Jürgen Ligi
Rahandusminister
Rahandusministeerium 15.10.2025 nr 10.1-13/1002-1
Erkki Keldo
Majandus- ja tööstusminister
Majandus- ja Kommunikatsiooniministeerium
Austatud ministrid
Edastame teile Euroopa Komisjoni voliniku Maria Luís Albuquerque 15.10.2025 kirja nr
Ares(2025)8764982 (sanctions).
Samasisuline kiri on edastatud ka välisminister Margus Tsahknale.
Lugupidamisega
Kyllike Sillaste-Elling
Alaline esindaja
Tiiu Noobel +32 2227 4337
[email protected]
Rue Guimard 11/13 1040 Brussels Tel: +32 2 227 39 10
[email protected] https://eu.mfa.ee
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR FINANCIAL STABILITY, FINANCIAL SERVICES AND CAPITAL
MARKETS UNION
EU Sanctions Envoy
Sanctions Coordinators Forum
Tuesday 28 October 2025
14:00 – 18:00
Venue: Albert Borschette Congress Centre, meeting room 0A
Rue Froissart 36, 1040 Etterbeek, Belgium
OPENING REMARKS – 14:00-14:10
Commissioner Maria Luís Albuquerque
REMARKS FROM SANCTIONS COORDINATORS – 14:10-14:20
EU Sanctions Envoy David O’Sullivan
UK Sanctions Director, David Reed
US Sanctions Coordinator (acting), Samuel Parker
SESSION ONE [EU MEMBER STATES, G7+, UKRAINE] – 14:20-15:30
I. Sanctions impact and perspectives from Ukraine
Scene setting: successes, challenges, path ahead
_______________________________________________________________________________________________________
Coffee break – 15:30-16:00
_____________________________________________________________________________
SESSION TWO [EU MEMBER STATES, G7+] – 16:00-17:55
I. Financial services supporting Russia’s warfare and restrictions on financial
networks in third countries
II. Economic pressure on Russia’s energy sector and shadow fleet
III. Circumvention trends and patterns in the Russian military industrial complex
CLOSING REMARKS – 17:55-18:00
EU Sanctions Envoy, David O’Sullivan
***
Electronically signed on 15/10/2025 11:48 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR FINANCIAL STABILITY, FINANCIAL SERVICES AND CAPITAL
MARKETS UNION
Brussels, FISMA
Practical Information
HIGH-LEVEL MEETING ON UNION RESTRICTIVE MEASURES
Physical meeting
28 October 2025
The High-Level meeting on Union Restrictive Measures will take place in person on
28 October 2025 between 9:00 – 12:30 at Albert Borschette Conference Center, 36 rue
Froissart, 1040 Brussels, meeting room 0A.
Meeting will take place in the 1 + 1 format. The European Commission will reimburse
the travel costs of one participant. Please note that only accredited persons are allowed in
the room.
Details on the registration process will be provided in due course via AGM (the
Commission system for managing expert group meetings) and the Permanent
Representations.
The European Commission is committed to personal data protection. DG FISMA is
processing your personal data under Regulation (EU) 2018/1725 for this expert group's
purposes as detailed in the specific privacy statement. Please note that you assume full
responsibility for the collection and/or publication of pictures, audiovisual recordings
and/or for any other processing of personal data that you might carry out during the
meeting at your own initiative.
Contacts: Michael Stelzer, Head of Unit, Sanctions (
[email protected])
Franca Poliani, event coordinator (
[email protected])
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 229 91111
EUROPEAN COMMISSION
DIRECTORATE-GENERAL FOR FINANCIAL STABILITY, FINANCIAL SERVICES AND CAPITAL
MARKETS UNION
Eighth High Level Meeting
Union Restrictive Measures
Agenda
28 October 2025, 09:00 – 12:30
Conference Centre Albert Borschette, Brussels
Rue Froissart 36, 1040 Etterbeek
Welcome coffee
1) Opening remarks by Commissioner Maria Luís Albuquerque
2) Opening remarks by the Danish Presidency [tbc]
3) Implementation of recent energy measures
4) Maritime sanctions: Shadow fleet – How to make EU measures more effective
5) Enforcement: Sharing of success stories
6) Closing remarks by Commissioner Maria Luís Albuquerque
Electronically signed on 15/10/2025 11:48 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121
EUROPEAN COMMISSION
PROTECTION OF YOUR PERSONAL DATA
Processing operation: Organisation and management of meetings of expert groups
Data Controller: European Commission, Directorate-General for Financial Stability, Financial
Services and Capital Markets Union (‘DG FISMA’), Sanctions Unit E5
Record reference: DPR-EC-00744
Table of Contents
1. Introduction
2. Why and how do we process your personal data?
3. On what legal ground(s) do we process your personal data?
4. Which personal data do we collect and further process?
5. How long do we keep your personal data?
6. How do we protect and safeguard your personal data?
7. Who has access to your personal data and to whom is it disclosed?
8. What are your rights and how can you exercise them?
9. Contact information
10. Where to find more detailed information?
1. Introduction
The European Commission (hereafter ‘the Commission’) is committed to protect your personal
data and to respect your privacy. The Commission collects and further processes personal data
pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council of
23 October 2018 on the protection of natural persons with regard to the processing of personal
data by the Union institutions, bodies, offices and agencies and on the free movement of such
data.
This privacy statement explains the reason for the processing of your personal data, the way we
collect, handle and ensure protection of all personal data provided, how that information is
used and what rights you have in relation to your personal data. It also specifies the contact
details of the responsible Data Controller with whom you may exercise your rights, the Data
Protection Officer and the European Data Protection Supervisor.
This privacy statement concerns the processing operation Organisation and management of
Commission expert group meetings undertaken by the European Commission, Directorate-
General for Financial Stability, Financial Services and Capital Markets Union (‘DG FISMA’),
Sanctions Unit E5 as presented below.
For the purpose of this privacy statement and the corresponding record, the term “expert
groups” describes Commission expert groups in the sense of Article 2(1) of Commission Decision
C(2016)3301 of 30 May 20161 and their sub-groups, as well as other similar entities in the sense
of Article 2(2) of Commission Decision C(2016)3301 and their sub-groups.
2. Why and how do we process your personal data?
Purpose of the processing operation: The European Commission collects and uses your personal
information only for the organisation, preparation, management and follow-up of expert groups
meetings. More specifically, this concerns the following processing activities:
• communication activities such as sending e-mails and invitations (this entails the
management of contact lists for correspondence);
• exchange of meeting documents (notably through information sharing and circulation
of documents via e-mail, the Advanced Gateway to EU Meetings (AGM) online system
for meeting organisation (see Record of processing DPR-EC-01141 - Information system
supporting the organisation of meetings (former notification DPO-3911)) or CIRCABC
(see Record of Processing DPR-EC-01666 - CIRCA and CIRCABC – Global User Directory
(former notification DPO-1008))) and sharing of information with other Commission
services to follow-up on the expert group meeting concerned;
• organisational and administrative activities to ensure the participants' access to
Commission premises (see Record of Processing DPR-EC-00655 (Commission Physical
Access Control System (PACS)));
• reimbursement of travel, subsistence costs or payment of special allowances in the
sense of Article 21 of Commission decision C(2016) 3301 (see Record of Processing DPR-
EC-00301 - Legal Entities and Bank Accounts (former notifications DPO-372 and DPO-
300));
• audio-visual recording of the meetings for the purpose of drafting minutes (see Record
of Processing DPR-EC-03266 (Audio-visual recording of meetings));
• publication of minutes of meetings, including list of participants, in the
https://ec.europa.eu/transparency/regexpert/index.cfm (‘the Register of expert
1
Commission Decision C(2016)3301 of 30 May 2016 establishing horizontal rules on the creation and
operation of Commission expert groups.
2
groups’) for reasons of transparency. In the case of organisations, Member States’
authorities and other public entities, the names of their representatives may only be
included in the minutes and published in the Register of expert groups subject to their
prior freely given, specific, informed and unambiguous consent, in compliance with
Article 3(15) and Article 7 of Regulation (EU) 2018/1725. Furthermore, in agreement
with the competent Commission department, the expert group may, by simple majority
of its members, decide that deliberations shall be public, in compliance with Article 13.6
of Commission Decision C(2016)3301 of 30 May 2016 establishing horizontal rules on
the creation and operation of Commission expert groups.
The audience or non-speaker participants are not photographed individually or in groups. They
may however appear on panoramic photographs of the whole event/audience.
Participants that do not wish to be part of the above web-streaming and recording/publishing
activities have the possibility to object to processing. The specific privacy statement will explain
how data subjects can object to processing (e.g. by sitting in back rows which are not
recorded/photographed, by wearing special badges, by attending the meeting in a separate
room without web-streaming, etc.).
Your personal data will not be used for an automated decision-making including profiling.
3. On what legal ground(s) do we process your personal data
We process your personal data, because processing is necessary for the performance of a task
carried out in the public interest (Article 5(1)(a) of Regulation (EU) No 2018/1725).
Expert groups play an important role in enabling the Commission to collect advice and views
from a variety of key actors, such as Member States' authorities, private stakeholders, scientists
and professionals. The Commission uses advice and expertise received as a basis for sound
policy making and implementation.
The natural way for the Commission to obtain the opinion of the expert groups is in meetings.
Furthermore, preparing minutes of the meetings of expert groups allows for the proper
documentation of the work of the expert groups and also increases the transparency on expert
groups and their work.
Processing of your personal data is also necessary to comply with a legal obligation to which the
controller is subject (Article 5(1)(b) of Regulation (EU) No 2018/1725), namely Commission
Decision C(2016)3301 of 30 May 2016 establishing horizontal rules on the creation and
operation of Commission expert groups, and in particular its Articles 13, 20 and 26.
The latter Commission Decision also constitutes the Union law on which the processing under
Article 5(1)(a) and (b) of Regulation (EU) No 2018/1725 is based.
For specific processing activities the consent of the data subject is necessary: The names of
representatives of organisations, Member States’ authorities and other public entities are
included in the minutes of the meetings only subject to their prior freely given, specific,
informed and unambiguous consent, in compliance with Article 3(15) and Article 7 of
Regulation (EU) No 2018/1725.
Your consent is required for the processing of your personal data relating to your dietary
requirements and/or access requirements. If you opt-in, you are giving us your explicit consent
under Article 5(1)(d) of Regulation (EU) 2018/1725 to process your personal data for those
specific purposes. You can give your consent form by informing the controller for the expert
group in question. You can withdraw your consent for these services at any time by contacting
the controller for the expert group in question.
4. Which personal data do we collect and further process?
In order to carry out this processing operation the Data Controller may collect the following
categories of personal data:
▪ Personal data necessary for organising and managing meetings such as gender (Mr/Ms),
name, organisation to which he/she belongs, e-mail address, phone/fax number;
▪ Personal data necessary for security (access control to Commission premises) such as ID
card/Passport number and date of birth, name, surname, organisation he/she belongs to,
gender;
▪ Personal data necessary for reimbursements purposes such as name, means of transport,
hotel accommodation and banking details;
▪ Personal data necessary for payment of special allowances, such as name and banking
details;
▪ Personal data included in the minutes of meetings, such as names of meeting participants
and their positions expressed (in case of representatives of organisations, Member States’
authorities and other public entities, only based on their prior freely given, specific,
informed and unambiguous consent, if at all);
▪ Personal data necessary for establishing the attendance list and the minutes: signature,
audio-visual recording of the meeting;
▪ Personal data relating to your dietary requirements and/or access requirements]
If you do not provide these personal data, possible consequences are the impossibility to attend
meetings and/or to be reimbursed or paid.
We have obtained your personal data either directly from you, via the competent National
department, other public entity or organisation that you work for or via the Permanent
Representation of your country in Brussels.
5. How long do we keep your personal data?
The Data Controller only keeps your personal data for the time necessary to fulfil the purpose of
collection or further processing, namely for a maximum of 5 years after closure of the file to
which the personal data processed belongs. The documents related to the work of the expert
groups are transferred to the Historical Archives for permanent preservation2.
The ‘administrative retention period’ of five years is based on the retention policy of
Commission documents and files (and the personal data contained in them), governed by the
common Commission-level retention list for European Commission files (SEC(2019)900).
2
For the processing operations concerning the Historical Archives, please see legacy notifications: 'DPO-
3871-3 Notification for the digital archival repository and ARCHISscanning' and 'DPO-2806-5
Gestion des dossiers papier structurés par nom de personnes et transférés aux Archives Historiques'.
4
It is a regulatory document in the form of a retention schedule that establishes the retention
periods for different types of Commission files. That list has been notified to the European Data
Protection Supervisor.
The ‘administrative retention period’ is the period during which the Commission departments
are required to keep a file depending on its usefulness for administrative purposes and the
relevant statutory and legal obligations.
This information is without prejudice to different retention periods which may apply to personal
data processed for the purpose of reimbursing travel and subsistence costs, payment of special
allowances and ensuring the participant's access to Commission premises based on the
dedicated processing operations notified to the DPO by the responsible Commission
departments (Records of Processing DPR-EC-00655 (Commission Physical Access Control System
(PACS)) and DPR-EC-00301 - Legal Entities and Bank Accounts (former notifications DPO-372 and
DPO-300)).
Sensitive personal data relating to dietary and/or access requirements will be deleted as soon as
they are no longer necessary for the purpose for which they have been collected in the
framework of the expert group meeting, but no later than within 1 month after the end of the
meeting.
Recordings from the web-streamed meeting will be kept for 2 years before being deleted. More
information is available in the Record of Processing DPR-EC-00306 (Web-streaming of
Commission events).
In case of audio-visual recording of the meeting, the recordings will be kept for 3 months after
the meeting before being deleted. More information is available in the Record of Processing
DPR-EC-03266 (Audio-visual recording of meetings).
Personal data shared with the Directorate-General for Human Resources and Security of the
European Commission for the participants to gain access to Commission buildings is kept for 6
months after the termination of the link between the data subject and the Commission. More
information is available in the Record of Processing DPR-EC-00655 (Commission Physical Access
Control System (PACS)).
6. How do we protect and safeguard your personal data?
All personal data in electronic format (e-mails, documents, databases, uploaded batches of
data, etc.) are stored on the servers of the European Commission (or of its contractors
(processors), if contractors are engaged to assist the controller). All processing operations are
carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on
the security of communication and information systems in the European Commission.
In order to protect your personal data, the Commission has put in place a number of technical
and organisational measures. Technical measures include appropriate actions to address online
security, risk of data loss, alteration of data or unauthorised access, taking into consideration
the risk presented by the processing and the nature of the personal data being processed.
Organisational measures include restricting access to the personal data solely to authorised
persons with a legitimate need to know for the purposes of this processing operation.
7. Who has access to your personal data and to whom is it disclosed?
Access to your personal data is provided to the Commission staff authorised for carrying out this
processing operation and to other authorised Commission staff according to the “need to
know” principle. Such staff abide by statutory, and when required, additional confidentiality
agreements.
More specifically, the following Commission staff have access to certain parts of the personal
data:
- Authorised staff of the European Commission's Directorate-General for Human
Resources and Security have access to the personal data necessary for providing access
to European Commission premises;
- Authorised staff of the European Commission's Directorate-General for Budget and the
Paymaster Office (PMO) have access to the personal data needed for reimbursement
purposes and payment of special allowances;
- Authorised staff of the European Commission's Directorate-General for Interpretation
(SCIC) as meeting room and equipment providers have access to the audio-visual
recordings of the meetings;
- Authorised staff of other European Commission departments involved in the policy
follow-up to a specific expert group meeting.
The minutes of expert group meetings are made public on the Register of expert groups and in
some cases contain personal data, as explained under Heading 2 of this privacy statement.
Please note that pursuant to Article 3(13) of Regulation (EU) 2018/1725, public authorities
(e.g. Court of Auditors, EU Court of Justice) which may receive personal data in the framework
of a particular inquiry in accordance with Union or Member State law shall not be regarded as
recipients. The further processing of those data by those public authorities shall be in
compliance with the applicable data protection rules according to the purposes of the
processing.
The information we collect will not be given to any third party, except to the extent and for the
purpose we may be required to do so by law.
Cookies
Cookies are short text files stored on a user’s device (such as a computer, tablet or phone) by a
website. Cookies are used for the technical functioning of a website (functional cookies) or for
gathering statistics (analytical cookies).
The registration for the meeting takes place via a Commission website. The cookies employed
by the Commission on the registrant’s device for that purpose will be covered by the cookie
policy of the Commission, which is available here: https://ec.europa.eu/info/cookies_en.
Cookies are stored by Europa Analytics, the corporate service which measures the effectiveness
and efficiency of the European Commission's websites on EUROPA. More information is
available in the Record of Processing DPR-EC-00685 (Europa Analytics).
Enabling these cookies is not strictly necessary for the website to work but it will provide you
with a better browsing experience. You can delete or block these cookies, but if you do that,
some features of the meeting website may not work as intended.
The cookie-related information is not used to identify data subjects personally and the pattern
data is fully under the Commission’s control. These cookies are not used for any purpose other
than those described here.
6
Should you wish to opt your personal data out of our anonymised, aggregated statistics, you can
do so on our cookies page. In particular, you can control and/or delete those cookies as you
wish.
8. What are your rights and how can you exercise them?
You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU)
2018/1725, in particular the right to access your personal data and to rectify them in case your
personal data is inaccurate or incomplete. Under certain conditions, you have the right to erase
your personal data, to restrict the processing of your personal data, to object to the processing
and the right to data portability.
You have the right to object to the processing of your personal data, which is lawfully carried
out pursuant to Article 5(1)(a) of Regulation (EU) 2018/1725, on grounds relating to your
particular situation.
To the extent you consented to the publication of some of your personal data, you can
withdraw your consent at any time by notifying the Data Controller. The withdrawal will not
affect the lawfulness of the processing carried out before you have withdrawn the consent.
You can exercise your rights by contacting the Data Controller, or in case of conflict the Data
Protection Officer. If necessary, you can also address the European Data Protection Supervisor.
Their contact information is given under Heading 9 below.
Where you wish to exercise your rights in the context of one or several specific processing
operations, please provide their description (i.e. their Record reference(s) as specified under
Heading 10 below) in your request.
Any request for access to personal data will be handled within one month. Any other request
mentioned above will be addressed within 15 working days.
9. Contact information
- The Data Controller
If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have
comments, questions or concerns, or if you would like to submit a complaint regarding the
collection and use of your personal data, please feel free to contact the Data Controller:
European Commission, Directorate-General for Financial Stability, Financial Services and Capital
Markets Union (‘DG FISMA’), Sanctions Unit E5 at
[email protected].
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer
[email protected] with
regard to issues related to the processing of your personal data under Regulation (EU)
2018/1725.
- The European Data Protection Supervisor (EDPS)
You have the right to have recourse (i.e. you can lodge a complaint) to the European Data
Protection Supervisor (
[email protected]) if you consider that your rights under Regulation
(EU) 2018/1725 have been infringed as a result of the processing of your personal data by the
Data Controller.
10. Where to find more detailed information?
The Commission Data Protection Officer (DPO) publishes the register of all processing
operations on personal data by the Commission, which have been documented and notified to
him. You may access the register via the following link: http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register with the
following Record reference: DPR-EC-00744.
8
Tiiu Noobel
From: Esindus EL juures üldaadress
Sent: kolmapäev, 15. oktoober 2025 16:00
To: Tiiu Noobel
Subject: FW: Invitation to the High-Level Group on Sanctions Implementation - 28 October
2025
Attachments: Transmission letter Estonia.pdf; Invitation to the 8th HL meeting.pdf; Practical
information - 28 October 2025.pdf; Privacy statement High-Level meeting Union
Restrictive Measures.pdf; Agenda SCF - 28 October 2025.pdf; Eight High-Level
meeting on sanctions - agenda.pdf
From: MELINTE Ovidiu Nicusor <
[email protected]>
Sent: Wednesday, October 15, 2025 2:31 PM
To: Esindus EL juures üldaadress <
[email protected]>
Cc: DRAGUSIN Cristina <
[email protected]>
Subject: Invitation to the High-Level Group on Sanctions Implementation - 28 October 2025
Dear sir / madam,
Please find attached a request by Ms Cristina Dias, Head of Cabinet of Ms Maria Luís Albuquerque, Member of
College of the European Commission to H.E. the Ambassador, to deliver an invitation letter to the 8th High-
Level Meeting on Union Restrictive Measures, on 28 October 2025.
Thank you!
Kind regards,
OVIDIU MELINTE
Assistant
European Commission
Cabinet of Commissioner Maria Luís ALBUQUERQUE
B-1049 Brussels/Belgium
+32 229-61.11.13
[email protected]
1
MARIA LUÍS ALBUQUERQUE
FINANCIAL SERVICES AND THE SAVINGS
AND INVESTMENTS UNION
Dear Minister,
I am writing to invite you to attend the eighth meeting of the High-Level Group on
sanctions implementation, which will take place in person in Brussels, on Tuesday 28
October 2025, starting at 9h00.
The focus of this eight meeting will be on strengthening the implementation of recent
energy measures and enhancing the efficacity of maritime sanctions, especially in
addressing the challenges posed by the shadow fleet. We will also exchange views on
successful enforcement practices among Member States, providing valuable insights and
fostering a collaborative environment.
Ensuring the effective implementation of sanctions adopted by the EU remains among the
main priorities of the European Commission, in particular in response to Russia’s war of
aggression against Ukraine. Therefore, I would like to bring together once again high-level
representatives from all Member States and the relevant Commission services working in
the field of sanctions implementation and enforcement, in order to continue our discussions
and enhance common efforts in these areas.
During the morning, Member States will have the opportunity to exchange views and
actively participate to the discussion on implementation and enforcement of Union
restrictive measures, identify best practices, and jointly reflect on how to improve
coordination going forward.
In the afternoon, EU Sanctions Envoy Mr David O’Sullivan will convene the Sanctions
Coordinators Forum, bringing together Member States and our international partners and
allies. As on previous occasions, colleagues from Ukraine will join for a dedicated session.
Please find attached the agendas for both the High-Level Group meeting and the Sanctions
Coordinators Forum. I thank you for your continued support on this important matter and
look forward to this exchange.
Yours faithfully,
Maria Luís Albuquerque
European Commission, Rue de la Loi 200, B - 1049 Brussels
Electronically signed on 15/10/2025 11:48 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121