16th package of EU Sanctions against Russia’s invasion of Ukraine

The EU Council adopted the 16th package of restrictive measures on 24 February 2025, precisely three years after the launch of the armed conflict in Ukraine.

This new package expands the scope of the prohibitions across numerous sectors of the Russian economy, with a heightened focus on tackling circumvention, particularly in the maritime sector.

I.                    GENERAL OVERVIEW

The 16th package introduces key updates to the listing criteria and broadens the range of individuals and entities subject to restrictive measures:

·       Assets freezing: 48 individuals and 35 entities are added to the list subject to an asset freeze and a prohibition on making funds and economic resources available to them.  These individuals and entities are considered significant support to the Russian military complex or actively involved in sanctions circumvention ;

 ·       Anti-circumvention:  74 vessels are listed as they are forming a shadow fleet and contributing to Russia’s energetic revenues.  Those vessels are subject to a port access ban, a prohibition to obtain maritime and other services (insurance and brokering, flag registration, ship supply services, cargo loading services…);

 ·       Trade restrictions: five additional categories of sensitive items as advanced technologies are subject to export restrictions (e.g., dual-use chemical precursors).  Additionally, minerals, chemical, steel, glass materials are subject to export bans;

 ·       Financial sector: extension of the transaction ban in an attempt to list financial institutions and crypto asset providers that participate in the circumvention of the Oil Price Cap and facilitate transactions with listed vessels of the shadow fleet;

 ·       Transport: prevention of Russian ownership of more than 25% in EU road transport companies. This measure aims to reduce any potential attempt of circumvention through purchase by Russian persons of EU road transport undertakings.

II.                  FOCUS

Ø  Including two new criteria for listing individuals and entities

The new package includes two new criteria for listing individuals and entities in an effort  to effectively tackle the so-called “dark/shadow fleet” transporting Russia’s energy exports and to align with the measures adopted by the US Office of Foreign Assets Control (OFAC) on 10 January 2025.

The new criteria result in the listing of individuals and legal entities (i) involved in vessels transporting Russian crude oil through high-risk shipping practices (e.g., AIS manipulation, concealed ship-to-ship transfers, or document falsification), or (ii) linked to Russia's military-industrial complex, including those providing material, financial, or logistical support for military technology, defense operations, and related supply chains.

Ø  Protective measures for EU operators

The 16th package defines measure shielding EU operators from Russian retaliatory measures.

EU operators are entitled to claim compensation for direct or indirect damages resulting from :

a.       Legal actions initiated by sanctioned entities or individuals in third countries (notably Russia);

and

b.      Disruptions to the performance of contracts or operations affected by EU sanctions.

To benefit from that protection, EU operators must demonstrate the lack of effective legal remedies in the jurisdiction where the foreign proceedings were initiated.

This provision aims to deter sanctioned entities from exploiting foreign courts to penalize EU operators complying with the EU sanctions.

Moreover, when no EU court has jurisdiction to hear such a claim, the new sanction Regulation provides for a forum necessitatis. This is a last-resort jurisdictional forum whereby EU courts may hear such claims when a sufficient connection exists with the Member State where the Court is located. For example (i) the EU operator’s domicile or place of business is in that Member State; or (ii) the EU company is incorporated under the laws of that Member State.

III.                KEY FIGURES FROM THE NEW LISTING

Notable figures highlight the 16th package's impact: 

a.       83 additional listings: 48 individuals linked to Russia’s military-industrial complex, circumvention efforts, and disinformation campaigns, and                35 entities involved in sectors such as maritime transport, crypto asset services, and industrial supply chains;

b.      74 additional vessels added to the sanctions list. The total listed vessels now number 153;

c.    53 new companies facing export restrictions, among which 34 companies based outside Russia, underscoring the EU’s focus on addressing international circumvention networks;

d.    13 additional financial institutions prohibited from accessing specialized financial messaging services and three banks added to the transaction ban due to their use of Russia’s SPFS to circumvent sanctions;

c.    two Moscow airports and four regional airports are targeted by the transport ban measures, plus five major ports;

e.    Eight additional media outlets in the EU where suspended.

See Regulation (EU) 2025/390, Regulation (EU) 2025/392, Regulation (EU) 2025/395 and Regulation (EU) 2025/398.

For more information, please contact:

Bruno Lebrun – Partner – b.lebrun@janson.be

Cédric Alter – Partner – c.alter@janson.be