As announced in its press release, on 24 February 2025, exactly three years after Russia invaded Ukraine, the EU published its 16th package of sanctions against Russia in the Official Journal. The package entered into force on 25 February 2025. The EU also introduced new measures against Belarus and Crimea and Sevastopol and certain non-Government controlled areas of Ukraine, largely aligning with the Russia sanctions measures.
Aside from additional designated person listings, this latest package of sanctions notably includes additional export, import, transit and services restrictions, measures to address circumvention schemes, financial loopholes and Russia’s revenue sources, and hybrid attacks involving the media.
In summary, the main measures of the 16th package include the following:
- the listing of 74 additional shadow fleet vessels under Annex XLII to Regulation 833/2014, bringing the total to 153 vessels subject to a port access ban and a ban on provision of services;
- the listing of 48 additional individuals and 35 entities to the list of natural and legal persons, entities and bodies subject to restrictive measures set out in Annex I to Regulation (EU) 269/2014 (including an additional bank, and parties in third countries, among others);
- notably, the addition of the “best efforts” requirement as a new Article 15a under Regulation (EU) 269/2014 requiring EU entities to take steps to ensure entities they own/control do not undermine the sanctions (i.e., now also in respect of dealings with designated persons);
- the addition of 53 new entities to the list of those supporting Russia’s military-industrial complex (including entities in China, Hong Kong, India, the UAE, and Kazakhstan), and tightened export controls targeting those entities;
- additions to the lists of items restricted for sale, export and supply to Russia (and ancillary services prohibitions) including certain chemicals (e.g., chemical precursors), some plastics, certain minerals;
- a ban on the export, supply, or provision of oil and gas exploration software to Russia;
- additions to the list of items for which the obligations to conduct due diligence and have appropriate policies, controls and procedures to mitigate diversion risk apply (now also capturing electrical generating sets and electrical switches in a new Annex XLVIII);
- a new prohibition on construction services, including civil engineering works;
- a transaction ban with certain listed ports, locks and airports involved in the circumvention of restrictive measures;
- a transaction ban on credit and financial institutions that use Russia’s alternate financial messaging service, SPFS, and the prohibition to provide specialized financial messaging services to 13 additional regional banks;
- additional restrictions on the purchase, import and transfer (and ancillary services prohibitions) of primary aluminium from Russia or of Russian origin;
- additional restrictions relating to the energy sector, including on the temporary storage for Russian crude oil and petroleum products, and targeting additional crude oil projects in Russia;
- the suspension of the broadcasting license of an additional 8 Russian media outlets;
- tightening of the controls on transport of goods within the EU by parties with Russian/Belarusian ownership, as well as further extension of the existing flight ban measures;
- various amendments to licensing grounds and exemptions, including to tighten the position relating to dual-use/mass market software updates;
- postponement of the date of entry into force of the requirement to provide traceability-based evidence for imports of polished diamonds; and
- new measures targeting Belarus and Crimea and Sevastopol and the non-government-controlled areas of Ukraine aiming at more closely mirroring Russia measures.
We provide additional detail on these measures below. Please get in touch with your usual Baker McKenzie international trade compliance contacts for support as needed.
- Listing of 74 additional shadow fleet vessels under Council Regulation (EU) 2025/390
i. An additional 74 vessels have been made subject to a port access ban and a ban on provision of services, bringing the total number of vessels listed under Annex XLII of Council Regulation (EU) 833/2014 to 153. These vessels are part of the shadow fleet or contributed to Russia’s energy revenues.
- Amendments to Council Regulation 833/2014 made under Council Regulation 2025/395
- Anti-circumvention measures
i. New, targeted export controls and designations have been introduced to prevent the continued export of certain dual-use goods and technologies to Russian defense and security end users. Notably, chemical precursors to riot control agents, software related to computer numerical control (CNC) machines, chromium compounds and controllers used to guide UAVs are added to the list of items which might contribute to Russia’s military and technological enhancement or to the development of its defence and security sector.
ii. A prohibition to enter into any transaction involving ports, locks and airports used for the transfer of UAVs, missiles or related technology or components thereof to Russia, or for the circumvention of the Oil Price Cap by vessels practicing irregular and high-risk shipping practices or of other restrictive measures has also been introduced.
- Additional measures targeting credit and financial institutions
i. The 16th package imposes a transaction ban on additional credit and financial institutions that use Russia’s alternate financial messaging service, SPFS (Bank BelVEB, Belgazprombank, or VTB Bank (PJSC) Shanghai Branch (as listed in Annex XLIV to Council Regulation (EU) No 833/2014)) with an exception for execution of transactions that are necessary for the repayment of guarantees granted by a Member State, divestment from Russia, or the wind-down of business activities in Russia, or execution of certain contracts.
ii. Extension of the prohibition to provide financial messaging services (i.e., cutoff from SWIFT) to 13 additional regional banks as follows: Ak Bars Bank, Uralsib Bank, Tochka Bank, National Reserve Bank, Roseximbank, Bank SINARA, Primsotsbank, BBR Bank, RNKO Platezhnyy Konstruktor, Petersburg´s Settlement Center, Kuznets Business Bank, MIR Business Bank, and Bank Kuban Kredit.
- Prevention of hybrid attacks in the media
i. Eight additional Russian media outlets are now prohibited from broadcasting in the EU (with associated restrictions on EU parties facilitating the broadcasting of their content): EADaily / Eurasia Daily, Fondsk, Lenta, NewsFront, RuBaltic, SouthFront, Strategic Culture Foundation, Krasnaya Zvezda / Tvzvezda. This does not prevent these media outlets from conducting other journalistic activities.
- New trade, services, and transport restrictions. The 16th package imposes various trade restrictions, including:
i. Restrictions on the purchase, import and transfer of primary aluminium from Russia or with Russian origin, to limit Russia’s generation of revenue from its aluminium trade;
ii. Restrictions on transit through Russia of certain chemicals, plastics and rubber products;
iii. Additional sale, export and supply restrictions on software related to oil and gas exploration, aiming at further restrict Russia’s oil and gas exploration and production capacities;
iv. A prohibition on completing crude oil projects in Russia, such as the Vostok oil project;
v. A prohibition on the provision of temporary storage for Russian crude oil and petroleum products within the EU;
vi. A prohibition for any legal person, entity or body established in the EU, which is owned 25 % or more by a Russian natural or legal person, entity or body to provide services of transport of goods by road within the territory of the EU, including in transit, and a prohibition on increasing Russian participation in their capital above 25%;
vii. A prohibition on providing construction and civil engineering services, aiming to prevent the contribution, by EU operators, to the development of Russia’s infrastructure; and
viii. A prohibition to sell, license or transfer intellectual property rights or trade secrets related to software for the management of enterprises, and for industrial design and manufacture.
- Extension of flight ban
i. The 16th package introduces a basis on which to prohibit air carriers operating domestic flights within Russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to a Russian air carrier or for flights within Russia (as well as to any entity owned or controlled by such air carriers), from taking off from or overflying the territory of the EU.
- Derogations
i. The 16th package grants a derogation from the prohibition to import Russian Liquefied Natural Gas (LNG) through EU LNG terminals that are not connected to the interconnected natural gas system. A Member State that is not connected to the interconnected natural gas system may grant such a derogation to ensure its energy supply when the LNG is purchased, imported or transferred from a terminal located in another Member State that is connected to the interconnected natural gas system.
ii. The 16th package also provides for a derogation from the prohibition on the provision of construction, architectural and engineering services, legal advisory services and IT consultancy services that are strictly necessary for the functioning of a consular or diplomatic representation of Russia located in a Member State.
iii. Notably, the 16th package tightens certain exemptions, in some cases now requiring licences for activities previously subject to exemption or only a notification requirement (including in respect of dual-use and mass-market IT equipment and software).
- Obligation to exercise due diligence with respect to “other sensitive goods”
i. Council Regulation 2025/395, by reference to Decision 2025/394/CFSP, expands the obligation resting on EU business operators to implement due diligence mechanisms to assess and mitigate re-exportation risks, to additional goods (in addition to the list provided under Annex XL to Regulation 833/2014). This broader requirement, relating to the items listed in new Annex XLVIII (currently, certain generating sets and other switches) will enter into force as of 26 May 2025. EU operators are required to ensure that legal persons, entities and bodies established outside the Union that they own, or control also implement those mechanisms.
- Additional sanctions listings under Council Implementing Regulation (EU) 2025/389
The EU has added 48 individuals and 35 entities to its sanctions list, subjecting them to asset freezes and travel bans. These additions are mostly due to these parties’ involvement with the Russian military-industrial complex and maritime sector, circumvention activities, and Russian crypto-asset exchanges. The full list of designated persons is located in Annex I to Council Regulation 269/2014, which includes a new designated bank Joint Stock Company “Black Sea Development and Reconstruction Bank”.
- Measures targeting Belarus under Council Regulation (EU) 2025/392
EU Belarus sanctions were amended to broadly mirror Russia restrictive measures (as detailed under point 2 above).
- Measures pertaining to the non-Government controlled areas of Ukraine, under Council Regulation (EU) 2025/398, and to Crimea & Sevastopol, under Council Regulation (EU) 2025/401
Export of certain goods and technology that are also restricted by Council Regulation (EU) 833/2014 are now also restricted for export to the non-government-controlled areas, including software for the management of enterprises and software for industrial design and manufacture, and related intellectual property rights or trade secrets.
The provision to the non-government-controlled areas of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, IT consultancy, market research and public opinion polling, technical testing and analysis and advertising services are now also prohibited.
The following amendments were made to align these regulations with previous amendments to Russia sanctions:
- Clarifications to the definition of circumvention;
- Addition of a “best efforts” requirement in respect of non-EU parties owned or controlled by EU operators; and
- Directions regarding a voluntary self-disclosure mechanism, whereby national competent authorities would, in accordance with local laws, take such disclosure into account when applying penalties, provided that the EU operator can demonstrate they have undertaken adequate due diligence to assess their risk under the regulation.
