EU adopts 16th package of restrictive measures against Russia

Persons subject to an asset freeze

Aluminium import restrictions

Export restrictions

The Council imposed reinforced export controls on 53 new entities, including several established outside Russia, for their involvement in supporting Russia’s military and industrial sector or in sanctions circumvention.

The 16^th package has also extended export restrictions on dual-use items to limit Russia’s access to technologies used on the battlefield. This includes chemical precursors, certain types of software and video game controllers, chromium ores and compounds.

Furthermore, the Council:

1. imposed export restrictions on industrial goods critical to military operations, targeting minerals, chemicals, steel, glass materials, and fireworks,
2. extended the deadline for the implementation of a mandatory blockchain-based tracing system, verifying the non-Russian origin of polished diamonds, to 1 January 2026. For all other types of diamonds, the deadline remains 1 March 2025.

Energy sector restrictions

The Council introduced a ban on the temporary storage and placement of Russian crude oil or petroleum products under the free zone procedure in the EU. “Free zones” are designated areas within the EU where non-EU goods can be placed without being subject to import duties, taxes, or commercial policy measures, and may later be released for free circulation (with applicable duties), placed under another customs procedure, or re-exported.

In addition, EU operators are prohibited from providing:

1. software used in oil and gas exploration to Russian persons,
2.  goods, technology, and services for the completion of Russian crude oil projects.

Anti-circumvention

The Council added 74 new vessels linked to Russia’s “shadow fleet” to the list of vessels prohibited from accessing EU ports or receiving services in the EU. These vessels have been associated with the transportation of military goods, the circumvention of measures targeting the Russian energy sector, or the transportation of stolen Ukrainian grain.

Furthermore, EU operators are prohibited from engaging in transactions with EU financial institutions and crypto-asset providers that facilitate transactions related to listed vessels, as well as with financial institutions and crypto-asset providers established outside the EU that circumvent the oil price cap.

Best efforts obligation

The Council introduced a “best efforts” obligation in relation to asset freeze sanctions. This obligation requires that EU operators prevent their subsidiaries established outside the EU from engaging in activities that undermine the asset freeze measures in Regulation No 269/2014. Previously, this applied only in the context of sectoral sanctions in Regulation No 833/2014.

Judicial proceedings

The Council clarified the procedure for the recovery of damages in the context of EU restrictive measures. Specifically, it:

1. affirmed that both direct and indirect damages are recoverable;
2. expanded the scope of potential claimants to include entities owned or controlled by an affected person;
3. specified that damages can also be recovered from those who filed claims before courts in third countries, or from those who own or control the entities that caused the damage;
4. established that a Member State court can hear a damages claim, even in the absence of jurisdiction by any EU court, provided that the claim has a sufficient connection to the Member State where the court is located.

Financial sector restrictions

The Council added 13 Russian banks to the list of entities subject to the prohibition on providing specialised financial messaging services.

Additionally, the Council added to the transaction ban three banks established outside Russia that use the Financial Messaging System of the Central Bank of Russia (SPFS).

Transport restrictions

The EU flight ban has been expanded to include listed third-country carriers that operate domestic flights in Russia or provide aviation goods to Russian airlines or for flights in Russia.

Furthermore, the Council prohibits Russian ownership in EU road transport undertakings from rising above 25%.

Infrastructure restrictions

The 16^th package imposed a full transaction ban on two Moscow airports, four Russian regional airports, and five Russian ports.

In addition, EU operators are prohibited from providing construction services to Russia.

Disinformation measures

The Council suspended the broadcasting of eight additional media outlets in the EU or directed at the EU as a result of their support of Russia’s invasion of Ukraine.

Restrictive measures against Belarus

The Council added a new listing criterion targeting persons that are part of, support, or benefit from Belarus’ military and industrial sector.

In addition, this package includes:

1. several trade-related restrictions already imposed on Russia,
2. the above clarifications in relation to damages claims,
3. the above prohibition on participation in EU road transport undertakings.

Lastly, the 16^th package prohibits the sale or provision of services for certain software, tightens deposit restrictions, and introduces restrictions on crypto-asset wallets.