The List Moscow Wrote

The European Union added 1,569 names to its Russia sanctions list on Monday 12 October, 826 companies and 743 people, in a single legal act adopted by foreign ministers meeting in Luxembourg. The Moscow Times called it a record expansion. The act itself, Council Implementing Regulation (EU) 2026/2281, is more interesting for where the names came from. Almost all of the work of choosing them was done in Moscow.

The regulation says so in its recitals. “The entities concerned appear in a list recently established by the Government of the Russian Federation that identifies them as belonging to the Russian military-industrial complex, and they are therefore entitled to receive subsidies from the Government of the Russian Federation.” The people listed are their executives, mostly general directors. The Council’s reasoning, in the regulation’s words, is that the entities “are therefore forming part of Russia’s military and industrial complex,” and that the executives “are therefore supporting” it.

One reason, 1,569 times

Each of the 1,569 entries in the annex gives the same ground in nearly the same words. A typical company entry reads that it “has been identified by the Government of the Russian Federation as being part of the Russian military-industrial complex,” and that, “as an employer identified as being active in the Russian military-industrial complex,” it “is entitled to receive federal subsidies for the housing costs of its employees.” The personal entries name the company a person runs and repeat its reason. A count of the annex by this publication found the housing-subsidy wording in every entry.

That is a different kind of evidence from the files behind most EU listings, which describe a particular contract, shipment or role. Here the evidence is the Russian state’s own classification, made for a domestic purpose: deciding which employers’ staff qualify for help with housing. The EU has adopted that classification as its finding. It is an efficient method. It also means the list is as good as the Russian document behind it, and that a company on that document for its housing scheme is on the EU’s for its war.

The regulation entered into force on the day of publication in the Official Journal, 12 October, and is signed for the Council by K. Kallas, the EU’s foreign-policy chief, who chairs the Foreign Affairs Council. A parallel Council Decision (CFSP) 2026/2279 amends the decision that underpins the regime.

What a listing does

The regulation amends Annex I to Regulation (EU) No 269/2014, the list of people and entities whose funds and economic resources in the EU are frozen and to whom no funds may be made available; listed individuals are also barred from entering or transiting EU territory. The Moscow Times reported the EU’s description of the companies as the “core” of Russia’s military industry, employing more than a quarter of a million people, with an annual turnover of at least €20 billion. Those figures are the EU’s, as reported; they do not appear in the regulation.

It is a list, not a package of economic measures. None of the acts published in the Official Journal on 12 October amends Regulation (EU) No 833/2014, which carries the EU’s trade and financial restrictions on Russia. At least one outlet described Monday’s action as a numbered sanctions package; the published texts do not support that. They add names. They do not ban a product or close a market.

The other two lists

Ministers adopted two smaller acts the same day. Implementing Regulation (EU) 2026/2292 adds 77 people over the elections to the Russian State Duma held in September 2026 in the occupied territories of Ukraine, which the regulation says breached Ukrainian and international law. The Moscow Times described them as 74 Duma lawmakers and three members of Russia’s Central Election Commission. The annex is more specific: three entries are members of the Central Election Commission, and most of the rest are candidates in those elections, many of them deputies of occupation bodies such as the so-called People’s Council of the Donetsk People’s Republic or the State Council of Crimea, standing for United Russia, the Liberal Democratic Party, the Communists, Just Russia and New People.

A third act, Implementing Regulation (EU) 2026/2278, adds three people and four entities to the separate North Korea regime. The Moscow Times linked them to North Korea’s military and economic cooperation with Russia. The regulation’s stated ground is narrower: assisting in the evasion of UN sanctions and supporting North Korea’s nuclear and ballistic-missile programmes.

Who decided

The common foreign and security policy decisions behind EU sanctions require the unanimous agreement of the Council, so all twenty-seven governments accepted Monday’s list. The Moscow Times reported that EU envoys agreed the measures the previous week and ministers adopted them formally on Monday. None of the reporting reviewed for this article described any government’s conditions.

The listing follows a week in which Washington moved the other way: on Friday 9 October, three weeks after the President signed a Russia sanctions law, the Treasury issued a temporary licence for Russian diesel. The EU’s answer was to take a list Moscow had drawn up to subsidise its defence workers’ housing and turn it into an asset freeze. If the Russian government revises that list, the EU’s version will not change with it. The Council will have to decide again.