16th EU sanctions package against Russia – the most important changes

February 24, 2025 marked the third anniversary of the significant expansion and escalation of the armed conflict by Russia against Ukraine. The member states of the European Union (EU) agreed on a further, 16th package of sanctions against Russia in order to send a strong signal of determination. 

Sanctions in the energy, trade, transport, infrastructure and financial industry sectors

The 16th sanctions package systematically targets important sectors within the Russian economy. The EU is also once again focusing on the circumvention of trade restrictions. In the following, we have outlined the most important changes to the regulations, in particular Regulation (EU) 833/2014 (“Russia Embargo Regulation”). 

Extended due diligence obligations

Exporters of “sensitive goods” are now subject to the special additional due diligence obligations of Art. 12gb of the Russia Embargo Regulation. Accordingly, companies must perform a risk analysis with regard to the dangers of exporting such goods to or for use in Russia. They are also obliged to take risk management measures to minimize the risk. This does not apply to deliveries to partner countries. The extended due diligence obligations also apply to third country subsidiaries if they trade in such goods. The EU is yet to determine which criteria make goods particularly sensitive.

Regulation (EU) 765/2006 also imposes special due diligence obligations to a similar extent (see Art. 8ga Regulation (EU) 765/2006). This regulation sets out the obligations for trade in so-called common high priority goods and power generating sets with the CN code 850220 as well as other switches with the CN code 853650. However, the latter goods are not designated as “sensitive goods”. Whether the EU will nevertheless consider the same goods to be sensitive under the Russia embargo regulation is still unclear. We will keep you informed of further developments on this page.

Import bans for aluminum products

In addition to the existing ban on imports of iron and steel products from Russia, the 16th sanctions package includes a ban on imports of aluminum from Russia to the EU.

Measures against circumvention of the oil price cap

Furthermore, the sanctions include measures against the Russian shadow fleet as well as transaction bans with ports, airports and locks. Both are also related to circumvention measures to avoid the oil price cap on Russian oil.

The shadow fleet largely consists of obsolete ships that sail under non-Russian flags and whose ownership is often unclear. Among other things, these ships are used to transport grain stolen from Ukraine and Russian oil – the latter bypassing the oil price cap imposed by the G7 states.

Environmental protection organizations fear an environmental disaster in the Baltic Sea, as the seaworthiness of the ships in the shadow fleet is sometimes considered doubtful. Other concerns include possible sabotage of data cables by the ships’ crews.

Sanctions in the banking sector

Thirteen additional Russian banks will be excluded from the “SWIFT” financial communication system. In addition, non-Russian credit and financial institutions participating in the SFPS system will be sanctioned. Further measures are also being taken against the Russian financial sector.

Transaction bans

These bans apply to chemical precursors, chrome, machine parts and devices that can be used to control combat drones (including video game consoles, controllers and flight simulators).

Prohibition of services for certain sectors

The new sanctions package prohibits the provision of services for Russian oil and gas refineries.

Extension of the list of sanctioned persons, organizations and institutions

It is worth noting that around two thirds of the sanctioned persons are not Russian, but are sanctioned, for example, for participating in acts of circumvention.

In addition, comprehensive bans on transactions and services were issued in connection with individuals or legal entities, organizations or institutions in Crimea, Sevastopol or Russian-controlled territories or for use there.

Entrepreneurs and companies should bear in mind that an export control violation is a criminal offense that can be punished with a severe prison sentence. Let us help you check whether there is a need for action for your organization and feel free to contact us if you need any advice in the areas of foreign trade or customs law.