16th package of EU sanctions against Russia and Belarus

Key takeaways

On 24 February the EU introduced the 16^th package of EU sanctions against Russia and Belarus. The new round expands the scope of the trade sanctions, including additional export bans and services restrictions, and designates further individuals and entities. The measures also tackle circumvention and ensure alignment among regimes, for instance by adding the best efforts obligation to all Russia-related regulations.

In addition, some amendments have been introduced both in the Russia and Belarus sanctions regimes in respect of the possibility to recover damages arising from claims in other jurisdictions brought in connection with contracts transaction affected by EU sanctions. Similarly, the provisions allowing the recovery of damages from the place into temporary management of Russian-registered entities with "unfriendly jurisdiction" ownership, as well as the forced removal of such shareholding under Russian legislation, have been further clarified.

With the 16^th package, the EU confirms its commitment to maintain the pressure against Moscow and use sanctions as a leverage to put Ukraine in the strongest possible position in the potentially upcoming peace negotiation table.

 

Sanctions targeting Russia (Council Regulation 269/2014 and 833/2014)

New designations

• This most recent round targets 83 new individuals and entities including those deemed to support to the Russian military complex, Russian crypto assets exchanges or the maritime sector or to be active in sanctions circumvention.
• A new designation criterion has been added, giving the EU legal basis to sanction individuals and entities deemed to be part of Russia's military industrial complex, or otherwise support or benefit from it.

Trade restrictions

Export/import-related bans

• A ban on the import on unwrought aluminium (CN code 7601), as well as aluminium alloys. The measure foresees a one-year wind-down period allowing a quota of 275,000 metric tonnes.
• Further dual-use export restrictions, including: (a) chemical precursors, such as those related to chloropicrin and other riot control agents used by Russia as chemical weapons, (b) software related to Computer Numerical Control (CNC) machine tools and video-game controllers, and (c) chromium ores and compounds.
• Export bans on additional industrial items, such as paper-related products, minerals, chemicals, glass materials, and fireworks.
• Transit restrictions against a wide variety of goods, including certain flat-rolled steel alloys, machine tools, as well as car spare parts and accessories.
• Amendments to existing derogations and exemptions: Some of the available derogations/exemptions have been clarified and further narrowed to ensure a restrictive interpretation by national competent authorities – including the exclusion of Common High Priority (CHP) goods from the medical and pharmaceutical purposes derogation.
• Extension of the phase-out period for the import ban on polished diamonds until September 2025.

Professional services and software bans

• Prohibition to provide construction services, including civil engineering projects, to the Russian government or legal entities.
• Prohibition to provide IP rights or trade secrets related to further restricted categories of software.

Infrastructure and transport-related prohibitions

• Extension of the flight ban to target third-country carriers conducting domestic flights within Russia or supplying aviation-related goods to Russian airlines or for use therein. Non-compliant third-country entities may be listed and subject to an EU flight ban.
• Prohibition to increase Russian ownership on EU road transport undertakings above 25%.
• Transaction ban on two key Moscow airports, four Russian regional airports, and important seaports, such as Ust-Luga and Primorsk, as well as some others in the Caspian and Black Sea.

Financial sector restrictions

• An additional 13 financial institutions are now subject to the SWIFT ban.
• Transaction ban against 3 banks over their use of the SPFS system.
• Further extension of the transaction ban to allow the EU to target financial institutions and crypto assets providers circumventing the Oil Price Cap.

Energy sector restrictions

• Prohibition on placing Russian crude oil petroleum products in temporary storage or free zone procedures in EU ports.
• Ban on goods, technology and services exports extended to crude oil projects in Russia, as well as LNG projects.
• Prohibition to supply software related to oil and gas exploration.

Anti-circumvention measures

• The EU has listed 74 additional vessels part of the Russian shadow fleet, and implemented a new designation criterion allowing it to sanction operators of unsafe oil tankers.
• Targeted export restrictions against 53 new companies involved in sanctions circumvention.
• Obligation for EU operators (as well as non-EU subsidiaries) to implement due diligence mechanisms when selling to third countries has been extended beyond CHP goods, as listed in Annex XL to Regulation 833/2014, to other sensitive goods as listed in Annex XLVIII.

Extraterritorial measures

• The best efforts clause concerning non-EU subsidiaries of EU companies has been added to Regulation 269/2014 – meaning it now applies equally to both financial and trade sanctions measures.

Broadcasting bans

• Suspension of broadcasting activities against 8 additional media outlets.

Provisions relating to claims for damages and litigation

• The provision that allows EU operators to recover damages and legal costs arising from claims in other jurisdictions brought in connection with any contract or transaction affected by the compliance with EU sanctions has been amended to include both direct and indirect damages caused, not only to that EU operator, but also to any EU entity it owns or controls.
• Furthermore, it has been clarified that the damages may be recovered from the persons and entities that benefitted from or are responsible for the judicial decision that caused the damage to the EU operator (Article 11a of Regulation 833/2014).
• Similarly, the provision that allows EU operators to recover under certain conditions damages caused to that EU operator by Russia-connected persons that have benefitted from, or are responsible for issuing, a decision pursuant to the Russian law allowing the place into temporary management of Russian-registered companies with "unfriendly jurisdictions" shareholding¹ (and similar or related legislation), has been amended in order to include as well the Russian law allowing the removal of "unfriendly jurisdiction" ownership from Russian-registered entities². The article further clarifies that those damages, which may be direct or indirect, shall be recovered from the persons and entities that benefitted from, or are responsible for, a decision issued under the said legislation, or from entities that are owned or controlled by them (Article 11b).
• In addition, the new amendments introduce a prohibition to recognise, give effect or enforce in a Member State any judicial decision pursuant to the Russian Arbitration Procedure Code (Article 11c).
• A provision to ensure access to justice in case no Member State has jurisdiction has been inserted (Article 11d). 

 

Sanctions targeting Belarus (Council Regulation 765/2006)

In order to ensure consistency and tackle circumvention of Russian sanctions undertaken through Belarus, certain provisions of the Russian regime (and as outlined above) have been mirrored in the Belarus sanctions regime. However, as it currently stands, the best efforts clause has not yet been extended to the Belarus regime.

Trade

Export

• Expansion of restrictions on dual-use and advanced technology goods.
• Export ban on oil and gas exploration software.

Import

• A ban on the import of unwrought aluminium (CN code 7601).

Transit ban and road transport restrictions

• Expansion of the prohibition on the transit of certain machinery and goods contributing to the enhancement of Belarusian industrial capacities.
• Ban on EU entities operating as road transport undertakings in the Union to have (or obtain) 25% or greater Belarussian ownership.

Professional services and software bans

• Introduction of a prohibition of construction services, including civil engineering works.
• Restrictions on the transfer of intellectual property rights or trade secrets related to additional prohibited goods and software, to Belarus, its government and related entities.

Financial sector restrictions

• The ban on accepting deposits now includes legal entities, organisations, or bodies from non-EU countries that are majority-owned by Belarusian nationals or residents.
• Deposits for non-prohibited cross-border trade require now prior authorisation from national competent authorities.
• A new prohibition on providing crypto asset wallets, accounts, or custody services to Belarusian nationals or natural persons residing in Belarus, or legal persons, entities or bodies established in Belarus.
• A new prohibition on Belarusian persons owning or controlling entities offering these crypto services.

New listing criterion

• Insertion of a new designation criterion providing the legal basis to sanction individuals or entities that form part of, support or, benefit from the military and industrial complex of Belarus. 

Legal claims in third countries

• The provision on the recovery of damages following claims in third country jurisdictions brought in connection to an agreement or transaction affected by EU sanctions has been amended mirroring the provisions of Regulation 883/2014.

Coordination measures

• Amendments designed to protect EU operators and strengthen sharing of financial intelligence units.

 

Occupied territories (Council Regulation 2022/263) and Crimea and Sevastopol sanctions regimes (Council Regulation 692/2014)

Trade

Export

• Expansion of export ban to banknotes denominated in any official currency of a Member State.
• Expansion of export ban to certain high-risk goods and technology (cars and car parts, battlefield goods, electronics, machinery, aircraft parts).

Professional services and software bans

• A new prohibition to provide certain professional services – mirroring the Russia regime.
• Prohibition on selling, supplying or exporting certain types of software for the management of enterprises and software for industrial design and manufacture, or to transfer connected intellectual property rights or trade secrets.

Extraterritorial measures

• Insertion of the best effort requirement for non-EU subsidiaries.

Coordination measures

• Amendments designed to protect EU operators and strengthen sharing of financial intelligence units.

Legal acts

• Regulation 269/2014 as amended by Council Regulation 2025/390 and implemented by Council Implementing Regulation (EU) 2025/389
• Regulation 833/2014 as amended by Council Regulation 2025/395
• Regulation 765/2006 (Belarus) as amended by Council Regulation (EU) 2025/392
• Regulation 2022/263 (occupied territories) as amended by Council Regulation (EU) 2025/398
• Council Regulation (EU) No 692/2014 (Crimea and Sevastopol) as amended by Council regulation 2025/401

---

¹ Decree of the President of the Russian Federation No. 302 of 25 April 2023.
² Federal Law No. 470-FZ, titled "On the Specifics of Corporate Governance in Business Companies Deemed Economically Significant Organizations" of 4 August 2023.