EU hits Russia with 16th sanctions package after three years of war
On 24 February 2024, the EU adopted the 16th package of sanctions against Russia on the three-year anniversary of Russia's fully-fledged invasion of Ukraine. While there are few groundbreaking amendments in this package, economic operators face new legislation with numerous changes to existing rules, which require careful analysis. The following article summarises the main elements, including newly introduced restrictions, grace-periods and exemptions.
New asset freezes
The EU designated another 48 individuals and 35 entities which are now subject to asset freezes and prohibitions on making funds and economic resources available.
Brussels further added new listing criteria targeted at operators engaging in irregular and high-risk shipping practices and those partaking in the Russian military and industrial complex, supporting it or even benefitting from it.
The “best efforts”-obligation, first introduced in June 2024 in Regulation (EU) 833/2014 that obliges EU operators to use best efforts to ensure that their non-EU subsidiaries do not participate in activities undermining EU sanctions, has now been introduced in Regulation (EU) Nr. 269/2014. EU operators must now take all suitable and necessary actions to prevent that funds or economic resources are made available by its non-EU subsidiaries to persons listed in Annex I to Regulation (EU) No 269/2014 .
Finance and banking sector
The SWIFT-ban has been extended to the following additional 13 regional Russian financial institutions: Ak Bars Bank, Uralsib Bank, Tochka Bank, National Reserve Bank, Roseximbank, Bank SINARA, Primsotsbank, BBR Bank, RNKO Platezhnyy Konstruktor, Petersburg’s settlement centre, Kuznets business bank, MIR Business Bank and Bank Kuban Kredit.
These three non-Russian institutions have been subjected to the transaction ban due to their participation in the Russian SWIFT-alternative, the Financial Messaging System of the Central Bank of Russia (SPFS) – BankBelVEB, Belgazprombank, VTB Bank (PJSC) Shanghai Branch.
Media sector
The EU will suspend the EU broadcasting licences of the following eight Russian media outlets and prohibits them from broadcasting in the EU: EADaily / Eurasia Daily, Fondsk, Lenta, NewsFront, RuBaltic, SouthFront, Strategic Culture Foundation, and Krasnaya Zvezda / Tvzvezda.
Tighter export restrictions for dual-use/advanced technology items for Annex IV companies
The EU tightened the existing export prohibition for dual-use goods and technologies as well as certain advanced technology items. Brussels now generally prohibits the export of these items to entities listed in Annex IV to Regulation (EU) 833/2014, irrespective of the end-destination of the item.
With the 16th package, an additional 53 companies have been added to Annex IV. These include 34 companies from outside of Russia for having participated in diversion or circumvention, including from China including Hong Kong, India, Kazakhstan, Singapore, Türkiye, the United Arab Emirates and Uzbekistan.
Further export restrictions for goods and software
The EU has added goods and software to the lists of items restricted for sale, transfer, supply and export to Russia or for use in Russia, including chemical precursors to riot control agents, software related to computer numerical control machines (CNC machines), chromium compounds and controllers used to guide Unmanned Aerial Vehicles (UAVS or “drones”) and missiles. Further items of military significance and those contributing to the enhancement of the industrial capacities of the Russian Federation have also been added to the respective lists. Many of the Annexes with item lists have been amended and the most important lists for export restrictions, Annexes VII and XXIII, have been replaced.
Import prohibition for primary aluminium
The EU extends the existing import prohibition for processed aluminium goods to include primary aluminium while introducing a quota mechanism allowing for 275,000 tons to still be imported until 26 February 2026.
Ban on construction services
EU operators can no longer provide construction services to the Russian government or persons in Russia.
Restrictions on the Russian transport sector
The EU has expanded the scope of its flight ban in Regulation (EU) 833/2014 to encompass air carriers operating domestic flights within Russia including third-country carriers, and those exporting aircraft and other aviation goods and technology to Russian air carriers and their controlled entities. Listed air carriers will be prohibited from operating in the EU.
Five listed air- and seaports are now subject to a comprehensive transaction ban. Except for limited cases where exemptions are available, no business can be conducted with these air- and seaports.
A prohibition on EU road transport undertakings has been introduced, which prohibits them from making changes to their capital structure to increase Russian ownership above 25%.
Another 74 vessels have been added to the list of Russia’s “shadow fleet” vessels, bringing the total to 153 vessels. These vessels have restricted access to EU ports and locks.
Restrictions on the Russian energy sector
EU sanctions have repeatedly targeted the Russian energy sector. The new restrictions in Regulation (EU) 833/2014 include a prohibition on the temporary storage in EU ports or placement under free zone procedures for Russian crude oil or petroleum products.
An extension of the prohibition to provide goods, technology and services for the completion of Russian LNG projects has been extended to apply to crude oil projects in Russia.
Certain listed software for use in oil and gas exploration is now restricted for export to Russia.
Due diligence-obligations in Art. 12gb
The due diligence-obligations in Art. 12gb have been extended to items listed in a new Annex XLVIII. Economic operators exporting or selling such items must implement, as of 26 May 2025, the specific due-diligence measures required by Art. 12gb.
Restrictions on Belarus
The amendments to the Belarus sanctions Regulation (EC) Nr. 765/2006 mirror the trade-related sanctions imposed on Russia by Regulation (EU) 833/2014, including restrictions relating to services, the provision of software and the extension of the due diligence-obligations.
Crimea, Sevastopol, Donetsk, Kherson, Luhansk and Zaporizhzhia
Additional restrictions have been imposed on trade with Crimea, Sevastopol and the non-government controlled areas of Ukraine in the oblasts Donetsk, Kherson, Luhansk and Zaporizhzhia (Specified Territories), as known from the sanctions against Russia. Notably, a restriction on the provision of certain designated services, comparable to those in Art. 5n or Regulation (EU) 833/2014 has been introduced. Accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, IT consultancy, market research and public opinion polling, technical testing and analysis and advertising services may no longer be provided. Also, the restriction on the provision of certain management, industrial design and manufacturing software has been transposed from Art. 5n (2b) Regulation (EU) 833/2014 into the sanctions against the Specified Territories.
For more information on sanctions against Russia, Belarus and non-government controlled areas of Ukraine, contact your usual CMS contacts or local sanctions experts.
