On 13 July 2026, the EU designated VK (VKontakte) to is asset-freeze sanctions. The designation was made under Regulation 2024/1485 which sets out a separate (from Regulation 269/2014 which is the main EU blocking regulation with respect to Russia) EU blocking sanctions regime related to human rights violations.
VKontakte is a popular Russian social media platform and an interesting question arises whether/how such designation may affect the EU residents which use this platform. The issue arises in the context of EU blocking sanctions prohibiting to provide “funds or economic resources” for the operator of the platform.
For sure, there are a few bright-lines. For example, any payments to the operator of the platform are prohibited for the EU residents even if made from the accounts outside the EU. Similarly, it would be also fair to say that the use of platform solely for private communication purposes should not be qualified as a breach of sanctions.
A more complex situation would be when, for example, an EU resident uses the platform for business purposes and such use may result in indirect payments to the platform operator (e.g., from additional advertisements or payments from third-parties which such business generates). In the current environment when EU Courts tend to give an over-restrictive interpretation of the sanctions, it would be safe to discontinue such activity or prepare a strong file confirming that no economic resources (a term which has a very broad meaning in EU sanctions covering, in essence, any assets of value) are directly or indirectly provided to the platform as a result of such activity.