The 16th sanctions package against Russia

On the third anniversary of the Russian attack on Ukraine, the EU adopted its 16th sanctions package against Russia on February 24, 2025. We present the key additions:

Expansion of personal restrictions

Implementing Regulation (EU) 2025/389 expanded the list of natural and legal persons, organizations and bodies (“POEs”) in Annex I to Regulation (EU) 269/2014 by 48 natural persons and 35 bodies. As a result, the assets of the newly listed natural persons and bodies will be frozen. Furthermore, they may not be provided with funds or economic resources (so-called prohibition on making resources available).

Expansion of the list of ships of the so-called "shadow fleet"

An additional 74 ships have been added to Annex XLII of Regulation (EU) No 833/2014 ("Regulation 833/2014") concerning the Russia embargo. This brings the total number of ships listed in Annex XLII of Regulation 833/2014 to 153. These are said to be ships of Russia's so-called "shadow fleet," which is used, among other things, to circumvent the oil price cap.

Further listings in Annex IV of Regulation 833/2014

Annex IV has been expanded by 53 companies. Only one-third of the 53 newly listed companies are based in Russia. The majority are based in other third countries, namely China (including Hong Kong), India, Kazakhstan, Singapore, Turkey, the United Arab Emirates, and Uzbekistan. Listing in Annex IV specifically prohibits the sale, supply, transfer, or export of dual-use goods and goods listed in Annex VII of Regulation (EC) No 833/2014 to these POE countries. Annex XI of Regulation (EC) No 833/2014 was amended to include raw aluminum of HS heading 7601, so that it is now also prohibited, directly or indirectly, to purchase, import into the Union, or transfer primary aluminum if it originates in or was exported from Russia. However, exceptions linked to import quotas apply for a transitional period until February 26, 2026. Expansion of export-side prohibitions: Annexes VII and XXIII of Regulation (EC) No 833/2014 have been expanded. They now include, in particular, dual-use chemical starting materials, chromium ores and chromium compounds, software related to numerically controlled machine tools (so-called CNC machines), and video game controllers for controlling drones on the battlefield. New transaction prohibitions: A transaction prohibition applies to ports, locks, and airports listed in Annex XLVII, Parts A and B, of Regulation (EC) No 833/2014. Furthermore, the transaction ban was tightened with regard to credit or financial institutions that use the Russian Central Bank's System for the Transmission of Financial Messages (SPFS) to circumvent sanctions by including three banks in Annex XLIV of Regulation (EC) No 833/2014 for the first time. Prohibition on the provision of construction services: Article 5n(2) of Regulation (EC) No 833/2014 was amended to include services in the construction sector. This means that EU companies are now completely prohibited from providing construction services to the Russian government or to legal persons, organizations or bodies established in Russia. General Authorization (“GAI”) No. 42 remains valid, but not for the time being with regard to the newly inserted prohibition concerning services in the construction sector. New Sanctions against Belarus: The sanctions against Belarus laid down in Regulation (EC) No. 765/2006 have also been extended. The changes essentially correspond to the tightening of sanctions against Russia described above. Occupied Ukrainian Territories: With regard to Russian-occupied territories in the Kherson, Donetsk, Luhansk, and Zaporizhzhia regions, as well as Crimea and Sevastopol, it is now generally prohibited to sell, supply, transfer, or export banknotes of an EU Member State's currency to, or for use in, these territories, to POE (People's Economic Enterprises) in these territories. Furthermore, prohibitions on providing services in these territories, based on Article 5n of Regulation (EC) No 833/2014, were introduced. Section 42 of the General Equal Treatment Act (AGG) does not apply in this regard. In addition, corresponding obligations to make efforts regarding subsidiaries in third countries, based on Article 8a of Regulation (EC) No 833/2014, were introduced. Pursuant to Article 13a of Regulation (EC) No 2022/263 and Article 8a of Regulation (EC) No 692/2014, respectively, public undertakings (POEs) are required to "make every effort to ensure that legal persons, bodies or organizations owned or controlled by them, established outside the Union do not engage in activities that undermine the restrictive measures laid down in this Regulation." Furthermore, export prohibitions were expanded by including additional goods in Annex II of Regulation (EC) No 692/2014. What companies should do now: In light of the expansion of personalized sanctions, companies should ensure that they take the new listings into account as part of their sanctions list screening. Furthermore, companies should assess, based on their business activities and product range, whether and to what extent they or their products could be affected by the new regulations. Based on the results of this assessment, the Internal Compliance Program (ICP) may need to be adjusted.