Editor’s Note
This article outlines the key provisions of the EU’s 16th sanctions package, which entered force on 25 February 2025. A central focus of these new measures is strengthening enforcement and closing loopholes to combat the circumvention of existing sanctions against Russia.
The 16th package of European economic sanctions adopted and published in the Official Journal of the European Union (hereinafter the “EU”) on 24 February 2025 came into force on 25 February 2025.
This 16th package of economic sanctions affects 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 with regard to destabilizing Russian actions in Ukraine (hereinafter, the “Russia Regulation”) – as amended by Council Regulation (EU) 2025/395 of 24 February 2025;
* Regulation (EU) 269/2014 concerning restrictive measures with regard to 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 24 February 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 24 February 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 24 February 2025;
* Regulation (EU) 2022/263 concerning restrictive measures in response to the illegal recognition, occupation and annexation by the Russian Federation of certain areas of Ukraine not controlled by the Government (hereinafter, the “Other Ukrainian Oblasts Regulation”) – as amended by Council Regulation (EU) 2025/398 of 24 February 2025.
Alongside the adoption of this 16th package of sanctions, the European Commission has published a frequently asked questions (hereinafter, the “FAQ”) to clarify certain provisions.
This alert (hereinafter, the “Alert”) aims to provide a summary of the new measures that may impact your activities.
Alignment of the other Regulations with the Russia Regulation:
Alignment of the various sanctions regimes concerning the “best effort” obligation as provided for in Article 8a of the Russia Regulation and Article 8i of the Belarus Regulation since the 14th package of sanctions:
* Article 15a of the Regulation on individual penalties;
* Article 8a of the Crimea Regulation;
* article 13a of the Regulations other Ukrainian Oblasts.
Combating the “shadow fleet” of Russian vessels:
* Addition of 74 new vessels, bringing the total number of ships on the list to 153 (Annex XLII of the Russia Regulations). These vessels are part of the Russian “shadow fleet” or have contributed to Russia’s energy revenues;
* new criterion for designation on the assets freeze list (article 3 of the Individual Sanctions Regulation): natural or legal persons, entities or bodies who own, control, manage or operate vessels carrying crude oil or petroleum products originating in or exported from Russia while engaging in illegal shipping practices or who otherwise provide material, technical or financial support for the operations of such vessels.
Targeted export restrictions:
Addition of 53 new entities (including 35 non-Russians: Chinese or Hong Kong, Indian, Kazakh, Uzbek, Turkish, Singaporean or Emirati) to the list (Annex IV of the Russia Regulations) of entities for which export controls on dual-use goods and goods listed in Annex VII of the Russia Regulations have been tightened, because of their support for the Russian military-industrial complex or their involvement in circumventing sanctions.
Amendment of the Individual Sanctions Regulation:
* Addition of 48 persons and 35 entities to the list in Annex I of Individual Sanctions Regulation (list of natural or legal persons, entities or bodies covered by the freezing of their funds and economic resources and the prohibition to make funds and economic resources available to them).
* New criterion for designation on the assets freeze list (article 3 of the Individual Sanctions Regulations): natural or legal persons, entities or bodies that are part of, provide material or financial support to, or benefit from, Russia’s military and industrial complex, including by participating in the development, production or supply of military equipment and technology.
Alignment of the other Regulations with the Russia Regulation:
This new criterion also applies to individuals and entities that form part of, support, or benefit from the military and industrial complex of Belarus (article 2(7a) of Belarus Regulation).