The EU's 18th sanctions package against Russia

On July 18, 2025, the European Union (EU) adopted its 18th sanctions package against Russia, which entered into force on July 20, 2025. In addition to the sanctions against Russia relating to persons and goods, the sanctions against Belarus were also tightened. The package consists of the following regulations, all dated July 18, 2025: Regulation (EU) 2025/1494 amending Regulation (EU) No 833/2014 on restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine (“Regulation 833/2014”);

• Regulation (EU) 2025/1472 amending Regulation (EC) No 765/2006 on restrictive measures in view of the situation in Belarus and the involvement of Belarus in Russia’s aggression against Ukraine (“Regulation 765/2006”);

• Implementing Regulation (EU) 2025/1476 implementing Regulation (EU) No 269/2014 on restrictive measures in view of actions that undermine or threaten the territorial integrity, sovereignty and independence of Ukraine (“Regulation 269/2014”); and

• Implementing Regulation (EU) 2025/1469 implementing Article 8a(1) of Regulation 765/2006. The main changes and additions are presented below: Expansion of personal restrictions Annex I of Regulation (EC) No 269/2014 has been expanded to include 14 natural persons and 42 legal persons, organizations and bodies (“POEs”). The new listings of legal POEs include not only those based in Russia but also those from third countries such as China and the United Arab Emirates, which are either involved in the so-called Russian shadow fleet or supply arms and dual-use goods to Russia. In addition, Annex I of Regulation (EC) No 765/2006 has been supplemented by eight companies in the Belarusian arms industry. Among other things, this listing means that funds and economic resources may not be made available to the listed POEs, either directly or indirectly (so-called prohibition on making funds and resources available). ‍
• Amendments to Regulation (EC) No 833/2014 on the Russia Embargo
• Requirement for Authorization for the Export of Annex VII Goods to Third Countries
• The export of goods listed in Annex VII to third countries other than Russia now requires an authorization if the exporter has been informed by the competent authority that the goods in question are intended, or could be intended, wholly or partly for natural or legal persons in Russia or for use in Russia (Article 2a, paragraph 1aa). Furthermore, Part A has been amended to include various chemical components for fuels and Part B has been amended to include additional numerical machine tools. ‍
• Supplement to Article 3k and Annex XXIII
• Annex XXIII has been supplemented with further CN codes, found in the newly added Annexes XXIIIE and XXIIIF. Goods listed in Annex XXIII may not be sold, supplied, transferred, or exported, directly or indirectly, to POE in Russia or for use in Russia. The provision of numerous services related to these goods is also prohibited (Article 3k). Existing treaty provisions apply to the newly added goods, and in some cases, the competent authorities of the Member States may grant exemptions. Import ban on petroleum products made from Russian crude oil. Furthermore, the EU is introducing an import ban on, and a ban on the provision of certain services relating to, refined petroleum products manufactured in a third country from Russian crude oil (Article 3ma). This is intended to prevent Russian crude oil from indirectly entering the EU market. Reduction of the oil price cap. A key element of the 18th sanctions package is the reduction of the oil price cap, which, within the framework of G7 cooperation, has so far been set at US$60 per barrel of crude oil. This will be reduced to US$47.60 per barrel of crude oil with effect from September 3, 2025. At the same time, a dynamic mechanism was introduced that will allow for a semi-annual adjustment of the price cap to market conditions (Article 3n, paragraph 11).
• Expansion of the list of the Russian "shadow fleet"
• Changes have also been made to Annex XLII of Regulation (EC) No 833/2014, which lists ships of the Russian "shadow fleet" used, among other things, to circumvent the oil price cap. Three ships have been removed from Annex XLII of Regulation (EC) No 833/2014. In addition, seven entries have been corrected and a further 105 ships have been listed. A total of 444 ships are now listed in Annex XLII of Regulation (EC) No 833/2014 and are therefore subject to the restrictions under Article 3s.
• Prohibitions on the provision of services pursuant to Article 5n of Regulation 833/2014
• Article 5n(2b) in conjunction with Annex XXXIX has been amended to include software with certain uses in the banking and financial sector. Therefore, it is now also prohibited, with regard to this software, to sell, supply, transfer, export, or make available, directly or indirectly, to the Government of Russia or to legal entities established in Russia. If the software is to be made available to subsidiaries of EU or Annex VIII partner country companies, General Authorization No. 42 should apply.
• Transaction Prohibitions
• The existing transaction prohibitions have been supplemented and new transaction prohibitions have been introduced:
• The transaction prohibition in Article 5aa is supplemented by a new exception. According to the newly inserted paragraph 2f, the transaction prohibition shall not apply to subsidiaries established in the EU of POE listed in Annex XIX, which act on behalf of or at the direction of the parent company listed in Annex This new legal exception and the corresponding recitals are likely incompatible with the (non-legally binding) FAQ 36 of the German Federal Ministry for Economic Affairs and Energy (BMWi), according to which the transaction prohibition in Article 5aa(1)(c) should not, in principle, apply to EU subsidiaries of POE listed in Annex XIX, and thus supersede the statement in the FAQ. With regard to the transaction prohibition under Article 5ac(1), it should now be sufficient for inclusion in Annex XLIV that the POE in question uses the System for the Transmission of Financial Messages (SPFS) of the Central Bank of Russia or equivalent specialized messaging services for payment transactions established by the Central Bank of Russia or the Russian State (Article 5ac(1)). However, Annex XLIV has not yet been supplemented with further entries. In connection with the transaction ban in Article 5ad, two companies were listed in Annex XLV, Part A, for the first time, effective August 9, 2025, thus bringing the ban into force. Annex XLV, Parts B and C, however, remain empty for the time being. Furthermore, additional transaction bans were inserted into Regulation (EC) No 833/2014: Firstly, a ban was placed on all economic transactions, including transactions related to financing, concerning the completion, operation, maintenance, or use of the Nord Stream 1 and 2 pipelines (Article 5af, paragraph 1). This underscores Europe's strategic decoupling from Russian gas, although exceptions or authorizations may apply in individual cases. Secondly, transactions with the Russian Direct Investment Fund (RDIF) were prohibited under the newly inserted Article 5ag, paragraph 1. The transaction ban also extends to legal POE entities that are owned or controlled by the RDIF; listed in the newly added Annex XLIX or the also newly added (but currently empty) Annex L; or acting on behalf of or at the direction of one of the aforementioned organizations. The competent authorities may grant exemptions in individual cases. The ban on providing special messaging services for payments (“SWIFT decoupling”) has also been replaced by a comprehensive transaction ban. Annex XIV has been expanded by 22 additional entries, so that a total of 45 financial institutions are now listed in Annex Annex VIII has been extended to include goods that may not be sold, supplied, transferred, or exported, directly or indirectly, to or for use in Belarus by POE (People's Economic Enterprises). Existing contractual arrangements and licensing options remain partially applicable. A new export licensing requirement is also introduced for goods listed in Annex Va, in accordance with Article 2a, paragraph 1aa of Regulation (EC) No 833/2014. Exports to countries other than Belarus require authorization if the exporter has been informed by the competent authority that the goods in question are intended, or could be intended, wholly or partly for or for use in Belarus by POE (Article 1f, paragraph 1aa). The prohibition contained in Article 1zb, paragraph 1, on providing specialized payment services to POE listed in Annex XV or POE whose shares are at least 50% held by such a listed POE (“SWIFT decoupling”) is also replaced by a complete prohibition on transactions with the POE concerned. Exceptions apply in individual cases, or the competent authorities of the Member States have the option to grant authorization.