In response to the Russian Federation's activities targeting Ukraine and the recognition of Luhansk/Donetsk as independent regions, EU foreign ministers have authorized eighteen packages of sanctions. The packages include several regulations limiting Russia's access to the capital market. Moreover, they include financial sanctions against certain individuals and companies as well as export bans and implement a price cap on Russian crude oil and certain oil products. Violations are subject to severe penalties.
In the following, we provide a general overview of the sanctions regime and explain what companies need to do now.
I. New Sanctions
18th package of Sanctions
On 19 July 2025, the EU launched its 18th sanctions package against Russia (Regulation (EU) 2025/1494, Regulation (EU) 2025/1476, Regulation (EU) 2025/1472 and Regulation (EU) 2025/1469). The focus is on the energy, banking and military sectors. Efforts to combat the circumvention of existing sanctions will also be stepped up.
- Reduction of the price cap for Russian crude oil from 60.00 to 47.60 US dollars per barrel. In future, the price cap will be adjusted flexibly and will always be 15 per cent below the global oil price.
- Shadow fleet expanded by 105 ships. This means that a total of 444 ships are now excluded from port access and services. In addition, for the first time, natural persons operating the shadow fleet or involved in trade in Russian crude oil will also be sanctioned.
- Import ban on products made from Russian crude oil that have been refined in third countries. Importers must provide appropriate proof that the crude oil does not originate from Russia. Products from the United States, Canada, Norway, Switzerland and the United Kingdom are exempt.
- Transactions related to Nord Stream 1 and 2 are prohibited. This includes maintenance, operation or completion. This rules out any restart of the pipelines.
- Further sanctions against the banking sector: 45 Russian banks have been completely cut off from the European financial system. For the first time, banks from third countries such as China and Turkey are also affected. The supply of banking software to Russian financial institutions is also prohibited.
- Extension of export restrictions on dual-use goods: Newly affected items include CNC machines and chemical substances for fuel production. Sanctions also apply to companies from Russia, China, Hong Kong and Turkey.
- Further 80 individuals are being sanctioned.
17th package of Sanctions
On 20 May 2025, the EU adopted its 17th and most comprehensive sanctions package against Russia (Regulation (EU) 2025/932, Regulation (EU) 2025/933, Regulation (EU) 2025/958, Regulation (EU) 2025/994 and Regulation (EU) 2025/965). The aim is to prevent Russia from accessing military-related technology and to significantly reduce its revenues from the energy sector.
- Doubling of the shadow fleet to 342 ships: The ships listed in Annex XLII are no longer allowed to call at European ports and will no longer receive any services. Individual financial sanctions have also been imposed on the operators of the shadow fleet. This includes shipping companies from countries such as Turkey and the United Arab Emirates that are deliberately circumventing the sanctions.
- Focus on Russian military economy: The EU is sanctioning over 45 companies and individuals that supply the Russian military with drones, weapons, ammunition and components. For the first time, Chinese and other foreign companies that supply machine tools for Russian arms production are also being listed.
- Further export restrictions apply to goods that contribute to military and technological rearmament. Dual-use goods, i.e. products that can be used for both civilian and military purposes, are particularly affected. New restrictions apply, to chemical precursors and machine parts that can be used for military purposes. 31 additional companies are being listed for circumventing trade restrictions.
- In the energy sector, the Russian company Surgutneftegaz is subject to further sanctions. It is one of the country's largest oil companies.
- Further personal sanctions are being imposed on 75 additional individuals and organisations. A total of over 2,400 actors are now affected. They are subject to asset freezes and a ban on financing by EU citizens and companies. In addition, these individuals are no longer allowed to enter or transit through the EU.
16th package of Sanctions
On 25 February 2025, the 16th sanctions package came into force on the occasion of the third anniversary of the Russian invasion of Ukraine (Regulation (EU) 2025/395 and Regulation (EU) 2025/390). It once again focuses on circumvention schemes, in particular by combating the so-called "shadow fleet" and introducing further sector-specific trade restrictions, including in the infrastructure, energy and services sectors.
- Listing of 74 additional vessels belonging to the shadow fleet: Vessels listed in Annex XLII may not call at ports or locks in the Union. Their import, purchase, sale, export, operation and the provision of other services is also prohibited.
- Ban on imports of Russian aluminum: There is a one-year transition period during which a total of 270,000 tons of Russian aluminum may be imported into the EU.
- Extension of the lists of goods: The lists of goods contained in the annexes to Regulation (EU) 833/2014 have been extended, e.g. to include goods used to complete facilities for oil exploration and production, as well as space goods. Furthermore, the license-free export of dual-use items and items listed in Annex VII for medical and humanitarian purposes is restricted to the extent that a license is required for items listed in Annex XL, even for the aforementioned purposes.
- Further expansion of the sanctions list by 83 entries, including 48 individuals and 35 organizations.
- Extension of the services ban: In the future, it will also be prohibited to provide construction services. The ban also covers the transfer of licenses, trademark rights and trade and business secrets related to business software.
- Russian infrastructure: The new measures include a comprehensive ban on transactions in certain areas of Russian infrastructure, such as airports, ports and locks.
15th package of Sanctions
On 16 December 2024, the 15th package of EU sanctions against Russia came into force (Regulation (EU) 2024/3192 and Regulation (EU) 2024/3189). In contrast to previous packages of measures, this package only brings a few changes.
- Extension of the deadline for wind-down operations: To make it easier for EU companies to withdraw from business with Russia, existing authorizations and exemptions are extended until 31 December 2025.
- Protection against Russian court rulings: A new regulation has been introduced to refuse recognition in the EU of Russian court rulings related to Article 248 of the Arbitrazh Procedure Code.
- New listing of vessels of the so-called "shadow fleet": The list of vessels in Annex XLII is extended by 52 entries. Vessels listed there are not allowed to call at any ports or locks in the Union. In addition, their import, acquisition, sale, export, operation and the provision of other services is prohibited.
14th package of Sanctions
On 25 June 2024, the 14th EU sanctions package against Russia came into force (Regulation (EU) 2024/1739 and Regulation (EU) 2024/1745). It addresses existing enforcement problems and includes new measures in the area of liquefied natural gas (LNG) as well as sanctions against ships that support Russia's war against Ukraine.
- Better enforcement of the measures and prevention of circumvention, in particular EU companies are responsible for monitoring their subsidiaries established outside the Union with regard to potential circumvention constellations (Article 8a of Regulation (EU) 833/2014)
- Ban on investment in LNG projects in Russia: Exports for the benefit of these projects are also covered. After a nine-month transition period, the use of EU ports for the transshipment of Russian LNG will be prohibited. Imports of Russian LNG will only be permitted at terminals connected to the EU gas pipeline network.
- Listing of 27 ships contributing to warfare: Ships listed in Annex XLII may not enter at ports or locks in the Union. Their import, purchase, sale, export, operation and the provision of other services is also prohibited.
- Specification of the import ban on Russian diamonds: Protection for goods that were already in the EU or in any case outside Russia before the ban came into force.
- Dual-use and high-tech goods: expansion of the list of goods (e.g. microwave amplifiers, off-road vehicles, chemicals, plastics, vehicle parts and manganese ores). In addition, the export of the above goods to 61 listed organizations (Russian and non-Russian) that are directly or indirectly linked to the Russian military complex will be restricted.
- Further expansion of the sanctions list by 116 entries, including 69 individuals and 47 organizations.
- Financial sanctions: EU banks outside Russia are prohibited from using the SPFS financial messaging system (Russian equivalent of SWIFT). In addition, a ban is introduced on transactions with banks and providers of crypto assets in Russia and third countries that facilitate transactions to support Russia's defense industrial base.
13th package of Sanctions
On the second anniversary of the Russian attack on Ukraine, the EU adopted a 13th sanctions package against Russia on 23 February 2024. It includes further restrictions on Russian access to military technology, e.g. drones. In addition, further companies and individuals involved in the Russian war effort were added to the EU sanctions list.
- Unprecedented expansion of the sanctions list by a total of 194 additions, including 106 individuals and 88 entities
- Measures to strengthen air defence: The EU wants to reaffirm its determination to prevent Russia from acquiring sensitive Western technology for its military. To this end, 27 additional companies from Russia and third countries have been added to the list of entities cooperating with the Russian military-industrial complex (Annex IV)
- Export bans on drone components, including electronic transformers, power converters and induction coils that are installed in drones and aluminum capacitors that can be used for military purposes
- Inclusion of the United Kingdom to the list of partner countries for the indirect import ban on iron and steel
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