In brief

  • The Council of the European Union has added a new name to the list of restrictive measures linked to Russia’s destabilising activities: Xenia Vladimirovna Fedorova, former president and head of information of Russia Today France between 2017 and 2022. This is entry 81 in the section for natural persons, so the list now reaches 81 natural persons and 20 legal persons, entities and bodies, 101 entries in all. It is a new listing, not an update of identifying information.
  • The effects in Romania are three: funds and economic resources are frozen, nobody may any longer make money or resources available to her, and her entry into and transit through the country are to be prevented. The freezing comes from Regulation (EU) 2024/2642, the entry ban from Decision (CFSP) 2024/2643, and both apply to any company registered in Romania and to any Romanian national, including outside the Union.
  • Since December 2025, breaching a European sanction is no longer merely an administrative offence in Romania. Government Emergency Ordinance no. 202/2008 now punishes with imprisonment of 1 to 5 years the making available of funds and the failure to freeze them, and from EUR 100,000 upwards the penalty rises to 2 to 7 years. The administrative fine, where the act is not a criminal offence, goes up to 100,000 lei.
Act: Council Implementing Regulation (EU) 2026/2165 of 24 September 2026 implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities
Published: Official Journal of the European Union, L series, 2026/2165 of 24 September 2026
In force from: 24 September 2026, that is, on the day of publication, under Article 2 of the regulation

On 24 September 2026 the Council of the European Union adopted two acts that say exactly the same thing, in two different instruments, and that add a single name to the list of sanctions for Russia’s hybrid threats. The mechanism is the same as the one used for the one-week extension of the European sanctions linked to Ukraine, with one substantive difference: there a deadline was being moved, here a person is being added, and the consequences begin on the day of publication. The name is Xenia Vladimirovna Fedorova, born on 26 December 1980, a Russian national, and the reason given in the act is her participation in information manipulation and interference in France and in the Union.

The two acts are Council Implementing Regulation (EU) 2026/2165, adopted on the basis of Article 13(1) of Regulation (EU) 2024/2642, and Council Decision (CFSP) 2026/2164, adopted on the basis of Article 29 of the Treaty on European Union, which amends Decision (CFSP) 2024/2643. The split is not a formality. The decision is the common foreign and security policy basis and is the act that obliges Member States to prevent the person’s entry into, or transit through, their territories, while the regulation is the instrument that makes the freezing of funds directly applicable in all Member States, with no national implementing measure. The annexes to the two acts are identical, word for word, including the column with the date of listing, 24 September 2026.

The statement of reasons in the annex runs to five paragraphs and follows a professional career. Xenia Fedorova joined Russia Today in 2005, headed the Berlin-based video news agency Ruptly from 2015 to 2017, and in 2017 became president and head of information of RT France. After RT’s broadcasting activities were suspended in the Union, the act says that she went on putting out in the French media discourse aligned with that promoted by the Russian authorities: that Western support for Ukraine prolongs the war, that Russia seeks peace while Europe looks for confrontation, and she disputed the generally accepted accounts of the unlawful transfer and deportation of Ukrainian children. Since 2025 she has been working with CNews, Europe 1 and Le JDNews, and in July 2026 the French authorities adopted an expulsion order against her.

What it changes in practice

The first effect is the freezing, and it takes place of its own accord. Article 2(1) of Regulation (EU) 2024/2642 freezes all funds and economic resources belonging to, owned, held or controlled by the listed person, and Article 2(2) prohibits making funds or economic resources available, directly or indirectly, to her or for her benefit. There is no intervening Romanian decision: the regulation applies directly, and the bank, the notary, the estate agent or the company about to make a payment has to stop from 24 September 2026.

The second effect concerns who is bound by the prohibition. Article 19 of the regulation sets its reach: within the territory of the Union, including its airspace; on board any aircraft or vessel under the jurisdiction of a Member State; to any natural person who is a national of a Member State, whether inside or outside the Union; to any legal person incorporated or constituted under the law of a Member State; and to any legal person in respect of any business done in whole or in part within the Union. The practical result: a Romanian company cannot conclude the contract through a subsidiary outside the Union either, and a Romanian national cannot make the payment even if he works in another country.

The third effect is the duty to report. Article 8(1) of the regulation requires any natural or legal person to supply immediately to the competent authority of the State where they reside or are established any information that would facilitate compliance with the regulation, including data on accounts and amounts frozen, and to cooperate in verifying it. In Romania, the domestic mechanism is written into Government Emergency Ordinance no. 202/2008, approved with amendments by Law no. 217/2009: Article 18(1) requires persons who report suspicious transactions under the anti-money-laundering legislation to apply customer due diligence measures in order to establish whether designated persons are among their customers, and Article 18(2) sends the report immediately to the National Agency for Fiscal Administration and to the supervisory authorities listed in Article 17(1), among them the National Office for Prevention and Control of Money Laundering. Romania’s contact authority for this regulation is the Ministry of Foreign Affairs, under Annex II to Regulation (EU) 2024/2642.

The fourth effect is the entry ban. Article 1(1) of Decision (CFSP) 2024/2643 requires Member States to take the measures necessary to prevent the entry into, or transit through, their territories of the persons in Annex I, so through Romania’s airports and border crossing points as well. The ban is not absolute: Article 1(2) relieves a State of the obligation to refuse entry to its own nationals, and Article 1(3) to (7) provide derogations for the obligations of international law of the host State of an international organisation, for urgent humanitarian reasons, for intergovernmental meetings and for judicial proceedings, including surrender and extradition. Any derogation is to be notified to the Council in writing.

The fifth effect is borne by the listed person. Article 9(2)(a) of the regulation requires her to report, within six weeks of the date of listing, the funds and economic resources within the jurisdiction of a Member State that belong to her or are under her control, to the competent authority of the State where they are located. The deadline, calculated by us from 24 September 2026, falls on 5 November 2026. Article 9(3) says that failing to comply with that obligation is regarded as participation in the circumvention of the measures, that is, it falls under the same regime as a direct breach.

What has changed compared with the previous situation

The length of the list has changed. Until 24 September 2026, the section for natural persons in Annex I stopped at entry 80, held by Ivan Sergeevich Kasyanenko, added on 13 July 2026 by Decision (CFSP) 2026/1707 and by the corresponding implementing regulation. The numbering has no gaps, so entry 81 is indeed the 81st natural person. Adding the 20 entries in the section for legal persons, entities and bodies, the regime created on 8 October 2024 reaches 101 entries after 716 days.

The type of identifying information has changed as well. The new entry is the first on this list whose identification column contains the addresses of personal accounts on social media platforms, an X account and an Instagram account. Article 14(2) of the regulation lists the information that may appear in Annex I: names and aliases, date and place of birth, nationality, passport and identity card numbers, gender, address if known, and function or profession. The list is open-ended, because the text says that the information „may include”, so account addresses contradict nothing. On the other hand, entry 81 lacks the place of birth, the passport number and the identification number, which appear at most of the other entries.

In Romanian law something else has changed in the meantime, and that is where the most concrete part of this listing comes from. Until December 2025, breaching a European sanction was an administrative offence in Romania, with a fine between 10,000 and 30,000 lei. Law no. 224/2025, published in Official Gazette of Romania (Monitorul Oficial), Part I, no. 1164 of 16 December 2025, raised the fine to 10,000-100,000 lei and introduced into Government Emergency Ordinance no. 202/2008 a new chapter of criminal offences, transposing Directive (EU) 2024/1226. Article 271(1) punishes with imprisonment of 1 to 5 years and a ban on the exercise of certain rights, among other things, making funds or economic resources available to a designated person, failing to comply with the freezing obligation, allowing a designated person to enter or transit Romania, supplying financial or other services, and circumvention by concealment. Article 271(2) raises the penalty to imprisonment of 2 to 7 years if the funds involved reach the equivalent of at least EUR 100,000, and Article 271(9) takes out of the scope of the offence acts committed for humanitarian assistance, in accordance with the principles of impartiality, humanity, neutrality and independence.

Advantages and disadvantages

What it improves

  • The measure is operational at once, with no national intermediary: the regulation applies directly from the day of publication, so there is no window in which funds could move while States transpose.
  • The two instruments are perfectly aligned. The annexes are identical word for word, so there is no repeat of the situation, familiar from other regimes, in which a person is listed in one act and not in the other.
  • The statement of reasons is detailed, with functions, periods and media outlets named, which gives the listed person concrete material to challenge and makes it easier for the Council to defend itself before the Court of Justice.
  • The regulation protects the operator acting in good faith: Article 10 removes the liability of anyone who freezes funds believing they are complying with the regulation, except in case of negligence, and Article 11 blocks the listed person’s claims for damages over contracts affected by the sanction.
  • The new Romanian provisions contain an express safety valve: Article 271(9) of Government Emergency Ordinance no. 202/2008 takes humanitarian assistance activities out of the scope of the offence, and Article 276 gives whistleblower protection to those who report breaches.

What remains a problem

  • The identifying information is thin for an effect this heavy. With no place of birth, no passport number and no address, a Romanian bank checks a name, a date of birth and two account addresses, while failing to comply with the freezing obligation has become an offence punishable by imprisonment.
  • The foreign policy act of the regime applies, under the first paragraph of Article 10 of Decision (CFSP) 2024/2643 as worded by Decision (CFSP) 2025/2019, until 9 October 2026, that is, 15 days after this listing. Failing an extension decided by the Council, the entry ban falls away, although the regulation has no deadline of its own.
  • The act nowhere indicates the criterion in Article 2(3) on which the listing rests. The reader infers it from the closing formula of the statement of reasons, which reproduces point (a)(iv), on information manipulation and interference.
  • Notification of the measure to the person concerned is made, under Article 13(2), directly if the address is known or by publishing a notice. Since the annex contains no address, only the notice route remains, and the six-week deadline for reporting funds runs in any event from the date of listing, not from notification.
  • The regulation requires every natural and legal person to report „immediately”, without saying to whom, in the case of an operator who does not fall within the categories of the anti-money-laundering legislation. Article 18 of Government Emergency Ordinance no. 202/2008 is written for reporters of suspicious transactions, and for everyone else what remains is the general duty to notify under Article 7(1), which likewise does not say which authority is to be addressed, but leaves the institution notified to redirect the notification within 24 hours.

Practical advice

  1. If you have compliance obligations, update your screening list with entry 81 on the day of publication, not at the next periodic review. The regulation applies from 24 September 2026 and provides for no grace period for IT systems.
  2. Check controlled legal persons as well. Article 2(1) also freezes funds held or controlled by the listed person, so a company in which she has control falls under the measure even if it is not itself on the list.
  3. Do not pay through third parties either. The prohibition in Article 2(2) covers making funds available indirectly and for the person’s benefit, and Article 9(1) prohibits taking part in activities whose object or effect is circumvention, including where you merely accept that this effect is possible.
  4. If you find funds or resources falling under the measure, report immediately to the National Agency for Fiscal Administration and to your supervisory authority, with the data on persons, contracts and accounts and with the total value of the assets, as required by Article 18(2) of Government Emergency Ordinance no. 202/2008. The duty to notify under Article 7(1) of the same ordinance falls on anyone holding data about the designated person, and failing to comply with it is an administrative offence distinct from the substantive act, under Article 26(1)(b).
  5. If the payment was already due, do not set it off and do not enforce it against a guarantee. Article 11 of the regulation blocks the listed person’s claims relating to contracts affected by the measures, and the burden of proving that a claim is not prohibited falls on the person making it.
  6. For derogations, apply to the competent authority and avoid reading the text for yourself. The regulation allows certain funds to be released for basic needs and in the other situations it lists, but only with the prior authorisation of the competent authority of the Member State.
  7. Consult the consolidated list of the Union’s financial sanctions, which the Commission updates under Article 16(1)(c), instead of working from the text of a single published act. A new listing appears there together with the other 100 entries of the regime.

Frequently asked questions

Why are there two acts for the same name?
One of them, Decision (CFSP) 2026/2164, amends the common foreign and security policy act, the basis of the entry and transit ban, while Implementing Regulation (EU) 2026/2165 amends the act that makes the freezing of funds directly applicable in all Member States. The decision is adopted on the basis of Article 29 of the Treaty on European Union, the regulation on the basis of Article 13(1) of Regulation (EU) 2024/2642. Their annexes are identical.
Is the listing new, or just an update of the data?
It is new. Entry 81 is added in the section for natural persons of Annex I, and until 24 September 2026 the list stopped at entry 80. It is not a correction of a name, a date of birth or a function at an existing entry.
What does a company in Romania have to do?
Check whether it has business relationships, accounts, contracts or payments connected with the listed person or with an entity controlled by her, stop making any funds or resources available, and report immediately anything it finds. If it falls within the categories of the anti-money-laundering legislation, the report goes to the National Agency for Fiscal Administration and to the supervisory authority, under Article 18 of Government Emergency Ordinance no. 202/2008.
What does someone who ignores the measure risk?
In Romania, the act may be a criminal offence. Article 271(1) of Government Emergency Ordinance no. 202/2008, introduced by Law no. 224/2025, provides for imprisonment of 1 to 5 years and a ban on the exercise of certain rights for making funds available, for failing to comply with the freezing obligation and for supplying financial or other services, and the penalty rises to 2 to 7 years if the value involved reaches the equivalent of EUR 100,000. Where the act is not a criminal offence, the administrative fine runs from 10,000 to 100,000 lei, with the possible suspension of the authorisation for 1 to 6 months.
Can she enter Romania?
No, as a matter of principle. Article 1(1) of Decision (CFSP) 2024/2643 requires Member States to prevent the entry into, or transit through, their territories of the persons in Annex I. There are limited derogations, among others for urgent humanitarian reasons, for intergovernmental meetings and for judicial proceedings, including surrender and extradition, and each derogation is to be notified to the Council in writing.
How long does she stay on the list?
The regulation lays down no deadline for an individual listing, but Article 13(4) requires Annex I to be reviewed periodically, at least every 12 months. Decision (CFSP) 2024/2643 applies, as worded by Decision (CFSP) 2025/2019, until 9 October 2026, so the foreign policy part of the regime needs an extension from the Council in order to continue.
Can it be challenged?
Yes. Article 13(2) of the regulation provides for the decision and the reasons to be communicated, directly or by publishing a notice, with the possibility of submitting observations, and Article 13(3) obliges the Council to review its decision if substantial new observations or evidence are put forward. An action for annulment before the Court of Justice of the European Union also remains open.

Editorial analysis

The listing is technically orderly and well reasoned on the substance: five paragraphs of statement of reasons, dated functions, named media outlets, plus an expulsion order adopted by the French authorities in July 2026, so an element verifiable outside the Council’s file. For a one-page act, the evidential density is greater than in many listings under the older regimes. The problem lies not in the reasoning, but in the ratio between what is asked of those who apply the measure and what they are given in order to apply it.

The observation that cannot be seen by reading the act from start to finish emerges from the comparison with the other entries in the same annex. Entry 81 has a name, a transcription in the Cyrillic alphabet, a function, a date of birth, nationality, gender and the addresses of two accounts on social media platforms. It has no place of birth, no passport number and no tax identification number. Entry 1 on the same list has a Russian passport and tax code, entry 80 has an individual taxpayer number, and Article 14(2) of the regulation expressly mentions the passport and the identity card among the data that may be included. The Council has breached nothing, because the same provision asks for the data only where that information is available. The practical effect nonetheless remains asymmetrical: a bank in Romania matches on a transliterated Russian name and a date of birth, and the risk of a wrong or a missed match has become, since December 2025, a criminal risk, not merely an administrative one. The account addresses are useful for journalistic verification, but they help with no query in a banking system.

The second observation concerns the calendar, and it is a matter of arithmetic. The date until which Decision (CFSP) 2024/2643 applies is 9 October 2026, set by Decision (CFSP) 2025/2019 of 3 October 2025. The listing enters into force on 24 September 2026, so at the date of publication the entry ban part has 15 days of guaranteed existence. The implementing regulation has no deadline and stays in force, so the freezing of funds continues, but failing an extension of the decision at the beginning of October 2026, the two halves of the same measure part company: the money stays blocked and the entry ban disappears. The flaw does not belong to the act of 24 September 2026. It comes from the habit of adding names two weeks before a renewal deadline.

The third observation concerns what the act does not say. No listing under this regime indicates the point and sub-point of Article 2(3) on which it rests, and the reader has to recognise the criterion from the closing formula of the statement of reasons. At entry 81, that formula reproduces point (a)(iv), on information manipulation and interference, a criterion that has been rewritten in the meantime: the version of 8 October 2024 required the planning or coordination, directly or indirectly, the support or other facilitation of coordinated information manipulation, whereas the version in force has dropped the word „coordinated” and has expressly added participation. The difference is not stylistic: under the old wording a coordinated campaign had to be shown, under the new one participation in the use of information manipulation is enough. An act that cited the criterion would show plainly which of the two it rests on.

What should be changed

  • Every entry should indicate the basis of the listing, the point and sub-point of Article 2(3). In practice, it would shorten any challenge and any compliance check: whoever reads the entry would see straight away which criterion applies, instead of comparing the closing formula with the consolidated text of the regulation.
  • The annex should contain at least one element of identification verifiable in a register, wherever one exists. A passport number, a tax code or the place of birth turns a name match into an identification. In a Member State where failing to freeze is an offence punishable by imprisonment, the difference between a name and an identifier decides whether an operator can act without risk.
  • Listings made in the last 30 days before the foreign policy act expires should be accompanied by its extension. An entry added on 24 September 2026, in a decision applicable until 9 October 2026, leaves the entry ban with 15 days of cover. Adopting the two operations together would spare Member States an interval in which they do not know whether they are still checking the border on this criterion.
  • The six-week deadline in Article 9(2) should run from notification, not from listing. When the annex contains no address for the person, notification is made by notice, and the date on which the person actually finds out does not coincide with the date of listing. Since failure to meet the deadline is treated as circumvention, an obligation that can expire before it is known is hard to defend.
  • The addresses of social media accounts should be put in a separate column, not among the identifying data. They change, they are deleted and they can be impersonated, and an operator who sees them next to a date of birth may think they are an element of identification he is entitled to rely on. In a context column, they would remain useful without misleading anyone.

Original text of the legal act

The text below is reproduced in Romanian, the official form of publication.

The full text, as published in the Official Gazette of Romania

Official Journal of the European Union, L series, 2026/2165 of 24 September 2026 3 pages PDF, 853 KB

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The other editions cited: Decizia (PESC) 2026/2164 a Consiliului din 24 septembrie 2026 de modificare a Deciziei (PESC) 2024/2643 privind masuri restrictive avand in vedere activitatile destabilizatoare ale Rusiei

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This article is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed attorney or tax advisor.