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Official Journal EN
of the European Union L series
2025/2568 15.12.2025
COUNCIL IMPLEMENTING REGULATION (EU) 2025/2568
of 15 December 2025
implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s
destabilising activities
THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union,
Having regard to Council Regulation (EU) 2024/2642 of 8 October 2024 concerning restrictive measures in view of
Russia’s destabilising activities(1), and in particular Article 13(1) thereof,
Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy,
Whereas:
(1) On 8 October 2024, the Council adopted Regulation (EU) 2024/2642.
(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 Regulation (EU) 2024/2642.
(5) Regulation (EU) 2024/2642 should therefore be amended accordingly,
HAS ADOPTED THIS REGULATION:
Article 1
Annex I to Regulation (EU) 2024/2642 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, 15 December 2025.
For the Council
The President
K. KALLAS
(1) OJ L, 2024/2642, 9.10.2024, ELI: http://data.europa.eu/eli/reg/2024/2642/oj.
ELI: http://data.europa.eu/eli/reg_impl/2025/2568/oj 1/14ANNEX
Annex I to Regulation (EU) 2024/2642 is amended as follows:
(1) the following entries are added under the heading ‘A. Natural persons’:
Name Identifying information Statement of Reasons Date of listing
‘48. John Mark DOUGAN Function: former Florida deputy sheriff John Dougan is a former Florida deputy sheriff who fled to Russia in 2016. He is 15.12.2025
publicly accused of participating in pro-Kremlin digital information operations
DOB: 15.12.1976
from Moscow by operating the CopyCop network of fake news websites and
POB: Wilmington, Delaware, United States of supporting Storm-1516 activities. The inauthentic websites mimic legitimate
America media outlets and spread fabricated stories and AI-generated deepfake content.
Reports from Western authorities and independent investigative sources link
Nationality: American, Russian Dougan’s activities to Russia’s military intelligence agency (GRU) and the
Moscow-based think tank the Center for Geopolitical Expertise, suggesting he
Gender: male
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.
2/14
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
EN
OJ
L,
15.12.2025Name Identifying information Statement of Reasons Date of listing
49. Andrey Andreievich Function: Director of the Institute for Andrey Sushentsov is one of the Russia’s key foreign-policy ideologues operating 15.12.2025
SUSHENTSOV International Studies (IIS), Moscow State within the state-academic and think-tank system. His institute (IIS MGIMO) is
Institute of International Relations (MGIMO directly subordinated to the Russian Ministry of Foreign Affairs and closely
(Russian: Андрей Андреевич
University) – a diplomatic academy under the integrated with official diplomatic and strategic planning structures. Sushentsov
СУШЕНЦОВ)
Ministry of Foreign Affairs of the Russian regularly appears in Russian and international media, presenting Russia’s
Federation; Programme Director of the Valdai foreign-policy worldview in line with Kremlin messaging. His commentary
Discussion Club; member of the Council on consistently promotes the following narratives: the West provoked the conflict in
Foreign and Defence Policy (SVOP); frequent Ukraine by expanding NATO and threatening Russia’s security; Russia’s actions are
commentator for Russian state media and defensive and aimed at restoring “strategic balance” in the international system; the
author for Russia in Global Affairs and other “unipolar world order” led by the US is collapsing, and Russia, together with China
Kremlin-aligned outlets and the “Global South”, is constructing a fairer multipolar world; and Western
sanctions are illegitimate and self-destructive, used as tools of coercion against
DOB: 8.6.1983
sovereign states. He frequently represents the Russian perspective at Valdai panels
POB: Orenburg, USSR (now Russian attended by President Vladimir Putin and senior officials, serving as both an
Federation) organiser and a spokesperson for Kremlin-approved messaging.
Nationality: Russian Therefore, Andrey Sushentsov is responsible for or supporting actions or policies
attributable to the Government of the Russian Federation which undermine or
Gender: male 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
INN: 400407010797
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.
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
3/14
OJ
L,
15.12.2025
ENName Identifying information Statement of Reasons Date of listing
50. Dmitry Vyacheslavovich Function: Deputy Director, Centre for Dmitry Suslov is a Russian foreign-policy analyst embedded in institutions closely 15.12.2025
SUSLOV Comprehensive European and International linked to the Kremlin’s policy and messaging apparatus. Through his roles at HSE
Studies (CCEIS), Higher School of Economics University, the Council on Foreign and Defence Policy, and the Valdai Discussion
(Russian: Дмитрий Вячеславович
(HSE University), Moscow; Deputy Director for Club, he regularly participates in high-level discussions shaping and disseminating
СУСЛОВ)
Research Programmes at the Council on Russia’s foreign-policy narratives. He frequently appears as an “independent
Foreign and Defence Policy (SVOP); expert and expert” in Russian state and international media, where he advances positions
frequent speaker at the Valdai Discussion Club; consistent with official Kremlin lines: portraying NATO and the United States as
contributor to Russia in Global Affairs and responsible for provoking the war in Ukraine, framing Western military support to
other Kremlin-aligned publications Kyiv as “escalation” or “direct involvement” in the conflict and justifying Russian
coercive actions as defensive or inevitable responses to Western aggression.
DOB: 15.2.1979
In 2024, Suslov publicly suggested that Russia should consider a “demonstrative
POB: Leningrad, USSR (now Saint Petersburg,
nuclear explosion” to “remind the West of the dangers of nuclear war,” a statement
Russian Federation)
widely reported by Reuters and other outlets. Such remarks normalise the idea of
Nationality: Russian nuclear signalling and coercion, directly contributing to the climate of intimidation
surrounding Russia’s war policy.
Gender: male
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.
4/14
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
EN
OJ
L,
15.12.2025Name Identifying information Statement of Reasons Date of listing
51. Fyodor Aleksandrovich Function: journalist, TV presenter and political Fyodor Lukyanov is a prominent Russian political analyst, foreign-policy 15.12.2025
LUKYANOV scientist; Editor-in-Chief of Russia in Global commentator, and academic closely tied to Kremlin-affiliated think tanks. He is the
Affairs; Research Director of the Valdai Editor-in-Chief of Russia in Global Affairs, one of Russia’s most influential
(Russian: Фёдор Александрович
Discussion Club; member of the Russian foreign-policy journals, and serves as Research Director of the Valdai Discussion
ЛУКЬЯНОВ)
International Affairs Council (RIAC) 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
DOB: 1.2.1967
Affairs Council (RIAC) and often moderates sessions with President Vladimir Putin
POB: Moscow, USSR (now Russian Federation) at Valdai forums.
Nationality: Russian Through his writing, interviews and public appearances, Lukyanov consistently
amplifies Kremlin propaganda, portraying Russia’s war of aggression against
Gender: male 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.
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
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ENName Identifying information Statement of Reasons Date of listing
52. Ivan Nikolaevich TIMOFEEV Function: political scientist, foreign-policy Ivan Timofeev is a prominent Russian political scientist and foreign-policy analyst 15.12.2025
analyst and policy strategist; Director-General closely associated with Kremlin-aligned institutions. He serves as the
of the Russian International Affairs Council Director-General of the Russian International Affairs Council (RIAC) – an
(RIAC); Programme Director of the Valdai organisation established by the Russian Foreign Ministry – and as a Programme
Discussion Club Director of the Valdai Discussion Club, a high-profile platform used by the Russian
leadership, including President Vladimir Putin, to promote official state narratives
DOB: 1983
to domestic and international audiences. Timofeev is also a frequent contributor to
POB: USSR (now Russian Federation) Russia in Global Affairs and a commentator for state media such as TASS and
Izvestia.
Nationality: Russian
Through his writing, interviews and appearances at Valdai forums, Timofeev
Gender: male 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.
6/14
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
EN
OJ
L,
15.12.2025Name Identifying information Statement of Reasons Date of listing
53. Andrey Georgievich Function: journalist, media manager, academic Andrei Bystritskyi’s leadership in Valdai and his media/academic background 15.12.2025
BYSTRITSKYI and think-tank executive; Chairman of the suggest he actively supports and disseminates the official Russian narrative
Board of the Valdai Discussion Club regarding international relations, media control and Russia’s role in global affairs.
(Russian: Андрей Георгиевич
Foundation The Valdai Club is used as a tool of Russian public diplomacy and soft power; by
БЫСТРИЦКИЙ)
managing this body, Bystritskyi contributes to the infrastructure of state narrative
DOB: 21.7.1960
production and dissemination. As dean of a major university faculty
POB: Moscow, USSR (now Russian Federation) (communications/media) and a seasoned media-manager, he is in a position to
shape curricula, research and public discourse around media, communications and
Nationality: Russian state narratives – which can facilitate coordinated information or interference
campaigns. His quotes and speeches reflect and promote Russian diplomatic
Gender: male
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.
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
7/14
OJ
L,
15.12.2025
ENName Identifying information Statement of Reasons Date of listing
54. Vladislav Yevgenevich Function: officer (Senior Lieutenant) of GRU Vladislav Borovkov is a member of GRU (Russia’s military intelligence agency), 15.12.2025
BOROVKOV Unit 29155 Unit 29155, as well as of cyber actor Cadet Blizzard. Borovkov acted in concert
with other Cadet Blizzard members. Furthermore, between December 2020 and
(Russian: Владислав Евгеньевич DOB: 7.10.1997
August 2024, Borovkov took part in cyber attacks against government
БОРОВКОВ)
POB: Russian Federation organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware
on the compromised systems, causing significant damage to Ukraine’s systems.
Nationality: Russian Furthermore the group also targeted Member States of the Union and members of
NATO with the aim of gaining sensitive information and destabilising their
Gender: male
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.
8/14
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
EN
OJ
L,
15.12.2025Name Identifying information Statement of Reasons Date of listing
55. Denis Igorevich DENISENKO Function: officer of GRU Unit 29155 Denis Denisenko is a member of GRU (Russia’s military intelligence agency), Unit 15.12.2025
29155, as well as of cyber actor Cadet Blizzard. Denisenko acted in concert with
(Russian: Денис Игоревич DOB: 14.5.1997
other Cadet Blizzard members. Furthermore, between December 2020 and August
ДЕНИСЕНКО)
POB: Russian Federation 2024, Denisenko took part in cyber attacks against government organisations in
Ukraine. Cadet Blizzard employed WhisperGate wiper malware on the
Nationality: Russian compromised systems, causing significant damage to Ukraine’s systems.
Furthermore the group also targeted Member States of the Union and members of
Gender: male
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.
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
9/14
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L,
15.12.2025
ENName Identifying information Statement of Reasons Date of listing
56. Dmitry Iurevich GOLOSHUBOV Function: officer of GRU Unit 29155 Dmitry Goloshubov is a member of GRU (Russia’s military intelligence agency), 15.12.2025
Unit 29155, as well as of cyber actor Cadet Blizzard. Goloshubov acted in concert
(Russian: Дмитрий Юрьевич DOB: 10.10.1998
with other Cadet Blizzard members. Furthermore, between December 2020 and
ГОЛОШУБОВ)
POB: Russian Federation August 2024, Goloshubov took part in cyber attacks against government
organisations in Ukraine. Cadet Blizzard employed WhisperGate wiper malware
Nationality: Russian on the compromised systems, causing significant damage to Ukraine’s systems.
Furthermore the group also targeted Member States of the Unionand members of
Gender: male
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.
10/14
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
EN
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15.12.2025Name Identifying information Statement of Reasons Date of listing
57. Jacques BAUD Function: former colonel in the Swiss army; Jacques Baud, a former Swiss army colonel and strategic analyst, is a regular guest 15.12.2025
former strategic analyst, intelligence and on pro-Russian television and radio programmes. He acts as a mouthpiece for
terrorism specialist pro-Russian propaganda and makes conspiracy theories, for example accusing
Ukraine of orchestrating its own invasion in order to join NATO.
DOB: 1.4.1955
Therefore, Jacques Baud is responsible for, implementing or supporting actions or
Nationality: Swiss
policies attributable to the Government of the Russian Federation which
Gender: male undermine or threaten stability or security in a third country (Ukraine) by
engaging in the use of information manipulation and interference.
58. Xavier MOREAU Function: former military officer and Xavier Moreau is a businessman and founder of the Stratpol website, and a former 15.12.2025
Franco-Russian businessman; founder of the military officer. He acts as a mouthpiece for pro-Russian and pro-Kremlin
Stratpol website propaganda, spreading conspiracy theories about Russia’s invasion of Ukraine, for
example accusing Ukraine of orchestrating its own invasion in order to join
DOB: 25.10.1971
NATO.
Nationality: French
Therefore, Xavier Moreau is responsible for, implementing or supporting actions
Gender: male 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.
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
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ENName Identifying information Statement of Reasons Date of listing
59. Diana Vitaliivna PANCHENKO DOB: 21.5.1988 Diana Panchenko is a Ukrainian-born journalist and propagandist. She produces 15.12.2025’
(Ukrainian: Діана Віталіївна and diffuses anti-Ukrainian, pro-Russian, anti-NATO narratives.
POB: Mykolaïv, Ukrainian SSR (now Ukraine)
ПАНЧЕНКО)
In her videos, she deliberately mimics news-broadcast formats, in order to
Nationality: Ukrainian, Russian
(Russian: Диана Витальевна legitimise the Kremlin’s narratives. She manipulates information to portray
ПАНЧЕНКО) Gender: female 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.
12/14
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
EN
OJ
L,
15.12.2025(2) the following entries are added under the heading ‘B. Legal persons, entities and bodies’:
Name Identifying information Statement of Reasons Date of listing
‘16. 142nd Separate Electronic 236000, Posyolok Kumachevo, Kaliningrad The 142nd Separate Electronic Warfare Battalion, based in Kaliningrad region, is 15.12.2025
Warfare Battalion region, Russian Federation 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
142-й батальон
disorganise any system of shortwave communication, conducting electronic
радиоэлектронной борьбы
warfare exercises to disrupt enemy navigation and radio communications as well
142-й батальон РЭБ as for the collection and analysis of intelligence information obtained by observing
electromagnetic radiation in the short and ultrashort wave ranges.
142-й отдельный батальон
радиоэлектронной борьбы 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.
ELI:
http://data.europa.eu/eli/reg_impl/2025/2568/oj
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ENName Identifying information Statement of Reasons Date of listing
17. International Russophile The International Russophile Movement is a movement responsible for amplifying 15.12.2025’
Movement destabilising narratives globally, on behalf of the Government of the Russian
Federation. The movement has strong ties with the Russian Ministry of Foreign
(Russian: Международное
Affairs, receiving endorsements for their work. Russian foreign minister Sergey
движение русофилов)
Lavrov has given keynote speeches in congress meetings of the movement. The
(French: Mouvement movement is also associated with the Kremlin’s top ideologue Aleksandr Dugin
International Russophile) 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.
14/14
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15.12.2025