24 February 2025 marked the third anniversary of Russia’s invasion of Ukraine. It is on this symbolic date that the European Union adopted new sanctions measures against Russia, in its 16th sanctions package. Apart from updating existing sanctions, for example by additional listings and adding additional vessels to Russia’s ‘shadow fleet’, more restrictive measures are introduced to put extra pressure on important sectors of the Russian economy such as energy, trade, transport and financial services.
The 16th sanctions package contains the following measures:
- EU import ban on primary aluminium from Russia. This ban is added to the already existing import ban on processed aluminium. The 16th package provides for a 12-month transition period with a quota mechanism, giving European companies time to adjust.
- Extension of dual–use export restrictions. Additional items have been identified as restricted dual-use items which may not be exported to Russia in order to prevent Russia using these items on the battlefield. These items now include chemical precursors (which can be used as chemical weapons), software for Computer Numerical Control (CNC) machine tools (used to manufacture weapons) and video-game controllers (used to steer drones), as well as chromium ores and compounds. Further, additional export restrictions are introduced on specific industrial goods (e.g. minerals, chemicals, steel, glass), which could have a dual-use purpose.
- Further energy-related measures. The leeway that was granted to the energy sector in order to adjust to the situation, is now gradually being taken away. Temporary storage of Russian crude oil or petroleum products in EU ports, which was allowed under certain circumstances, is now forbidden. No goods, technology or services may be provided anymore for the completion of Russian LNG projects. Lastly, the existing software ban for oil and gas exploration software to Russia is broadened.
- Transport/infrastructure measures. Third-country carriers conducting domestic flights in Russia or supplying aviation goods to Russia are no longer allowed to fly to the European Union. Further, a full transaction-ban with specific Russian infrastructure ports is introduced, including two Moscow airports and the Novorossiysk port. As for road transport, the 16th package intends to prevent Russian ownership in EU road transport companies going beyond 25% (thereby preventing circumvention of existing sanctions).
- Further measures on the financial sector. 13 financial institutions are added to the list subject to the prohibition to provide specialised financial messaging services. 3 other Russian banks are now subject to the transaction ban, while the EU means to target crypto asset providers as well.
- Measures against disinformation. 8 media outlets are added to the list of entities of which the broadcasting activities are suspended in the EU.
- Additional listings. As with every sanctions package, new individuals (48) and entities (35) are added to the ‘sanctions list’, which means their assets within the EU will be frozen and all transactions with these designated entities and individuals are forbidden.
- Additional anti-circumvention measures. The 15th package targeted Russia’s shadow fleet and the EU is continuing this trend by adding 74 additional vessels to this list, therewith almost doubling it. Vessels on the shadow fleet (no matter under which flag they are sailing) may not access EU ports and a broad range of services may not be provided to them. Further, targeted export restrictions are imposed on 53 companies (of which 34 are from third countries) who either support Russia’s military sector or have engaged in sanctions circumvention.
For detailed information on the previous 15 packages of restrictive measures against Russia, please see: EU sanctions measures against Russia.
This publication is provided for your convenience and does not constitute legal advice.
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