February, 2025 - EU introduces 16th package of sanctions against Russia; and UK announces ‘largest sanctions package against Russia since 2022’
EU Sanctions
On 24th February, 2025 (the third year anniversary of Russia’s invasion of Ukraine), the European Union (EU) issued its 16th package of sanctions against Russia. These include measures which target Russia’s energy, trade, infrastructure and transport sectors (among others).
Trade
The latest measures include a direct import ban into the EU from Russia of primary aluminium (previous measures included a prohibition for importing processed aluminium goods from Russia). During an initial 12-month transitional period, a quota mechanism has been introduced, allowing for 275,000 tons of aluminium (i.e. 80% of EU imports in 2024). By the end of 2026, no Russian aluminium can be imported into the EU.
Dual-use export restrictions have also been extended to include additional items used on the battlefield or with special military significance, such as dual-use chemical precursors and video-game controllers.
Full transaction ban on certain Russian ports
The 16th package also includes a full transaction ban on certain Russian ports (and airports), which are believed to have been used to transport combat-related goods and technology, or to circumvent the oil price cap by transporting Russian crude oil via ships in the shadow fleet. The restrictions are broadly drafted and will apply to any relevant port call even if there is no direct transaction with the port authorities themselves.
The banned ports are the Volga port, Astrakhan, and Makhachkala port on the Caspian Sea, and sea ports Ust-Luga and Primorsk on the Baltic Sea, and Novorossiysk on the Black Sea. There are certain exemptions including foodstuffs and fertilisers, specified goods for EU import, pharmaceuticals, and an exception for price cap compliant Russian oil and refined petroleum products and oil from third party countries, such as Kazak oil.
Energy
The EU has also decided to completely prohibit temporary storage or the placement under free zone procedures of Russian crude oil or petroleum products within the EU. This was previously allowed if the oil complied with the price cap and ultimately went to a third party country.
The existing 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, such as the Vostok oil project.
Ships targeted
The EU has listed an additional 74 ships that form part of the shadow fleet or contribute to Russia’s energy revenues, bringing the total number of listed ships to 153. These ships are subject to a port access ban, and it is prohibited to provide a range of maritime services to them.
There is also a new listing criterion, targeting those who ‘support’ the operations of unsafe oil tankers.
Further information can be found by following this link.
UK sanctions
The UK has also updated its list of sanctioned entities and individuals including non-Russian nationals. The latest measures include the designation of a further 40 ships said to be part of the shadow fleet, bringing the total listed to over 130.
Further information can be found by following this link.
If Members have any questions in relation to the above issues they are invited to contact the Club for further information.
Authored by Charlotte Murphy and Kieron Moore