Bulgaria secured the delisting of two names the package had been expected to add: Vagit Alekperov, the founder of Lukoil, and Patriarch Kirill, head of the Russian Orthodox Church, both dropped from the 21st sanctions package at Sofia's request 1. Lukoil is Russia's largest privately owned oil company. Bulgarian foreign minister Velislava Petrova confirmed the exclusion, drafted as early as 12 July and carried into the final text.
Bulgarian president Rumen Radev argued that blacklisting Alekperov would be 'shooting ourselves in the foot'. Lukoil holds an active EUR 3bn compensation claim against Sofia over the 2023 nationalisation of the Neftohim Burgas refinery, the largest in the Balkans, and sanctioning its founder personally risked handing the company fresh ammunition in that arbitration. A personal listing that reads as symbolic in Brussels reads as evidence in a Bulgarian courtroom.
The carve-out cuts against the package's own logic. The 21st package cleared three failed COREPER votes, the EU ambassadors' committee, before adoption on 23 July , yet still carried a personal exemption. Sanctioning the shadow fleet while shielding Lukoil's founder shows how one member state's domestic liability can bend a bloc-wide instrument, and it hands Moscow a talking point about selective enforcement.
