On Monday, 24 February 2025 – three years to the day after Russia started its war of aggression against Ukraine – the European Union adopted what is now its 16th sanctions package, further tightening measures affecting Russia, Belarus and the territories occupied by Russia.
The 16th sanctions package introduces a large number of embargo measures mirroring the wide range of sanctions regulations issued over the last few years. It includes new import and export restrictions as well as bans on the provision of services and expanded personal sanctions lists; adds targeted sanctions in the aviation, shipping, transport, energy and finance sectors; and steps up the fight against sanctions circumvention and Russian disinformation. The package also expands the scope of certain due diligence obligations and strengthens measures to protect companies against Russian claims. Finally, it introduces a new category of sanctions: transaction bans on specific Russian infrastructures.
With the measures adopted in the 16th sanctions package, the EU is selectively tightening and amending all the sanctions-related regulations issued or expanded in response to the Russian war against Ukraine.
Regulation (EU) 2025/390 and Implementing Regulation (EU) 2025/389 make amendments to the largely personal financial sanctions set out in Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Regulation (EU) 2025/395 amends the primarily trade-related sanctions from Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine. The 16th sanctions package also introduces Regulation (EU) 2025/392 and Implementing Regulation (EU) 2025/386, which expand Regulation (EU) 756/2006 on restrictive measures in view of the situation in Belarus and and the involvement of Belarus in the Russian aggression against Ukraine. Finally, Regulation (EU) 2025/401 and Regulation (EU) 2025/398 amend the regulations containing measures concerning the territories occupied by Russia (Regulation (EU) 2022/263 concerning restrictive measures in response to the illegal recognition, occupation or annexation by the Russian Federation of certain non-government controlled areas of Ukraine and Regulation (EU) 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol).
Particularly noteworthy changes include:
Expansion of trade restrictions
The 16th sanctions package expands goods-related trade restrictions, which essentially apply in parallel to trade relations with both Russia and Belarus.
The import bans under Article 3i Regulation (EU) 833/2014 and Article 1ra Regulation (EU) 765/2006 now also cover unwrought aluminium (CN code 7601). While Belarusian aluminium or aluminium exported from Belarus may only be purchased, imported or transferred based on the existing contracts provision in Article 1ra(9) Regulation (EU) 765/2006 (execution until 26 May 2025 of contracts concluded before 25 February 2025), a total volume quota of up to 275,000 metric tonnes of Russian unwrought aluminium or unwrought aluminium exported from Russia may still be imported into the EU before 26 February 2026. This import volume quota – which applies to all unwrought aluminium imports into the EU – will be managed in accordance with the rules applicable to tariff quotas (Article 49 et seq. Implementing Regulation EU 2015/2447).
Unlike the import restrictions on iron and steel introduced by the 11th sanctions package, the new restrictions on unwrought aluminium do not cover the import of aluminium products manufactured in third countries using Russian unwrought aluminium.
The annexes listing goods which might contribute to Russia or Belarus’s military and technological enhancement or to the development of their defence and security sectors and which are therefore subject to export restrictions under Article 2a Regulation (EU) 833/2014 and Article 1f Regulation (EU) 765/2006 have also been expanded. The main focus is on chemical precursors to riot control agents, CNC control software, chromium compounds and controllers used to guide unmanned aerial vehicles.
Further items have also been added to the annexes listing goods which might contribute to the enhancement of Russian or Belarusian industrial capacities and therefore fall under the export restrictions in Article 3k Regulation (EU) 833/2014 and Article 1bb Regulation (EU) 765/2006. These restrictions now also apply to various additional minerals, chemicals, glass materials and fireworks, among other things. While Article 3k(3ag) Regulation (EU) 833/2014 allows existing contracts to be executed until 26 May 2025, Article 1bb Regulation (EU) 765/2006 has no comparable provision.
Certain types of software used in oil and gas exploration have now been added to Annex II to Regulation (EU) 833/2014, rendering them subject to export restrictions under Article 3 Regulation (EU) 833/2014. Existing contracts may however still be executed until 26 May 2025, and the same applies to the parallel prohibition in Article 1gd Regulation (EU) 765/2006.
Replacement of exemptions with authorisation options
A large number of the exemptions that have so far applied to various prohibitions have been deleted and reintroduced as authorisation options (cf., for example, the amendments in Article 2a(3) and (4) Regulation (EU) 833/2014 or in Article 1e(3) and (4) Regulation (EU) 765/2006).
Companies that have previously used exemptions to conduct what would otherwise be sanctioned business with Russia or Belarus should therefore check whether these business relationships now require prior authorisation.
Tougher action against Russia’s military-industrial complex
Like the 15th sanctions package, the 16th sanctions package expands the list of persons, entities and bodies supporting Russia’s military-industrial complex in its war against Ukraine, adding 53 listings to Annex IV to Regulation (EU) 833/2014. Thirty-four of these are companies based outside Russia.
The legal consequences resulting from inclusion in Annex IV to Regulation (EU) 833/2014 have also been tightened by the amendment to Article 2b Regulation (EU) 833/2014. Whereas the direct effect of such a listing was previously to increase the obstacles to obtaining special authorisation to export sanctioned goods to the listed recipients, a strict export ban now applies to dual-use goods and goods listed in Annex VII to Regulation (EU) 833/2014 when destined for recipients listed in Annex IV to Regulation (EU) 833/2014. This is of particular relevance because – as previously noted – the list does not only include Russian persons, entities and bodies. Article 2b(1) Regulation (EU) 833/2014 now contains an independent export ban on certain goods to listed recipients in China, India, Kazakhstan, Serbia, Singapore, Turkey, Uzbekistan and the UAE, among others.
Finally, the newly introduced Article 3(1), letter (l) Regulation (EU) 269/2014 allows for legal persons, entities and bodies that are part of Russia’s military-industrial complex, that support it materially or financially, or that benefit from it to be included in Annex I to Regulation (EU) 269/2014, thereby freezing their assets and prohibiting funds or economic resources from being made available to them.
Energy measures
Until now it has been possible to temporarily store Russian petroleum products in the EU’s free zones (Article 5, point (17) Regulation (EU) 952/2013) or to place them in these zones under the free zone procedure (Article 245(3) Regulation (EU) 952/2013), but this is now prohibited under Article 3nb Regulation (EU) 833/2014. Russian petroleum oil already in the EU will be exempted from this prohibition until 26 May 2025. The aim of this measure is to increase transportation costs for Russian oil, thereby further reducing Russia’s revenues. The prohibition covers both crude oil and refined petroleum products and applies regardless of the final destination or purchase price of the goods.
The existing prohibition on the provision of goods, technologies and services for the completion of Russian LNG projects has moreover been extended to cover crude oil projects in Russia (Article 3t Regulation (EU) 833/2014).
Measures against Russian disinformation
As a countermeasure to the large-scale and ongoing disinformation campaigns orchestrated by Russia, the broadcasting activities of eight additional Russian media outlets have been suspended in the EU. Annex XV to Regulation (EU) 833/2014, referred to in Article 2f Regulation (EU) 833/2014, has been extended accordingly.
Expansion of bans on services
The bans on services already in place in Article 5n Regulation (EU) 833/2014 and Article 1jc Regulation (EU) 765/2006 have been expanded to cover the construction sector (including civil engineering works) to prevent EU operators from contributing to the development of Russian or Belarusian infrastructure.
Corresponding extensive bans on services (including in the construction sector) now also apply to persons, entities and bodies in Crimea and Sevastopol pursuant to Article 2c Regulation (EU) 692/2014, and to persons, entities and bodies in the “specified territories” occupied by Russia pursuant to Article 5 Regulation (EU) 2022/263.
New transaction bans on specific Russian infrastructures
The 16th sanctions package also introduces a new category of sanctions and contains a comprehensive ban on transactions with certain Russian locks, ports and airports in the newly inserted Article 5ae Regulation (EU) 833/2014. The Russian infrastructures impacted are specified in the new Annex XLVII.
Additional goods subject to increased due diligence
From 26 May 2025, the increased due diligence obligations introduced in Article 12gb Regulation (EU) 833/2014 and Article 8ga Regulation (EU) 765/2006 will also apply to the goods listed in the new Annex XLVIII to Regulation (EU) 833/2014 and Annex XXXI to Regulation (EU) 765/2006, specifically generators with spark-ignition internal-combustion piston engines (CN code 8502 20) and certain types of switches (CN code 8536 50).
“Best-efforts” obligation in all sanctions regulations
The “best efforts” obligation in Article 8a Regulation (EU) 833/2014 and Article 8i Regulation (EU) 765/2006 regarding compliance with EU sanctions by subsidiaries in third countries as set out in the 14th sanctions package (see our article of 26 June 2024) previously only applied to the restrictive measures contained in these two Regulations. The provisions of Article 15a Regulation (EU) 269/2014, Article 8a Regulation (EU) 692/2014 and Article 13a Regulation (EU) 2022/263 newly introduced by the 16th sanctions package mean that the “best-efforts” obligation now extends to all other relevant regulations covering the full range of sanctions against Russia and Belarus.
EU companies that had previously worked to ensure that their non-European subsidiaries comply with Regulation (EU) 765/2006 and Regulation (EU) 833/2014 should now assess whether those non-European subsidiaries risk undermining the restrictions in Regulation (EU) 269/2014, Regulation (EU) 692/2014 and/or Regulation (EU) 2022/263, and take appropriate action.
Protections for EU companies
Article 11a et seq. Regulation (EU) 833/2014 expand the provisions available to EU companies seeking damages and/or legal protection in disputes with Russian business partners.
The damage recovery provisions of Article 11a and 11b Regulation (EU) 833/2014 (see our article of 26 June 2024) now allow non-European subsidiaries of EU companies to recover damages from persons who either own or control the Russian companies responsible.
The new Article 11d Regulation (EU) 833/2014 creates an emergency jurisdiction for damage recovery actions pursuant to Article 11a and 11b Regulation (EU) 833/2014.
Similar provisions will also be incorporated into the other sanctions regulations.
Stricter measures against Russia’s dark fleet
The 16th sanctions package contains further measures targeting Russia’s “dark fleet”, i.e. the vessels Russia uses to undermine the price cap on petroleum products, among other purposes.
Seventy-four vessels have been added to Annex XLII to Regulation (EU) 833/2014, which now includes 153 vessels in total. These ships are subject to the extensive catalogue of sanctions set out in Article 3s Regulation (EU) 833/2014.
In addition, legal persons, entities and bodies that own, control, manage or operate vessels in Russia’s dark fleet, or which provide technical or financial assistance for their operation, may now be included in Annex I to Regulation (EU) 269/2014, thus freezing their assets and meaning that no funds or economic resources may be made available to them (the new Article 3(1), letter (k) Regulation (EU) 269/2014).
Further exclusions from SWIFT and the first sanctions resulting from use of SPFS
Some Russian banks were de facto excluded from the SWIFT system under Article 5h Regulation (EU) 833/2014. The EU has now added 13 more Russian banks to Annex XIV to Regulation (EU) 833/2014, further isolating Russia from the global financial system.
The 14th sanctions package made it possible to impose transaction bans on users of the SPFS system, Russia’s replacement for SWIFT. The 16th package is the first to now make use of this option. Two Belarusian banks and one Chinese bank have now been added to the thus far neglected Annex XLIV to Regulation (EU) 833/2014.
Further sanctions lists
Forty-eight individuals and 35 entities have been added to the persons, entities and bodies listed in Annex I to Regulation (EU) 269/2014. Their assets must now be frozen and no funds or economic resources may be made available to them (Article 2 Regulation (EU) 269/2014). Most of the individuals and entities targeted by these provisions are Russian and were included in connection with assistance given to the Russian military complex or the circumvention of sanctions, but some nationals of North Korea, China and Ukraine have also been listed. The Commission cites their role in sending North Korean mercenaries to Ukraine, assisting Russia’s military operations in the form of satellite reconnaissance, or spreading Russian propaganda narratives in the east of Ukraine.
Outlook
The latest sanctions package again tightens restrictions on trading and financial relations with Russia and Belarus, across a number of sectors. It also includes selective changes to a large number of the embargo measures implemented to date. Entirely new measures, such as transaction bans applicable to certain Russian infrastructures, have also been added.
The 16th sanctions package demonstrates once more the EU’s determination to respond to Russia’s ongoing aggression against Ukraine with sanctions. It remains to be seen how current geopolitical developments – in particular negotiations between the US and Russia on ending the war in Ukraine – will influence European sanctions policy against Russia and Belarus.
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