast (SIZO-2) in Taganrog, Russia. As a member Federal Penitentiary Service for the Rostov of the management of SIZO-2, Sapitskiy is responsible for widespread and systematic Oblast, Russian Federation torture and other cruel, inhuman, and degrading treatment of Ukrainian detainees, both civilian and military, as well as other detainees held in that facility. Nationality: Russian Detainees in SIZO-2 are regularly subjected to beatings by guards, suffer from severe Gender: male food shortages, and have little to no access to medical care or legal assistance. During interrogations, detainees face both psychological and physical coercion, including brutal beatings, electric shocks, and threats, with the aim of forcing them to confess to alleged war crimes, crimes of terrorism, or other offences all intended to crush resistance to Russia’s aggression against Ukraine. This treatment represents a serious violation or abuse of human rights and is a violation of the principle of rule of law. At least 15 detainees have died as a result of ill-treatment in the facility, including Ukrainian investigative journalist Victoria Volodymyrivna Roshchyna. As Deputy Director for Personnel and Educational Work Issues of SIZO-2, Andrey Sapitskiy bears responsibility for the facility’s operations. He is therefore responsible for serious human rights violations, repression of civil society, and activities seriously undermining of rule of law in Russia. 4/11 ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj EN OJ L, 20.11.2025Name Identifying information Statement of Reasons Date of listing 56. Aleksandr Aleksandrovich Position: Director of Pre-Trial Detention Centre Aleksander Shtoda, serves as Director of Pre-Trial Detention Centre No. 2 of the Main 20.11.2025 SHTODA No. 2 of the Main Directorate of the Federal Directorate of the Federal Penitentiary Service for the Rostov Oblast (SIZO-2) in Penitentiary Service for the Rostov Oblast, Taganrog, Russia. Shtoda is responsible for widespread and systematic torture and (Александр Александрович Russian Federation other cruel, inhuman, and degrading treatment of Ukrainian detainees, both civilian ШТОДА) and military, as well as other detainees held in the facility under his command. DOB: 19.11.1980 Detainees in SIZO-2 are regularly subjected to beatings by guards, suffer from severe Nationality: Russian food shortages, and have little to no access to medical care or legal assistance. During Passport number: series 6001 No419633 interrogations, detainees face both psychological and physical coercion, including brutal beatings, electric shocks, and threats, with the aim of forcing them to confess INN (Russian Tax ID): 611903638423 to alleged war crimes, crimes of terrorism, or other offences all intended to crush resistance to Russia’s aggression against Ukraine. This treatment represents a serious violation or abuse of human rights and is a violation of the principle of rule of law. At least 15 detainees have died as a result of ill-treatment in the facility, including Ukrainian investigative journalist Victoria Volodymyrivna Roshchyna. As Director of SIZO-2, Aleksander Shtoda holds authority over the facility’s operations. He is therefore responsible for serious human rights violations, repression of civil society, and activities seriously undermining the rule of law in Russia. ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj 5/11 OJ L, 20.11.2025 ENName Identifying information Statement of Reasons Date of listing 57. Timur Savelevich Position: Judge of Basmanny District Court, Timur Vakhrameev, a judge at the Basmanny District Court in Russia, has been 20.11.2025 VAKHRAMEEV Moscow; FormerMagistrate (Justice of the involved in a number of politically motivated prosecution cases, imposing Peace) in Tagansky district of Moscow disproportionately harsh sentences on several individuals and extending the detention (Тимур Савельевич ВАХРАМЕЕВ) of others. DOB: 13.5.1990 Judge Vakhrameev participated in the unjust and politically motivated prosecution of Nationality: Russian journalists Kirill Martynov and Dmitry Kolezev, as well as activist Lyusya Shtein, Gender: male sentencing each of them to several years in prison in an effort to silence independent journalism and civil society in Russia. He also extended the pre-trial detention of lawyers Vadim Kobzev and Alexey Liptser, as well as journalists Konstantin Gabov and Sergei Karelin, in politically motivated cases related to crackdowns on individuals associated with the Anti-Corruption Foundation or Alexei Navalny himself. Additionally, he prolonged the pre-trial detention of Grigory Melkonyants, co-chairman of the Golos movement, Russia’s key independent election watchdog initiative, in an apparent attempt to exert additional pressure on public election monitoring in the country. In all of the aforementioned cases, controversial articles of the Russian Criminal Code on undesirable organisations, discrediting the Russian army, or extremism were applied. Moreover, earlier in 2023, while serving as a justice of the peace in Moscow’s Tagansky District, Timur Vakhrameev also played an active role in penalising international companies such as Wikimedia and Google for failing to remove factual information about Russia’s war of aggression against Ukraine. Timur Vakhrameev is therefore responsible for serious human rights violations, the repression of civil society and democratic opposition and activities seriously undermining democracy and the rule of law in Russia. 6/11 ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj EN OJ L, 20.11.2025Name Identifying information Statement of Reasons Date of listing 58. Artemy Alexeevich TELMINOV Position: Investigator of the Investigative Artemy Telminov serves as an Investigator of the Investigative Committee of the 20.11.2025 Committee of the Russian Federation Russian Federation, and has been involved in a number of politically motivated (Артемий Алексеевич prosecutions of individuals associated with Alexei Navalny, including, journalists ТЕЛЬМИНОВ) DOB: 30.12.1994 Antonina Favorskaya, Olga Komleva, Konstantin Gabov, and Sergey Karelin, as well as Nationality: Russian lawyers Vadim Kobzev, Alexei Liptser, and Igor Sergunin. By advocating for the imposition or extension of their detention, he has actively contributed to the Russian Gender: male regime’s efforts to suppress dissent within the country. All of the individuals mentioned above were investigated and subsequently charged with participation in an extremist community or organisation, or with involvement in its activities. In reality, these charges were based solely on their lawful actions while associated with Alexei Navalny and his Anti-Corruption Foundation. The misuse of legislation related to terrorism and extremism to suppress political opposition and peaceful civil society efforts linked to Navalny has become a widespread practice in Russia. All of the aforementioned cases exhibit a consistent pattern of politically motivated prosecution, including prolonged pre-trial detention and, in some instances, closed court proceedings. Artemy Telminov’s active role in orchestrating the unjust prosecution of Antonina Favorskaya, Olga Komleva, Konstantin Gabov, Sergey Karelin, Vadim Kobzev, Alexei Liptser, and Igor Sergunin constitutes a grave violation of human rights. Therefore, he is directly responsible for serious human rights abuses and for the repression of civil society and democratic opposition in Russia. ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj 7/11 OJ L, 20.11.2025 ENName Identifying information Statement of Reasons Date of listing 59. Boris Ashirbaevich Position: Deputy Chairman of the Appellate Boris Kozhevnikov is a Deputy Chairman of the Appellate Military Court of Russia. 20.11.2025 KOZHEVNIKOV Military Court of Russia As deputy chairman of the Appellate Military Court of Russia, Boris Kozhevnikov (Борис Аширбаевич DOB: 31.8.1964 rejected the appeal of Alexei Gorinov, a former municipal deputy in the Krasnoselsky КОЖЕВНИКОВ) district of Moscow, against a politically motivated sentence. In a procedurally flawed Nationality: Russian trial, Alexei Gorinov was sentenced to three years’ imprisonment in a strict regime Gender: male penal colony under Article 205.2 of the Russian Criminal Code for “justification of terrorism”. Alexei Gorinov’s sentence was based on statements he made in a conversation with his cellmates in which he allegedly recognised that Crimea was Ukrainian territory and the Azov regiment was part of the Ukrainian army. Furthermore, Kozhevnikov upheld the sentences of imprisonment for Andrei Boyarshinov, Ibragim Orudzhev, Alexei Nuriev and Roman Nasryev on politically motivated charges in alleged terrorism related cases. Therefore, Boris Kozhevnikov is responsible for serious violations of human rights, including violating freedom of opinion and expression, for the repression of civil society and democratic opposition, and for activities which seriously undermine the rule of law in Russia. 8/11 ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj EN OJ L, 20.11.2025Name Identifying information Statement of Reasons Date of listing 60. Maxim Alexandrovich PANIN Position: Judge of the Appellate Military Court Maksim Panin is a judge of the Appellate Military Court of Russia. 20.11.2025 of Russia (Judicial Panel for Criminal Cases) (Максим Александрович As a member of the panel of judges of the Appellate Military Court of Russia, Maksim ПАНИН) DOB: 22.2.1982 Panin rejected the appeal of Alexei Gorinov, a former municipal deputy in the Krasnoselsky district of Moscow, against a politically motivated sentence. In Nationality: Russian a procedurally flawed trial, Alexei Gorinov was sentenced to three years’ Gender: male imprisonment in a strict regime colony under Article 205.2 of the Russian Criminal Code for “justification of terrorism”. Alexei Gorinov’s sentence was based on statements he made in a conversation with his cellmates in which he allegedly recognised that Crimea was Ukrainian territory and the Azov regiment was part of the Ukrainian army. Furthermore, Panin participated in politically motivated prosecutions of other individuals. As a member of the appellate panel, he upheld the conviction of Elena Kotenochkina, who was accused of “justifying terrorism” through a social media post and sentenced, in absentia, to six years and eleven months in a penal colony. Panin also confirmed the extension of the detention period in the cases of Polina Yevtushenko, prosecuted for spreading “fake news” about the Russian army and “rehabilitation of Nazism”, and Enver Krosh, Rinat Aliev and Vilen Temeryanov, Crimean Tatars prosecuted for their alleged involvement in an Islamic group banned in Russia. Therefore, Maksim Panin is responsible for serious violations of human rights, including violating freedom of opinion and expression, for the repression of civil society and democratic opposition, and for activities which seriously undermine the rule of law in Russia. ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj 9/11 OJ L, 20.11.2025 ENName Identifying information Statement of Reasons Date of listing 61. Marina Viktorovna USHAKOVA Position: Judge of the Appellate Military Court Marina Ushakova is a judge of the Appellate Military Court of Russia. 20.11.2025 of Russia (Judicial Panel for Criminal Cases) (Марина Викторовна As a member of the appellate panel of judges of the Appellate Military Court of УШАКОВА) DOB: 2.5.1979 Russia, Marina Ushakova rejected the appeal of Alexei Gorinov, a former municipal deputy in the Krasnoselsky district of Moscow, against a politically motivated Nationality: Russian sentence. In a procedurally flawed trial, Alexei. Gorinov was sentenced to three years’ Gender: female imprisonment in a strict regime colony under Article 205.2 of the Russian Criminal Code for “justification of terrorism”. Alexei Gorinov’s sentence was based on statements he made in a conversation with his cellmates in which he allegedly recognised that Crimea was Ukrainian territory and the Azov regiment was part of the Ukrainian army. Furthermore, Ushakova upheld the convictions of Nikita Tushkanov, Daniil Bondarenko and Stanislav Shevchenko, based on politically motivated charges of “justifying terrorism” in their statements on social media or in private conversations regarding, in particular, the Crimean Bridge explosion. Therefore, Marina Ushakova is responsible for serious violations of human rights, including violating freedom of opinion and expression, for the repression of civil society and democratic opposition, and for activities which seriously undermine the rule of law in Russia. 10/11 ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj EN OJ L, 20.11.2025Name Identifying information Statement of Reasons Date of listing 62. Svetlana Sergeevna RYGALOVA Position: Prosecutor of the Criminal Judicial Svetlana Rygalova, serving as a prosecutor of the Prosecutor’s Office of the Vladimir 20.11.2025’ Department of the Prosecutor’s Office of Region, participated in the politically motivated prosecution of Alexei Gorinov, (Светлана Сергеевна РЫГАЛОВА) Vladimir Region, Junior Justice Counsellor a former municipal deputy in the Krasnoselsky district of Moscow, for expressing his opinion related to Russia’s war of aggression against Ukraine. Nationality: Russian Prosecutor Rygalova approved the indictment in a criminal case and led the Gender: female prosecution of Alexei Gorinov under Article 205.2 of the Russian Criminal Code for “justification of terrorism”, proposing that he be sentenced to three and a half years of imprisonment. The prosecution’s case was based on statements Gorinov made in a conversation with his cellmates in which he allegedely recognised that Crimea was Ukrainian territory and the Azov regiment was part of the Ukrainian army. On the basis of Rygalova’s indictment, Gorinov was sentenced to three years of imprisonment. Therefore, Svetlana Rygalova is responsible for serious violations of human rights, including violating freedom of opinion and expression, for the repression of civil society and democratic opposition, and for activities seriously undermining the rule of law in Russia. ELI: http://data.europa.eu/eli/reg_impl/2025/2356/oj 11/11 OJ L, 20.11.2025 EN

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