EU diplomats have drafted a new sanctions list naming 1,600 Russian entities, according to the Kyiv Post. The document is circulating among member states' ambassadors — the stage at which the bloc's Russia sanctions are assembled before ministers are asked to sign off.

EU sanctions on Russia are foreign-policy measures under the Common Foreign and Security Policy, adopted by the Council under Article 29 TEU and given legal force through an implementing regulation under Article 215 TFEU. Both routes require unanimity — all 27 national governments, not a qualified majority. A working-level list like the one reported by the Kyiv Post is a proposal; it becomes binding only once ambassadors in the Permanent Representatives Committee ("Coreper") sign off and the Council formally adopts it, and any single government can block or force changes to individual names.

That single-veto structure is why sanctions rounds routinely arrive late, trimmed, or split into fragments — capitals have used it before to protect specific companies or sectors from listing.

Hypothesis: this list will face the same bottleneck that has slowed other Russia measures this year, where one government's objections — on unrelated grounds — hold up the whole package. Supporting this: Belgium has separately withheld consent on using immobilised Russian central-bank assets to help finance Ukraine, citing its own legal exposure as host of the depository holding most of the frozen funds. Against this: a straightforward entity-listing exercise carries less financial liability for any one state than the asset question does, which may make it easier to push through unanimously. The Kyiv Post report does not say which governments, if any, have raised objections to the current draft.

What to watch: whether the draft reaches Coreper intact, which capitals attach reservations, and whether it is folded into a wider renewal package or adopted on its own timeline.