The EU’s 16th Sanctions Package: What Is New?

Authors: Annika Lampela, Juuso Lumilahti, and Anna-Maria Tamminen

On 24 February 2025, on the third anniversary of Russia’s invasion of Ukraine, the European Union (EU) adopted its anticipated 16^th package of sanctions against Russia. The 16^th package is intended to target strategically important sectors of the Russian economy and tackle the problem of sanctions circumvention. The sanctions regimes concerning Belarus, Crimea, Sevastopol, and the non-government-controlled areas of Donetsk, Kherson, Luhansk, and Zaporizhzhia oblasts were also strengthened. Below, we summarise the key changes brought on by the package.

1. Russian aluminium imports banned, among other trade measures. The sanctions package introduces a number of new product-specific sanctions, perhaps most notably a direct import ban on Russian aluminium. While previous sanctions already prohibited the import of processed aluminium goods from Russia, the 16^th package extends this ban to include primary aluminium as well. The ban is significant because the majority of aluminium in the EU is imported, and although imports of Russian aluminium have decreased in the past years, Russia continues to supply aluminium for use in the EU.

To facilitate the transition for businesses, the package introduces a one-year transition period, during which 275,000 tons of primary aluminium may still be imported from Russia. This quota corresponds to approximately 80% of EU aluminium imports from Russia in 2024.

The package includes several new export restrictions in addition to the primary aluminium import restriction. The package extends export restrictions on dual-use products by banning the export of dual-use chemical precursors to produce chloropicrin and other riot control agents, software related to computer numerical control (CNC) machine tools, video-game controllers, and chromium ores and compounds. The package also clarifies and tightens the derogations and exemptions for the export of certain dual-use and advanced tech exports. Furthermore, the package introduces additional export restrictions on industrial goods which may have military significance, including minerals, steel, glass material, chemicals, and fireworks.

2. Russia’s shadow fleet targeted, additional entities sanction-listed, and further anti-circumvention measures taken. A key objective of the 16^th package is to strengthen the efficacy of sanctions by curbing sanctions circumvention. This includes cracking down on Russia’s “shadow fleet” by introducing new individuals and entities to the sanctions list; the package targets 74 additional vessels which are part of the shadow fleet or contribute to Russia’s energy revenues.

In addition to the listed vessels, the package adds 48 individuals and 35 entities to the sanctions lists. Among the entities listed is the Russian crypto exchange Garantex, closely associated with sanctioned banks and sanctioned by the United States and United Kingdom in 2024. The move is intended to target the use of cryptocurrency in circumventing sanctions. The package also imposes targeted export restrictions on 53 new companies—including 34 companies located outside of Russia—which support Russia’s military and industrial complex or engage in sanctions circumvention.

Sanctions circumvention in the financial sector is addressed by imposing a transaction ban on three banks established outside of Russia which use the “System for Transfer of Financial Messages” of the Central Bank of Russia (“SPFS”), the Russian equivalent of the SWIFT system. In addition, the package bans an additional 13 regional banks from providing specialised financial messaging services. The package further extends the EU’s transaction ban to enable the listing of financial institutions and crypto asset providers which facilitate transactions with listed vessels and participate in the circumvention of the oil price cap.

The 16th package also introduces other new criteria for adding individuals and entities to sanctions lists to further combat sanctions circumvention. These criteria target those who support the operation of unsafe oil tankers and individuals and entities that support, benefit from, or are part of Russia’s military and industrial complex.

3. Energy, transport, and infrastructure targeted. The package includes further measures in the energy, transport, and construction industries. Sanctions targeted at Russian oil include the total ban on the temporary storage or placement under free zone procedures of Russian crude oil or petroleum products in EU ports. Previously, this was allowed if the oil complied with the price cap and was destined for a third country. Additionally, the prohibition on providing goods, technology, and services for Russian liquified natural gas projects now also includes crude oil projects in Russia, such as the Vostok oil project. Furthermore, the package broadens the existing software ban to restrict the export, supply, or provision of oil and gas exploration software to Russia.

Russian infrastructure is also targeted, as the package prohibits all transactions with specific Russian ports and airports. This prohibition is tempered, however, by exemptions intended to ensure that essential trade flows and individual trade can continue without interruption. Furthermore, the package bans EU operators from providing construction services in Russia. Previously, EU operators were only banned from providing architectural and engineering services in Russia.

Beyond Russia, the package allows third-country carriers which conduct domestic flights in Russia or supply aviation goods to Russian airlines or for domestic flights in Russia to be listed under the flight ban, meaning that if listed, these airlines will no longer be allowed to fly to EU Member States. The previous road transport prohibition is also tightened, as the package includes an amendment prohibiting increasing Russian ownership in EU road transport undertakings above 25%.

4. Measures against Russian propaganda. In order to curb the spread of misinformation by Russia within the EU, the package suspends the broadcasting licences of an additional eight media outlets which are under the permanent control of Russian leadership. The measures only target broadcasting activities and do not prevent the employees of these media outlets from, for example, conducting research in the EU.

The adoption of the 16^th sanctions package emphasises the EU’s continued support for Ukraine. While the contents of the package cannot be considered surprising, it demonstrates that companies operating in the EU must continue to stay vigilant in ensuring their compliance with the EU’s sanctions regime.

We continue to follow closely the updates on the EU sanctions legislation.