On February 19, 2025, the countries of the European Union reached an agreement in principle on a new sanctions package against Russia (the 16th). On February 24, the European Union adopted this package and it entered into force. To prevent circumvention, all the sanctions listed below also apply against Belarus. Below are the main proposed rules by category.
Expansion of sanctions lists
There were already several lists for individuals and companies that imposed certain specific sanctions, such as a freeze on all assets and a ban on travel to the European Union. New individuals and companies have been added to these lists. In total, there are nearly 100 additions. An additional 74 vessels are also subject to sanctions. These are mostly old ships likely to be used in the transportation of oil. They are now much more difficult to dock in international ports and it also becomes more difficult to obtain insurance. Entities that assist in operating unsafe oil tankers may also now face sanctions rules.
Trade restrictions
Goods have again been added to the list of so-called “dual-use goods,” also known as “dual-use goods. These are goods that can be used for both military and non-military purposes, such as boats. We wrote about dual-use goods and the sanctions on them earlier. In particular, the goods now included see software, video game consoles, machinery that can be used by the arms industry and substances for making chemical products. In addition, some exceptions to the sanctions on dual-use goods have been further tightened.
In addition, there will be a total import ban on aluminum from Russia. This year, a maximum of up to 80% aluminum may still be imported from Russia compared to last year. After this deadline, no Russian aluminum may be purchased at all.
New restrictions have been imposed on trade in certain minerals, chemicals, steel, glass and fireworks. These could, in fact, be used for specific military purposes. These are more far-reaching restrictions: sanctions previously applied to these goods.
Transport
Companies whose core business is road transport may not be more than 25% Russian-owned.
Airlines that are not based in the EU or Russia but operate domestic flights in Russia may be placed on a separate sanctions list. In that case, they will no longer be allowed to fly in European countries.
Financial
Three new banks have been designated with whom European parties may no longer do business at all. In addition, 13 financial institutions are no longer allowed to offer special messaging services. Also, the list of crypto providers that are no longer allowed to do business with has been expanded.
Infrastructure
European companies will no longer be allowed to do construction work in Russia. There will also be a complete transaction ban on certain infrastructure projects, such as airports near Moscow and ports on the Caspian Sea.
Energy
It is no longer allowed to (temporarily) store Russian oil in ports within the EU. The storage ban applies even if the price ceiling is met and the oil has another country as final destination. Furthermore, the system that previously only applied to Russian LNG projects will now also apply to crude oil projects. There will also be an export ban on software related to the export, delivery or provision of oil and gas to Russia.
Media
8 media companies will lose their European broadcast license. This means that they must cease all their activities.
Occupied territories
In addition to the sanctions already described above, additional restrictions have been adopted against (the Russian occupiers of) certain occupied territories. These include Crimea, Sevastopol, Donetsk, Kherson, Luhansk and Zaporizhzhia.
Press release
The full press release regarding the 16th sanctions package is available on the website of the European Commission.
Want to know more?
Do you have a question regarding sanctions on Russia? Or do you have another legal question? If so, please feel free to contact attorney John Wolfs, who has extensive experience in the areas of sanctions, international trade and corporate law.
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