The EU’s 16th Sanctions Package on Russia – Focusing on Circumvention Prevention
On 24 February 2025, the European Union (the “EU”) adopted its 16th sanction package against Russia, marking the third anniversary of Russia’s full-scale invasion of Ukraine. The 16th package focuses on key sectors of the Russian economy, including energy, trade, transport, infrastructure, and financial services, and introduces further measures to combat circumvention of the sanctions. In parallel, the EU also introduced new sanctions against Belarus, broadly mirroring the trade sanctions against Russia. In this blog post, we discuss the key elements of the new sanctions package.
Previous bog posts on the sanctions can be found here and here.
Measures to prevent circumvention of sanctions
Previously adopted sanction packages enable the EU to list vessels that support Russia’s warfare against Ukraine in order to prevent Russia from circumventing sanctions. Listed vessels are subject to port access bans, and prohibitions to provide a broad array of maritime services and other services such as financing and financial assistance. In the 16th package, the EU has listed 74 additional vessels linked to Russia’s energy revenues or shadow fleet.
Broadened import-related restrictions on aluminum
Previously, import bans from Russia included EU imports of processed aluminum goods. The new sanctions package expands the import ban to cover imports of primary aluminum as well.
Export-related restrictions
The new sanctions package also imposes further restrictions against exports of dual use goods related to the Russian military and defense sector. This includes dual-use technology such as chemical precursors, Computer Numerical Control (CNC) software for weapon manufacturing, video game controllers that can be used to pilot drones and chromium ores and compounds.
Furthermore, additional export bans have been introduced on industrial goods, specifically targeting minerals, chemicals, steel, glass materials, and fireworks, that are of military significance. Export restrictions have also been imposed on 53 specific entities, including 34 entities established in countries other than Russia, that support Russia’s military-industrial complex or sanctions circumvention. In some cases of exports where previously only a notification was required before export, the export now requires an authorization from the supervisory authority confirming that the exemption applies.
Measures related to energy, infrastructure and transport
The sanction package targets the Russian energy sector. There is a ban the temporary storage or free zone placement of Russian crude oil and petroleum products in EU ports. Banning free zone placement means that Russia cannot use these zones in EU ports to temporarily store or handle its oil before shipping it elsewhere. This restriction aims to disrupt Russian oil trade and increase its logistical costs. Additionally, the 16th package expands restrictions on supplying goods, technology, and services for Russian LNG projects to also cover crude oil projects, including exploration and production. It also bans the sale, supply, transfer, export, or provision of software used for oil and gas exploration in Russia.
The new sanctions also impose transaction bans on specific Russian infrastructure. A complete transaction ban is imposed on specific Russian airports and seaports that have been used i.e., to transport combat-related goods and technology. A ban is also imposed on construction services provided by EU operators in Russia, as only architectural and engineering services were banned in earlier sanction packages. The new package introduces a possibility to list third-country airlines operating domestic flights in Russia or supplying aviation goods to Russian airlines or for domestic flight in Russia. Listed airlines will face a ban on flying to the EU.
Measures in the financial sector
The 16th sanction package includes strengthened measures against the financial sector to target Russia’s use of smaller banks. This includes adding 13 financial institutions to the list of entities subject to a prohibition to provide specialized financial messaging to combat the extension of business to the occupied territories and imposing a transaction ban to three additional banks to fight institutions that support circumvention of EU’s sanctions.
Additional listings
The 16th package adds 48 individuals and 35 entities to the list of individuals and entities that are subject to asset freeze measures, and a prohibition on making funds and economic resources available to them.
Concluding remarks
The new package is designed to further ramp up pressure on the aggressor and is a part of the EU’s unwavering commitment to a just and lasting peace for Ukraine. The newest package indeed signals the European Unions continued support of Ukraine, at a time when other important international support is being withdrawn.
While the new sanction package further strengthens the EU’s sanctions against Russia, all companies operating in the EU must ensure compliance with the sanctions and are expected to implement appropriate policies, controls and procedures to mitigate and manage compliance risks. Delphi is happy to assist companies with ensuring compliance with applicable sanctions regime.