ARTICLE ON 16th EU SANCTIONS PACKAGE

 Sanctions adopted following Russia’s military aggression against Ukraine.

The European Union (EU) continues to adopt further packages of economic sanctions against Russia due to the continuance of its military aggression against Ukraine, the latest of which is summarised below. The relevant legal framework is EU Regulation 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (“Regulation 269”) and EU Regulation 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (“Regulation 833”) (hereinafter collectively referred to as the “EU Sanctions”).

Note: The position is constantly evolving. Additional sanctions may be introduced in the coming days and these will be the subject of future articles.

This information is:

• of a general nature only and is not intended to address the specific circumstances of any particular individual or entity;
• not necessarily comprehensive, complete, or up to date;
• not professional or legal advice (if you need specific advice, you may consult us).

16th SANCTIONS PACKAGE

A new sanctions package, (the 16th package) was adopted on 24th of February 2025 by the European Union marking the third anniversary of Russia’s invasion of Ukraine. This new package was adopted through the Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and through the Council Regulation (EU) 2025/390 of 24 February 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

The 16th package targets systemically important sectors of the Russian economy such as transport, energy, trade, infrastructure, and financial services. It also adds further measures aimed at tackling circumvention. It is noted that certain provisions of the 16th package are now also mirrored in the Belarus sanctions regime.

The 16th package contains the following key elements:

ANTI-CIRCUMVENTION MEASURES

The 16th package targets 74 additional vessels, part of the shadow fleet or contributed to Russia’s energy revenues, bringing the total number of listed vessels to 153. The measures add a new listing criterion, targeting those who support the operations of unsafe oil tankers. The package imposes targeted export restrictions on 53 new companies supporting Russia’s military-industrial complex or engaged in sanctions circumvention, including 34 companies in countries other than Russia.

ADDITIONAL LISTINGS

This package includes 83 additional listings, including 48 individuals and 35 entities, such as those supporting the Russian military complex, active in sanctions circumvention, Russian crypto assets exchanges and in the maritime sector.

TRADE MEASURES

Direct import ban on Russian aluminium:

In addition to the prohibition for imports of processed aluminum goods from Russia, already in place, this package includes a ban on EU imports of primary aluminium from Russia.

Dual-use export restrictions have been extended to additional items in order to cut Russia’s access to key technologies it has been using on the battlefield, covering among others the following:

• Dual-use chemical precursors to produce chloropicrin and other riot control agents used as chemical weapons by Russia in violation of the Chemical Weapons Convention.
• Software related to Computer Numerical Control (CNC) machine tools used to manufacture weapons, and video-game controllers used by the Russian army to pilot drones on the battlefield.
• Chromium ores and compounds due to their military applications.

The limited derogations and exemptions for certain dual-use and advanced tech exports, e.g. for medical use, have been clarified and further tightened to support effective application by customs and licensing agencies.

Moreover, additional export restrictions have been introduced on industrial goods, specifically targeting chemicals, minerals, glass materials, steel, and fireworks, with special military significance.

ENERGY MEASURES

EU also imposed full-fledge sanctions over three entities transporting Russian crude oil and oil products and providing substantial revenues to the Russian Government.

TRANSPORT MEASURES

The package extends the flight ban to enable the listing of third-country carriers conducting domestic flights within Russia or supplying aviation goods to Russian airlines or for domestic flight in Russia. If listed, these airlines will not be allowed to fly to the EU.

Road transport prohibition: EU adds through this package an amendment that prevents increasing Russian ownership above 25% in EU road transport undertakings.

INFRASTRUCTURE MEASURES

Full transaction ban on specific Russian infrastructures including two Moscow airports (Vnukovo Airport and Zhukovsky Airport), four regional airports, the Volga port Astrakhan and Makhachkala port on the Caspian Sea and the sea ports Ust-Luga and Primorsk on the Baltic Sea and Novorossiysk on the Black Sea.

FINANCIAL SECTOR MEASURES

Since Russia has diverted much of its financial flows via smaller banks, the purpose of the 16th package is to strengthen EU measures on the financial sector. In particular, 13 financial institutions have been added to the list of entities subject to the prohibition to provide Specialised Financial Messaging Services (“SPFS”) and 3 banks have been included to the transaction ban due to their use of the Financial Messaging System of the Central Bank of Russia (SPFS) system to circumvent EU sanctions.

Exception to the SPFS ban(a) strictly necessary for the direct or indirect purchase, import or transport of natural gas, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the Union, a country member of the European Economic Area, Switzerland, or the Western Balkans;

(b) strictly necessary for the direct or indirect purchase, import or transport of oil, including refined petroleum products, from or through Russia, unless prohibited under Article 3m or 3n;

(c) necessary for the purchase as well as import and transport into the Union of pharmaceutical, medical or agricultural and food products, including wheat and fertilisers, whose purchase as well as import and transport into the Union is allowed under this Regulation;

(d) necessary for the repayment of a debt due to a national of a Member State or a legal person, entity or body established in the Union;

(e) necessary for the payment of a pension scheme to a person established in the Union; or

(f) necessary for a payment from or to the Jewish Claims conference.

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Authors

Marilou Pavlou Christodoulides | Partner

Stella Kagia | Senior Associate