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Newsletter 25 Jul 2025 · France

News flash: EU Adopts 18th Sanctions Package

29 min read

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A Comprehensive Overview

On 18 July 2025, the Council of the European Union approved its 18th package of sanctions against Russia – described by the EU’s High Representative as “one of its strongest sanctions packages to date”. This package, officially published on 19 July 2025, introduces wide-ranging restrictive measures targeting Russia, while also tightening enforcement against third-country circumvention1. Five key areas have been subject to a plethora of technical changes:

  1. A significant widening of the Russian financial institutions with whom it is not permitted to deal, with a particular focus on reducing avoidance transactions via crypto firms.
  2. Further restrictions to seek to reduce Russian energy exports including a tightening of measures against Russia’s shadow fleet.
  3. A further tightening of the export control/export ban regime concerning dual-use military goods and technologies.
  4. Targeted measures to restrict exports of software used in Russia’s financial sector.
  5. Enhanced anti-circumvention and third-country measures.

In parallel, the EU adopted mirror measures against Belarus to align Belarus’s sanctions regime with the new Russia sanctions.2

Most measures took effect on 20 July 2025, with certain provisions staggered by specified dates. Below is a structured breakdown of the key measures in the 18th package – spanning financial, energy, export control, customs, dual-use, software, and anti-circumvention domains – followed by detailed guidance on legal obligations and best practices for compliance programs. All relevant legal references (EU regulations, decisions and annexes) are noted to facilitate further review.

With respect to parties based in European countries that are not members of the EU the situation must be assessed on a country-by-country basis. In the case of Switzerland, the Swiss authorities have not yet adopted the EU’s 18th sanctions package against Russia. The 17th package has been adopted and entered into force on 3 June 2025. However, Switzerland's current policy is to align with EU sanctions[3]. The relevant adoption may lag behind the EU schedule, though, due to the required adaptation of EU packages within the Swiss legal framework, as set out in the Ordinance on measures in response to the situation in Ukraine issued by the Swiss Federal Council[4]. Despite the absence of formal adoption for the time being, Swiss institutions, particularly regulated financial institutions, should adopt a risk-based approach in the meantime to avoid any risk of circumvention that could result in enforcement proceedings being initiated by the Swiss Financial Market Supervisory Authority.

Financial Sector Restrictions

Expanded Transaction Bans on Banks: The 18th package significantly tightens financial sanctions. The EU converted its earlier SWIFT cutoff measures into a full transaction ban framework for sanctioned banks. Under Article 5ac of Regulation 833/20145 (as amended), any transaction with the 23 Russian banks previously removed from SWIFT is now prohibited, effectively immobilizing them from all EU financial activities. A corresponding ban applies to 4 Belarusian banks under the mirrored provision in the Belarus regulation. In addition, 22 more Russian banks have been newly designated under this framework, meaning they too face a complete EU transaction ban (effective 9 August 2025). These measures sever a broad swath of Russia’s banking sector from EU finance, far beyond the earlier messaging restrictions.

Sanctioning Third-Country Institutions: To disrupt sanctions evasion, the EU lowered thresholds to target non-EU financial institutions and crypto firms that assist Russia. Under a new “frustration transaction ban” (Article 5ad of Reg. 833/20146), the Council can designate any non-EU credit or financial institution or crypto-asset service provider that “significantly frustrates” EU sanctions (e.g. by processing payments for sanctioned trades or supporting Russia’s war effort). Once listed in Annex XLV, such third-country entities are subject to an EU-wide transaction ban. This tool explicitly aims at banks in third countries funneling money or facilitating trade for Russia. Indeed, in this round two Chinese banks were designated for sanctions circumvention, becoming subject to EU asset freezes and a transaction ban. Likewise, the EU expanded its ban on dealings with entities involved in circumventing oil sanctions – now any non-EU company that helps Russia evade the oil import ban or price cap can be listed for a full transaction ban.

Russian Financial Infrastructure: The package directly targets Russia’s financial infrastructure and investment vehicles. A complete transaction ban on the Russian Direct Investment Fund (RDIF) and its network is introduced (new Article 5ag of Reg. 833/20147). This prohibits all dealings with RDIF, entities it owns or controls, certain non-Russian investee companies designated by the EU, as well as service providers to any of these. Four Russian companies in which RDIF has significant investments were simultaneously listed in a new Annex XLIX, banning transactions with them. These measures further choke off Russia’s access to foreign investment and capital. Additionally, Russia’s domestic financial messaging system (SPFS) is now explicitly penalized: any entity (even outside Russia) that uses SPFS (or any Russian alternative to SWIFT) may be designated for sanctions without further conditions. This is a clear warning to third-country banks considering connecting to SPFS.

Other Financial Measures: The EU also banned the sale or export of certain banking-related software to Russia (discussed below in “Software Restrictions”). Notably, Nord Stream 1 & 2 – the Russian-controlled gas pipelines – are now under a full transaction ban (new Article 5af8). All transactions related to the completion, maintenance, operation or use of the Nord Stream pipelines are prohibited, as are services and financing associated with them. This permanently immobilizes the defunct pipelines and blocks any future revival. Targeted exemptions were created only to ensure the pipelines “will not be used” (e.g. for necessary safety or wind-down activities). Together, these financial sector measures (backed by Council Regulation 2025/14949) represent an intensified effort to isolate Russia’s banking system and prevent circumvention through foreign intermediaries.

Energy Sector Measures

Energy exports remain Russia’s economic lifeline, and the 18th package strikes directly at this sector with new restrictions and closing of loopholes. Oil Price Cap Reduction: The G7/EU price cap on Russian crude oil is lowered from $60 to $47.6 per barrel, aligning it with the current market discount for Russian Urals crude. Effective 3 September 2025, this lower cap aims to further curtail Russia’s oil revenues. Going forward, the cap will be dynamically adjusted every six months to stay 15% below average market prices for Russian oil. (Extraordinary reviews can occur if oil markets or geopolitical conditions warrant.) Existing contracts under the old $60 cap are grandfathered only until 18 October 2025. This adjustment, implemented via an amendment to Article 3n of Reg. 833/2014[10], reinforces the pressure on Russia’s budget.

“Shadow Fleet” Crackdown: In tandem, the EU escalated measures against the so-called Russian oil “shadow fleet” – the hundreds of aging tankers and intermediaries used to circumvent oil sanctions. An additional 105 vessels suspected of illicitly transporting Russian oil (or even weapons and stolen Ukrainian grain) have been added to the EU’s blacklist. These ships are now barred from EU ports and denied services essential to maritime transport (e.g. insurance, bunkering, technical assistance), bringing the total number of banned vessels to 444. For the first time, the EU is even sanctioning individuals in the shadow fleet network – including a ship captain and an operator of an international flag registry – as well as a major foreign customer: an Indian refinery (co-owned by Rosneft) that was a key buyer of price-capped Russian crude. These listings, made under Regulation 269/2014[11], impose asset freezes and travel bans on the targeted persons and companies. By targeting the shadow fleet’s owners, service providers, and buyers, the EU aims to undermine the complex schemes propping up Russia’s oil exports. Also EU operators are prohibited from engaging in any transaction with Russian ports and locks listed in Annex XLVII of Council Regulation 833/2014. The 18th package adds a new exemption to the transaction ban for Russian ports and locks by allowing the import of coal from Russia, proving that it originates from a third country, and its owner is non-Russian. Airports transaction ban has been added by a new exemption regarding certain operations required for the completion of civil nuclear facilities (Part B, Annex XLVII).

Import Ban on Refined Products via Third Countries: A critical new trade rule closes a loophole in the oil embargo. As of January 2026, the EU will ban the import of petroleum products (CN[12] code 2710) that were refined from Russian crude oil in any third country. In other words, Russian-origin oil cannot be laundered into the EU as, say, Indian diesel or Turkish gasoline. To enforce this, importers will be required to obtain proof of the crude oil’s origin used in their imported fuels. The European Commission is tasked with issuing guidelines on acceptable evidence of origin. Notably, this documentation requirement is waived for imports from certain “partner countries” that have equivalent restrictions on Russian oil. A new Annex XLI to Reg. 833/2014[13] lists these exempted partner countries, which include Canada, Norway, Switzerland, the UK and US. The regulation also presumes that petroleum exports from bona fide net exporters (countries that produce more oil than they consume) are from their own crude – though EU customs can challenge this presumption if suspicious. This innovative measure – introduced as Article 3ma of Reg. 833/2014[14] – compels EU importers to conduct supply chain due diligence and prevents Russian oil from “re-entering” the EU market through refining hubs.

Pipeline and LNG Restrictions: The 18th package closes a remaining gap in oil sanctions by ending the last pipeline crude oil exemption. Deliveries of Russian oil via pipeline to Czechia had been temporarily exempted, but as of this package all EU imports of Russian crude (whether by sea or pipeline) are now prohibited without exception. Furthermore, a new measure addresses liquefied natural gas: while the EU has banned most Russian gas, a narrow derogation now allows certain isolated Member States to import Russian LNG through non-interconnected terminals. Specifically, a Member State with an LNG terminal not linked to the broader EU gas network, and which only received its first long-term LNG supply after 20 July 2025, may be authorized to use Russian LNG if needed for energy security. This provision (Article 3u of Reg. 833/2014[15]) was crafted for exceptional cases to avoid energy crises in peripheral markets, and any use of it will be strictly monitored.

In sum, the energy-focused sanctions in this package – underpinned by amendments to Regulation 833/2014 – further choke off Russia’s revenue from oil and gas. Companies in energy trading must pay close attention to the new origin certification requirement for petroleum imports and ensure no dealings with blacklisted vessels or intermediaries.

Export Controls and Dual-Use Goods

The EU has tightened export controls to impede Russia’s access to military-useful goods and technologies, expanding both the list of banned items and the legal tools to enforce those bans. Notably, 26 new entities (companies and organizations) have been added to the EU’s military and dual-use end-user blacklist (Annex IV of Reg. 833/2014[16]). These include eleven entities in China, Hong Kong, and Türkiye identified as providing Russian procurement networks with Western technology (for example, components for UAVs). EU exporters are now prohibited from selling any dual-use or advanced technology items to these listed entities without authorization, as they are presumed to be diverting goods to Russia’s military. (Providing such items knowingly to listed parties is a serious sanctions offense.) One Belarusian defense entity was similarly added to Annex V of Reg. 765/2006[17], reflecting the parallel crack-down on Belarus’s military support for Russia.

Broader Export Bans (180 New CN Codes): The 18th package dramatically expands the lists of prohibited exports to Russia by more than 180 additional commodity codes. These new listings target a wide array of “industrial capacity” goods – many not traditionally seen as arms, but which can support Russia’s war economy. For example, the expanded Annex XXIII of Reg. 833/2014[18] now bans exports of various metal products, tools, and engineering equipment to Russia. New prohibited items include machine parts, measuring devices, industrial machinery, certain chemicals and plastics, and metal goods that Russia could repurpose for military manufacturing. Notably, advanced manufacturing tools like CNC (computer numerical control) machines have been added to the tech export ban list, as have specialty chemicals that could be used in explosives or propellants. These additions (in Annex VII and Annex XXIII of Reg. 833/2014) amount to some €2.5 billion worth of trade that is now forbidden. Companies must therefore re-screen their product classifications against the updated lists: even innocuous-seeming goods (e.g. certain electric discharge machine tools, water-jet cutting machines, bearings, industrial engines) may now be outright banned for export to Russia.

“Catch-All” End-Use Controls: Crucially, the EU introduced a new catch-all provision to stop unlisted high-tech items from reaching Russia via third countries. Under amended Article 2a of Reg. 833/2014[19], Member State authorities can require prior authorization for exports of any advanced technology item to a third country if they inform the exporter of a credible risk that the goods might be re-exported to Russia (or Belarus). In practice, this means if an EU company plans to ship sensitive electronics, software, or machinery to a country like Kazakhstan, and their national authority suspects the ultimate end-use is Russia, they can impose a licensing requirement even if the item isn’t on the sanctioned list. This anti-circumvention “catch-all” tool is discretionary – it’s not a blanket ban on all such exports, but a case-by-case instrument to investigate dubious transactions. Importantly, it does not replace the existing prohibition on indirect exports to Russia; even if no license is required, exporters remain liable if their goods ultimately end up in Russia in violation of sanctions. This measure (mirrored in Article 1f of the Belarus Reg. 765/2006[20]) equips customs and licensing authorities with a proactive means to crack down on sanctions evasion via third countries. Companies should expect greater scrutiny of “Russia-sensitive” exports headed to third countries and ensure robust end-use due diligence is conducted.

Military and Defense Items: The package also formally incorporated the arms embargo into the EU regulations. Previously, the ban on exporting military items on the EU Common Military List to Russia (and on importing arms from Russia) was only stated in the CFSP Decision; now it is written into Regulation 833/2014[21] (Article 4), making enforcement more direct. Likewise, for Belarus, a full arms embargo is established in the Regulation (Belarus had previously only been barred from arms exports, now imports of arms by the EU are banned as well). The incorporation of these military embargo provisions ensures no legal ambiguity – any military-grade equipment trade with Russia/Belarus is strictly forbidden by EU law.

In summary, the export control measures of the 18th package (implemented via Council Regulation 2025/1494[22] amending Reg. 833/2014) substantially widen the scope of goods that EU companies cannot send to Russia, and they provide authorities new powers to intercept potential diversions. Companies must update their export screening filters to include the new CN codes and proactively monitor for red flags indicating that a non-listed item might be destined for a military end-use or a Russian recipient.

Software and Technology Restrictions

An innovative sanction in this package is the targeting of software used in Russia’s financial sector. The EU imposed a ban on the sale, supply, or export of certain management and accounting software” for banking/financial use to Russia. This prohibition (new Article 5n of Reg. 833/2014[23]) specifically covers software products crucial for running financial operations – for example, bank management systems, risk assessment or financial trading software – when destined for the Government of Russia or any entity established in Russia. The aim is to degrade Russia’s financial system efficiency by denying it updates or new installations of Western software. A wind-down derogation allows contracts signed before 20 July 2025 to be executed until 30 September 2025, after which all such software exports or support must cease.

From a compliance perspective, firms in the tech sector should note that “software” is now explicitly within the scope of EU trade sanctions on Russia, not just traditional goods. Software companies must evaluate whether their products (or updates/patches) are caught by the banned software list (Annex XXXIX of Reg. 833/2014[24]) and ensure no prohibited support or maintenance services are provided to Russian clients in the banking field. This measure underscores that digital tools and intellectual property can be “exported” just like physical goods – and are subject to similar restrictions when they bolster sanctioned sectors.

Additionally, the EU continued its focus on cyber and dual-use technology by adding more electronics and IT hardware to the controlled lists. Prior packages had already banned exports of semiconductors, encryption devices, and high-end electronics to Russia. The 18th round reinforces this by including new categories of advanced manufacturing tech (as noted above, CNC machines, etc.) and by using the catch-all control to police unlisted tech. Companies in software, IT, and electronics industries should closely review Annex VII (advanced tech) and Annex XVIII/XXIII (industrial goods) of Regulation 833/2014[25] as updated, to verify if any additional technologies or components they deal in are now restricted.

Anti-Circumvention and Third-Country Measures

A major theme of the 18th package is closing loopholes and punishing circumvention, both within the EU and beyond. Several measures directly tackle the methods used to bypass sanctions:

  • Transit Bans: The EU expanded its ban on the transit of sanctioned goods via Russian territory. Since 2022, certain high-tech goods could not be sent through Russia en route to third countries (to prevent “leakage” into Russia). Now Annex XXXVII of Reg. 833/2014[26] (transit ban list) is enlarged to include additional critical industrial goods, notably heavy vehicles and machine tools. For example, diesel trucks (semi-trailer tractors) and their trailers are now forbidden even to transit through Russia, as are specific classes of machine tools (e.g. electrical discharge and water-jet cutting machines) which were already export-banned to Russia. The logic is to prevent Russia from seizing or illicitly procuring such items under the guise of “transit.” This affects EU exporters sending equipment to Central Asia or Asia via land routes: if the goods are on the transit-ban list, they must take alternative routes (or not be shipped at all). Belarus-related transit bans were similarly widened (new Annex XIVa and expansion of Annex XIX in Reg. 765/2006[27]).
     
  • Mirror Measures for Belarus: The Council explicitly decided to “mirror” the Russia sanctions measures in Belarus’s regime. This means Belarus now faces the same sectoral trade bans: its list of prohibited exports and transit goods is expanded in lockstep with the Russia lists. For example, previously Belarus was subject mainly to an arms and dual-use embargo; under Regulation (EU) 2025/1472[28], Belarus is now under equivalent bans on industrial goods, advanced technology, aviation/energy equipment, etc., matching the Russia Annexes. The Belarusian financial sector also sees the SWIFT ban on certain banks converted to a full transaction ban, just as for Russia. And notably, the EU has banned imports of arms from Belarus (closing a loophole where Belarusian arms could previously be purchased if not otherwise controlled). In short, Belarus’s sanctions are no longer “lighter” than Russia’s – they are aligned, to close any backdoor by which Belarus could serve as a transshipment or financial intermediary. Companies must treat Belarus with the same level of sanction scrutiny as Russia, both in financial dealings and trade compliance.
     
  • Enforcement and Listings: The EU demonstrated willingness to sanction non-Russian actors abetting circumvention. Beyond the Chinese banks and trading firms mentioned, the Council’s new asset freeze list included entities in UAE and India involved in trading Russian oil, and various individuals across third countries working as fronts for sanctioned Russian interests. By imposing asset freezes under Regulation 269/2014[29] on such actors, the EU makes clear that facilitators in any jurisdiction risk being cut off from the EU financial system. Internally, EU customs agencies are also ramping up enforcement: Finnish Customs alone reported detecting over 30,000 “anomalies” in goods traffic and conducting 4,000+ targeted inspections for sanctions evasion since 2022. This has led to 900+ investigations in Finland (130 of them serious criminal cases), whereas before the war sanctions cases were negligible. One recent case in July 2025 saw Finnish authorities investigate a logistics company suspected of rerouting exports to Russia via Lithuania, Central Asia and other third countries. The scheme involved ball bearings and industrial motors – goods with potential military applications – valued at €300,000, and was uncovered after customs intercepted a direct shipment of prohibited dual-use items to Russia. This example underscores the increased vigilance and intelligence-sharing among EU enforcement bodies (e.g. Finnish Customs coordinating with Europol and OLAF). The 18th package further facilitates this by giving Member States the option to require licenses for suspect exports (the catch-all mechanism) and by obligating them to prevent circumvention when there is credible risk.
     
  • Investment and Legal Loopholes: Finally, a novel element aimed at circumvention is the EU’s move to block illegitimate Investor-State Dispute Settlement (ISDS) claims by Russian entities. Some Russian companies and oligarchs have attempted to sue EU states under Bilateral Investment Treaties for the losses caused by sanctions. The new package introduces provisions refusing recognition/enforcement of any judgments or awards from such arbitration proceedings, and even allows EU governments to recover any damages paid out. This is a defensive measure to prevent Russia or its state-owned companies from circumventing sanctions via legal challenges in foreign arbitral tribunals.

In summary, the anti-circumvention measures target both the physical rerouting of goods and the financial/legal backdoors that might undermine sanctions. Companies should heed the clear message: sanctions enforcement is tightening, and creative workaround schemes (shell companies, third-country routings, etc.) are increasingly likely to trigger regulatory action. Companies must ensure their sanctions screening and due diligence extend to indirect transactions and third-party partners to avoid unwitting involvement in circumvention.

 

Compliance Obligations and Customs Guidance

The scope and complexity of these new sanctions demand heightened diligence from companies. Chief Companies should immediately consider the following actions and best practices to align with the 18th package and broader EU customs law obligations:

1. Update Classification and Screening Procedures: All exporters must review the latest annexes and CN codes introduced by Regulation 2025/1494 to determine if their products are now controlled or prohibited. The addition of 180+ CN codes means items previously freely exportable might now be banned or require a license. Integrate the new HS/CN codes (e.g. for metal tools, machinery, electronics, etc.) into your export control screening software. Similarly, update sanctions screening lists to include newly designated entities (the 14 individuals and 49 entities added to asset freeze lists, including those in third countries). Ensure your ERP or trade compliance system flags any transaction involving those names or goods for manual review.

2. Enhance Dual-Use and “Catch-All” Controls: Revisit your procedures under the EU Dual-Use Regulation and sanctions regulations to account for the expanded dual-use list and the catch-all clause. Train export personnel that even if an item is not listed in Annex I of the Dual-Use Regulation or the Russia sanctions annexes, it may still require an export license if there are indications of a military end-use in Russia/Belarus or if authorities notify of a risk. Establish an internal review committee to vet any orders destined for countries near Russia (e.g. Eurasian Economic Union states, China, Türkiye, UAE) involving advanced technology or high-volume industrial goods – these should trigger end-use inquiries. If any “red flags” (such as a new shell customer, unusual routing, or misuse of freight forwarders) suggest a Russia diversion, consider voluntarily consulting your national export control authority. Proactively applying for an export license or requesting guidance can demonstrate good faith compliance and may be legally required if you’ve been “informed” of a risk (per the new rules).

3. Documentation and Origin Evidence: The upcoming requirement (Jan 2026) for crude oil origin certificates on refined petroleum imports means importers of fuels must prepare compliance mechanisms now. If your company imports blended fuels or petrochemicals, liaise with suppliers to obtain affidavits or traceability documentation about the oil source. Maintain organized records, as customs authorities will expect paper trails proving non-Russian origin (especially if sourcing from countries like India or China that refine Russian crude). Likewise, document your product classifications meticulously – keep records of how you determined an item’s CN code or dual-use status, including technical specifications. In the event of a customs audit, being able to show a reasoned classification (and why it was/was not on a control list) is critical.

4. Licensing and Government Engagement: If any of your exports or business activities now fall under new restrictions (e.g. providing software updates to a Russian bank, exporting a machine now listed in Annex XXIII, or continuing a contract with RDIF-related entities), engage early with the relevant licensing authorities. Seek clarifications or apply for authorizations/exemptions where available. For instance, certain exemptions exist to wind down contracts (some new bans allow execution of pre-existing contracts into Q3 2025) or for specific cases like humanitarian, medical, or safety-related dealings. Make sure to document any official guidance or license obtained and strictly follow any conditions attached. Also stay alert for European Commission guidance documents (e.g. on oil origin evidence, or FAQs on the scope of “banking software”) which often follow major sanctions packages.

5. Strengthen Due Diligence on Customers and Partners: Given the focus on third-country circumvention, perform enhanced due diligence on any new intermediaries, traders, or logistics providers you engage. Verify the ownership and physical presence of companies in trade routes that commonly serve as transshipment points (Central Asia, Middle East, Turkey). Be wary of customers who suddenly increase orders of EU-origin goods that could be destined for Russia. Incorporate clauses in contracts requiring counterparties to comply with EU sanctions and not re-export to Russia/Belarus. Request end-use certificates where appropriate, and consider using technology like supply chain tracking or blockchain to monitor the movement of sensitive goods beyond the EU border. Remember, under EU law, companies can be held accountable if they knew or had reasonable cause to suspect their exports would end up in Russia via a third country.

6. Internal Training and Audit: Update your compliance manuals and training to reflect these new rules. Front-line staff (sales, logistics, procurement) should be briefed on the implications of the 18th package – e.g. “we can no longer ship product X to Turkey if it’s likely going to Russia” or “we must not do any business with ABC Bank because it’s now completely blacklisted, even non-financial transactions.” Conduct an internal audit or “health check” of your sanctions compliance program focusing on the areas impacted by this package. For example, audit your export logs since July 2025 to ensure no inadvertent shipments occurred of now-banned CN codes. Review your customer lists against the updated sanctions list (including those SPFS-related or oil trade-related entities). Testing your controls now – and remedying any gaps – will put you in a defensible position should authorities investigate. Given the intense enforcement environment (with thousands of checks and investigations ongoing across the EU), demonstrating a robust compliance program and a culture of compliance is not only prudent but could be a mitigating factor if a violation is discovered.

7. Engagement with Customs Authorities: Proactively maintain open lines of communication with your national customs authority or sanctions enforcement body. Many customs services (like Finnish Customs, Tulli) publish guidance and even invite consultations for complex questions. Leverage any offered support – e.g., Finnish Customs has noted its active role in guiding businesses on sanctions enforcement. Participate in industry forums or working groups on sanctions if available, to stay updated on enforcement trends. Remember that enforcement agencies are now cooperating EU-wide (through Europol and OLAF) – inconsistent approaches are diminishing. If you encounter any suspect approach or pressure to violate sanctions (for instance, a request to falsify documents or trans-ship via a certain route), consider reporting it to authorities. Whistleblower protections and incentives may apply, and it can shield your firm from deeper involvement in illicit schemes.

By implementing the above steps, companies will be better prepared to navigate the stringent requirements of the 18th sanctions package. The tone from Brussels is unmistakable: full compliance is expected, and firms must exercise vigilance “as long as it takes” to ensure Russia and Belarus cannot leverage EU-origin goods or finance for their aggression. Non-compliance can lead to severe consequences ranging from frozen assets to criminal investigations. Conversely, robust compliance can secure your organization’s reputation and minimize disruption amid these evolving restrictions.

Conclusion

The EU’s 18th sanctions package of July 2025 represents a comprehensive tightening of the screws on Russia and its allies, spanning from oil exports and banks to machine tools and software. For Companies, this package demands a thorough update of internal controls and a re-doubling of due diligence in all Russia/Belarus-related activities. The measures not only broaden the substantive prohibitions (what is forbidden) but also enhance the procedural mechanisms (how enforcement can catch evasion). In an internal compliance memorandum or briefing to leadership, it is crucial to convey that these sanctions are legally binding, backed by EU Regulations with direct effect, and that regulators are actively looking for lapses. By citing the official acts – e.g., Council Regulation (EU) 2025/1494 amending Reg. 833/2014 – and understanding their content, companies can provide informed guidance. Ultimately, navigating this new landscape will require a mix of legal rigor (knowing the rules and exceptions) and practical vigilance (implementing controls and watching for red flags). With appropriate action, companies can continue legitimate business while avoiding entanglement in sanction breaches – a balance that the compliance program is now more critical than ever to maintain.


1 European Commission, Press release, Jul 18, 2025 (EU adopts 18th package of sanctions against Russia).
2 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 (Regulation - EU - 2025/1494 - EN - EUR-Lex).
3 Council Decision (CFSP) 2025/1495 of 18 July 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (Decision - CFSP - 2025/1495 - EN - EUR-Lex).
4 Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
5 Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (EUR-Lex - 02014D0512-20250521 - EN - EUR-Lex).
6 Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Regulation - 269/2014 - EN - EUR-Lex).
7 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 (Regulation - EU - 2025/1472 - EN - EUR-Lex).
8 Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (EUR-Lex - 02006R0765-20250327 - EN - EUR-Lex).
9 However, Switzerland independently decides to what extent it will align itself with EU sanctions, rather than automatically adopting those imposed by the EU.
10 Ordinance on measures in response to the situation in Ukraine of 4 March 2022, status as of 25 June 2025 (https://www.fedlex.admin.ch/eli/cc/2022/151/fr).
11 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
12 Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
13 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex) , amended by Council Regulation (EU) N°2025/1494 (Regulation - EU - 2025/1494 - EN - EUR-Lex).
14 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex), amended by Council Regulation (EU) N°2025/1494 (Regulation - EU - 2025/1494 - EN - EUR-Lex).
15 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 (Regulation - EU - 2025/1494 - EN - EUR-Lex).
16 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
17 Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (EUR-Lex - 02014R0269-20250515 - EN - EUR-Lex).
18 The Combined Nomenclature (CN) is a tool for classifying goods, set up to meet the requirements both of the Common Customs Tariff and of the EU's external trade statistics. The CN is also used in intra-EU trade statistics. It is a further development (with special EU-specific subdivisions) of the World Customs Organization's Harmonized System nomenclature. This is a systematic list of commodities applied by most trading nations, and also used for international trade negotiations (i.e. Commission Implementing Regulation (EU) 2024/2522 of 23 September 2024 amending Annex I to Council Regulation (EEC) No 2658/87 on the tariff and statistical nomenclature and on the Common Customs Tariff).
19 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
20 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
21 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex) , amended by Council Regulation (EU) N°2025/1494 (Regulation - EU - 2025/1494 - EN - EUR-Lex).
22 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
23 Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus (Regulation - 765/2006 - EN - EUR-Lex).
24 Annex IV of Council Regulation (EU) 2025/1494 modifying Annex XXIII “List of goods and technology as referred to in Article 3k” to Regulation (EU) 833/2014 (Regulation - EU - 2025/1494 - EN - EUR-Lex).
25 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
26 Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures against President Lukashenko and certain officials of Belarus (EUR-Lex - 02006R0765-20250327 - EN - EUR-Lex).
27 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
28 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 (Regulation - EU - 2025/1494 - EN - EUR-Lex).
29 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
30 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
31 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
32 Ibid (EUR-Lex - 02014R0833-20250521 - EN - EUR-Lex).
33 Council Regulation (EC) No 765/2006 of 18 May 2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (EUR-Lex - 02006R0765-20250327 - EN - EUR-Lex).
34 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 (Regulation - EU - 2025/1472 - EN - EUR-Lex).
35 Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (Regulation - 269/2014 - EN - EUR-Lex).

Authors

Denis Redon, Partner, CMS France : Contact
Nicolas Tollet, Partner, CMS France : Contact
Vaïk Müller, Partner, CMS Switzerland : Contact
Kai Neuhaus, Partner, CMS Belgium : Contact
Bernhard Lötscher, Partner, CMS Switzerland : Contact
Hermann Müller, Partner, CMS Germany : Contact
Russell Hoare, Partner, CMS United Kingdom : Contact 
Marie-Clémence Cicile, Associate, CMS France : Contact
Karim Soussi, Associate, CMS France : Contact

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