On February 24, 2025, three years after Russia’s large-scale aggression against Ukraine, the Council of the European Union adopted its 16th sanctions package aimed at strengthening restrictive measures against Russia. These new measures are designed to expand the European Union’s arsenal of sanctions, targeting key sectors of the Russian economy and adding new entities, companies, vessels and individuals to the list of sanctioned entities, with a particular emphasis on third-country actors involved in sanctions circumvention.
Similar provisions have also been included in the regime sanctioning Belarus.
Extension of export restrictions on technology items used for military ends
- Dual-use chemical precursors, including cholopicrin, used by Russia as chemical weapons.
- Chromium ores and compounds.
- Software related to Computer Numerical Control CNC) machine tools : These software programs are used to design parts and components on an industrial scale.
- Video game controllers, used by the Russian army to pilot drones.
Restrictive measures targeting key products and services of the Russian economy
- Primary aluminum originating or coming from Russia is now banned from import into the EU. The ban is being implemented progressively, with a one-year quota set at 80% of European consumption. It is important to stress that, unlike the restrictions on steel, this ban does not extend to products manufactured or processed in a third country from Russian raw aluminum.
- The energy sector is also targeted, with a ban on the export of goods, technologies or services required for the completion of Russian oil projects, as well as a ban on the supply of oil and gas exploration software. The temporary deposit or free-zone placement of Russian oil products on EU territory, which was previously authorized, is now prohibited.
- Construction and civil engineering services have also been added to the list of prohibited sectors, with a few exceptions, such as the health sector.
- Limit on ownership of road transportation companies: Russian ownership of European road transportation companies is limited to 25%.
Anti-circumvention measures & new listed entities
- The sanctions package also includes third-country carriers supplying aviation goods to Russian airlines or operating domestic flights in Russia on the list of companies banned from flying to the European Union.
- Companies and smaller banks have been added to the list of sanctioned entities for their role in circumventing sanctions and oil price caps, notably through the use of crypto-assets. Furthermore, 16 additional financial institutions have been excluded from the SWIFT banking system or listed for their use of the Russian SPFS banking system.
- Last but not least, one of the major contributions of the 16th European sanctions package is the extension of the list of sanctioned persons to include entities linked to the activities of the Russian “shadow fleet”, as well as those involved in or benefiting from the Russian military and industrial complex. For this 16th sanctions package, almost two-thirds of the 53 new sanctioned companies are located in third countries (notably China, India and Turkey).
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