Update Foreign Trade: European Union issues 16th sanctions package against Russia

On 24 February 2025, marking the third anniversary of Russia's war of aggression against Ukraine, the EU adopted its 16th package of sanctions against Russia. This new package aims to intensify economic and political pressure on Russia by targeting key sectors of its economy and entities supporting its military operations and further reduce sanctions circumvention.

The focus of the new sanctions package are the maritime, energy and banking sectors, but other sectors such as aluminum and chemical industry are concerned as well.

Key components of the 16th sanctions package include in particular:

1. Import and Export Restrictions

Aluminum Import Prohibition: The new measures include a prohibition on importing primary aluminum from Russia. This prohibition will gradually phase in. During the transitional period until 26 February 2026 it is allowed to import and provide services for the import into the EU of 275,000 metric tons of primary aluminum. This measure supplements the already existing prohibition of importing processed aluminum goods from Russia.
Additional Embargo on chemicals: The 16th package expands restrictions on exporting certain chemicals (including chromium compounds) to Russia.

2. Financial Sector Sanctions

Expansion of SPFS ban: As from 25 June 2024 it was prohibited for EU entities to connect to the SPFS system or engage in transactions with listed banks that use this system (Art. 5ac of Regulation 833/2014). The new measures add three other Russian banks, Bank BelVEB, Belgazprombank and VTB Bank (PJSC) Shanghai Branch.
Authorisation to release frozen funds: The new provisions amend an existing derogations for releasing frozen funds. If EU funds are frozen due to the implication of a sanctioned bank in the transactions or entities controlled by such banks, EU operators may request an authorization for release of such funds under certain conditions.

3. Transportation and Infrastructure Measures

Airline Restrictions: A ban on third-country airlines operating domestic flights within Russia from entering EU airspace was added. There are no consequences for third-country airlines merely flying over Russia.

Road Transport Limitations: In order to avoid circumvention of existing road transport prohibitions prevent increasing Russian ownership above 25 % in EU road transport undertakings.

4. Maritime sanctions

Shadow Fleet Targeting: Sanctions on 74 additional vessels believed to be part of Russia's "shadow fleet," used to circumvent oil export restrictions.

Transaction ban on ports: The new measures introduce a transaction ban on certain ports (and two Moscow as well as four regional airports). It is thus prohibited to participate in transactions involving the Volga port Astrakhan and Makhachkala port on the Caspian Sea, the sea ports Ust-Luga and Primorsk on the Baltic Sea, and Novorossiysk on the Black Sea. Certain transactions remain permitted but must be reported to national authorities.

5. Additional Measures

Service Bans: Prohibition on providing construction, architectural, engineering, legal advisory, and IT consultancy services to Russian entities, with specific exceptions for diplomatic and consular operations.

Energy Sector Derogations: A derogation allowing the import of Russian liquefied natural gas (LNG) through EU terminals not connected to the interconnected natural gas system, ensuring energy supply for certain member states.

Forum necessitatis: The new provisions further extended adequate protection of Union operators by (i) providing for further compensation options against non-EU claimants in the framework of EU sanctions enforcement and (ii) a forum necessitatis to allow a court of a Member State, on an exceptional basis, to rule on a claim for damages brought pursuant to Article 11a of Regulation (EU) No 269/2014 where Union law or the law of a Member State does not establish the jurisdiction of a court of any Member State in particular.

Financial sanctions: 83 persons were added to the financial sanctions list (48 individuals and 35 entities).

Measures against Belarus

In parallel to the 16th package of sanctions imposed on Russia, the EU also adopted additional sanctions on Belarus. These measures essentially mirror the new measures against Russia.

Measures concerning Crimea and Oblasts of Donetsk, Kherson, Luhansk and Zaporizhzhia

As the sanctions regimes concerning Crimea and the oblasts of Donetsk, Kherson, Luhansk and Zaporizhzhia had not been amended significantly in the past years, new measures were now introduced, in particular to fight circumvention. The new measures include in particular: 

• Export bans, covering notably banknotes and certain high-risk goods and technology (cars and car parts, goods used on the battlefield, electronics, machinery, aircraft parts);
• a prohibition to provide architecture, engineering, IT and legal services, as well as certain types of software;
• horizontal amendments designed to protect EU operators and, at the same time, strengthen compliance

What companies should do

Make sure that your sanctions screening is up to date.

Verify whether any goods or services provided by the company are subject to the new sanctions.

Verify whether the company is subject to a new reporting obligation and implement processes to comply with this obligation.

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