Unwrapping The EU's 15th Sanctions Package

A. Introducing the 15^th Sanctions Package

Once again, as in 2022 and 2023, the EU sanctions community received another sanctions package to unwrap just in time for the holiday season. This concludes another busy year in EU sanctions, with two major sanctions packages, most notably the 14^th sanctions package which brought many changes and additions to the EU's already broad sanctions regime including the "best efforts" obligation and an extension of the "No Russia Clause".

Compared to the previous packages, the 15^th sanctions package (which coversRegulation 2024/3189, Regulation 2024/3183 and Regulation 2024/3192) appears smaller in scope and less remarkable than its precursor. Yet, it does contain noteworthy additions and relevant adjustments.