Editor’s Note
This article outlines the key details and immediate legal effect of the EU’s 16th package of economic sanctions against Russia, which came into force on February 25, 2025.
The 16th package of European economic sanctions, adopted and published in the Official Journal of the European Union (EU) on February 24, 2025, entered into force on February 25, 2025.
This 16th package of economic sanctions impacts the various economic sanctions regimes adopted by the EU in response to Russia’s unjustified military aggression against Ukraine:
• Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilizing the situation in Ukraine (hereinafter, the “Russia Regulation”) – as amended by Council Regulation (EU) 2025/395 of February 24, 2025;
• Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (hereinafter, the “Individual Sanctions Regulation”) – as amended by Council Regulation (EU) 2025/390 of February 24, 2025;
• Regulation (EU) 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (hereinafter, the “Belarus Regulation”) – as amended by Council Regulation (EU) 2025/392 of February 24, 2025;
• Regulation (EU) 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol (hereinafter, the “Crimea Regulation”) – as amended by Council Regulation (EU) 2025/401 of February 24, 2025;
• Regulation (EU) 2022/263 concerning restrictive measures in reaction to the illegal recognition, occupation and annexation by the Russian Federation of certain non-government controlled areas of Ukraine (hereinafter, the “Other Ukrainian Oblasts Regulation”) – as amended by Council Regulation (EU) 2025/398 of February 24, 2025.
In parallel with the adoption of this 16th sanctions package, the European Commission published a Frequently Asked Questions (hereinafter, the “FAQ”) to clarify certain provisions.
This alert (hereinafter, “Alert”) aims to provide a summary of the new measures likely to impact your activities.
Alignment of Other Regulations with the Russia Regulation:
Alignment of the different sanctions regimes regarding the “best effort” obligation as provided for by Article 8bis of the Russia Regulation and Article 8decies of the Belarus Regulation since the 14th sanctions package of June 24, 2024:
• Article 15bis of the Individual Sanctions Regulation;
• Article 8bis of the Crimea Regulation;
• Article 13bis of the Other Ukrainian Oblasts Regulation.
Combating the Russian “Shadow Fleet” of Vessels:
• Addition of 74 more vessels, bringing the total number of vessels listed (Annex XLII of the Russia Regulation) to 153. These vessels are part of the Russian “shadow fleet” or have contributed to Russia’s energy revenues;
• New designation criterion for the asset freeze list (Article 3 of the Individual Sanctions Regulation): natural or legal persons, entities or bodies that own, control, manage or operate vessels transporting crude oil or petroleum products originating from or exported from Russia while engaging in illegal shipping practices or that provide, in any other way, material, technical or financial support to the operations carried out by such vessels.
Targeted Export Restrictions:
Addition of 53 new entities (including 35 non-Russian: Chinese or Hong Kong, Indian, Kazakh, Uzbek, Turkish, Singaporean or Emirati) to the list (Annex IV of the Russia Regulation) of entities for which export controls on dual-use goods and goods listed in Annex VII of the Russia Regulation are strengthened, due to their support for the Russian military-industrial complex or their engagement in sanctions circumvention.
Amendment of the Individual Sanctions Regulation:
• Addition of 48 persons and 35 entities to the list in Annex I of the Individual Sanctions Regulation (list of natural or legal persons, entities or bodies subject to the freezing of their funds and economic resources and the prohibition of making funds and economic resources available to them).
• New designation criterion for the asset freeze list (Article 3).