EU adopts 18th package of restrictive measures against Russia

On 18 July 2025, the Council of the EU adopted its eighteenth package of restrictive measures against Russia, which supplements those detailed in our previous newsflashes.

This package imposes an asset freeze on 55 additional persons, establishes an automatic adjustment mechanism for the crude oil price cap, and enhances the EU’s anti-circumvention measures.

The Council adopted four regulations that entered into force on 19 July 2025, the last two of which relate to Belarus:

• Council Regulation (EU) 2025/1494 of 18 July 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
• Council Implementing Regulation (EU) 2025/1476 of 18 July 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
• Council Regulation (EU) 2025/1472 of 18 July 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine
• Council Implementing Regulation (EU) 2025/1469 of 18 July 2025 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

Among the 14 individuals and 41 entities newly subject to asset freezes and bans on providing economic resources is Nayara Energy, which operates the largest Rosneft-affiliated refinery in India.

This package introduces a dynamic pricing mechanism that sets the price cap for Russian oil exported to third countries at 15% below the average market price for Russian crude oil. In practice, this lowers the cap from USD 60 to USD 47.60 per barrel, with automatic adjustments every six months and the possibility of ad hoc reviews.

An additional ban has been imposed on the import or transfer of certain petroleum products from third countries if they were produced using Russian crude oil.

The 18^th package also establishes a complete ban on all transactions related to the Nord Stream 1 and Nord Stream 2 pipelines.

Russian ‘shadow fleet’

Furthermore, the package adds 105 vessels to the list of Russia’s shadow fleet: ships that are now banned from entering EU ports and locks, and from receiving a broad range of services related to maritime transport.

Tightened export controls and anti-circumvention measures

The Council has expanded export bans on critical goods, including specific types of machinery, metals, plastics, chemicals, and technologies used in the production of drones, missiles, and other weapon systems. In addition, 26 Russian and foreign companies supporting Russia’s military-industrial complex are now subject to stricter export restrictions on dual-use goods and technologies.

To prevent the circumvention of these controls, the Council has broadened the list of goods subject to a transit ban through Russia. Moreover, a new administrative mechanism will enable Member States to require prior authorisation for the export of restricted items to third countries in cases where there are reasonable grounds to suspect that the final destination could be Russia.

Expanded transaction bans

The Council has extended the existing prohibition on the provision of specialised financial messaging services – originally applicable to 23 Russian banks – by listing an additional 22 Russian banks and converting the measure into a full transaction ban.

The restrictive measures also include a transaction ban targeting the Russian Direct Investment Fund (RDIF), its subsidiaries, significant investments linked to the fund, and entities providing related services. Furthermore, a transaction ban now applies to certain financial institutions established in third countries, that are deemed to be involved in circumventing EU restrictive measures or in supporting Russia’s military aggression against Ukraine. The current list includes two financial institutions based in China.

Protection from Bilateral Investment Treaty (BIT) claims

The 18^th package introduces various measures limiting the recognition, effect, and enforcement of investor-State dispute settlement proceedings brought against Member States outside the EU in connection with EU restrictive measures targeting Russia.

Restrictive measures targeting Belarus

The Council added eight Belarusian military sector entities to the asset freeze list due to their support for Russia’s war in Ukraine. It also imposed an arms embargo on weapons exported from Belarus.

In addition, the package applies several of the same restrictions imposed on Russia to Belarus. These include a full transaction ban for entities previously subject to limits on financial messaging services, a requirement for authorisation when exporting restricted items to third countries if Belarus might be the final destination, tighter export controls on dual-use goods, and measures to protect EU Member States from BIT claims related to these sanctions.