EU sanctions update – Package 16 and update on asset freezes

Insights|March 20, 2025

On the third anniversary of Russia’s invasion of Ukraine, the EU adopted an additional sanctions package which widened the regulation in many ways. It underlines the importance for companies to check their counterparties, check their products, their main components, their technologies, and where these are actually shipped to, used in, and procured from. The EU’s 16th sanctions package against Russia contains a set of measures designed to target critical sectors of the Russian economy, focusing on the Russian shadow fleet, anti-circumvention efforts, sanctions within trade and finance, alongside tackling Russian propaganda.

Nearly simultaneously, EU leaders were in deep negotiations with Hungary to reach the unanimity requirement to keep in force the asset freeze sanctions, which Hungary threatened to derail. A similar situation occurred with the sectoral sanctions regime in January. The Council decided to uphold the current list for a further six months, which keeps the situation in flux.

The list below summarizes what is new in the 16th sanctions package.

New listings and widened scope

  • The latest package introduces 83 new listings, encompassing 48 people and 35 entities.
  • Furthermore, it establishes new criteria, enabling the EU to impose restrictions on a broader range of individuals and entities, targeting those supporting or benefiting from Russia’s military and industrial complex, as well as entities and individuals that own or operate vessels in Russia’s shadow fleet.
  • Consequently, 53 new entities have been added to the list of entities directly supporting Russia’s military and industrial complex. These entities are now subject to stricter export restrictions on dual-use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia’s defense and security sector. Two-thirds of these entities are located in third countries, including China, India, Singapore, and Türkiye.
  • In addition, the sanctions extend to Belarus, introducing additional trade-related sanctions, restrictions on transport, service restrictions, and financial asset controls. New restrictions are also imposed in Crimea, Sevastopol, and non-government-controlled areas of Ukraine to prevent their integration into Russia and to avoid circumvention of EU sanctions. These restrictions include a wide variety of service provisions, including accounting, IT consultancy, and advertising services, as well as the provision of certain software.

Russia’s shadow fleet and preventing circumvention

The EU has targeted 74 additional vessels associated with Russia’s shadow fleet, banning them from port access and restricting services related to maritime transport. Moreover, temporary storage for Russian crude oil and petroleum products within the EU has also been banned.

  • Additionally, transactions with specific Russian ports and airports used for transferring certain military technology are also banned. The ban also targets locations used for evading the Oil Price Cap or other restrictions, particularly by vessels engaged in risky shipping practices, and encompasses bans on accessing the facilities and the provision of any services to vessels or aircraft.
  • Moreover, the sanctions impose further restrictions on export, particularly software related to oil and gas exploration, and prohibit goods, technology, and services for completing crude oil projects in Russia.

Finance and banking

  • The EU has imposed a transaction ban on credit or financial institutions established outside Russia that use the financial messaging service developed by the Central Bank of Russia (SPFS).
  • Additionally, the package includes an extension of the prohibition on specialized financial messaging services, now covering 13 regional banks deemed significant to Russia’s financial system.

Trade and transportation

  • The package includes an expanded import ban, including on Russian natural resources such as aluminum, as well as expanded restrictions on the export of goods which contribute to the enhancement of Russian industrial capabilities and their transit through Russia.
  • The package also expands the list of restricted items that contribute to the technological enhancement of Russia’s defense and security sector by adding further restricted goods. The scope of exemptions is also narrowed down.
  • The package also includes a ban on construction services to Russia and mandates due diligence from EU operators when selling sensitive items to non-partner countries to prevent the illegal re-export of sanctioned goods to Russia.
  • Additionally, the package includes an expansion of the flight ban to include air carriers operating domestic flights within Russia and those exporting aircraft or aviation technology to Russian carriers and their affiliates. Road transport restrictions are also tightened for operators with significant Russian ownership, with the new rules prohibiting any changes to the ownership structure that would increase the Russian ownership stake beyond 25%.

Curbing russian propaganda

  • An additional eight (8) media outlets under the permanent control of the Russian leadership were suspended from EU broadcasting licenses, including Eurasia Daily, NewsFront, and Fondsk.

Updates on asset freeze regulation

  • Based on the Council’s previous decision to prolong the restrictive measures under the asset freeze regulation for another six months, these measures were at risk of expiring on 15 March due to Hungary’s veto in the unanimous decision-making process. Following last-minute negotiations, on 14 March the Council reached a decision to prolong the restrictions until 15 September 2025.
  • In the context of the review, four names were removed from the list, according to news outlets, three at the request of Hungary.
  • A similar risk of expiry arose in relation to the sectoral sanctions in late January, when the Council agreed on an extension until 31 July 2025.
  • We are closely following these developments, as geopolitics remain in turmoil.

Stay tuned for our update on the impacts of the Sanctions Crime Directive, the national implementations of which enter into force in May 2025.