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EU adopts 16th Sanctions Package against Russia
On 24th February 2025 the European Union adopted its 16th Sanctions Package against Russia, marking the third anniversary of conflict between Russia and Ukraine. This package targets critical sectors of the Russian economy, including trade, transport, energy, infrastructure, and financial services, and introduces measures to address the 'shadow fleet' and prevent sanctions circumvention.
The Key Measures adopted are the following:
Listings & Designation Criteria
- 48 individuals and 35 entities have been added to the sanctions list, subjecting them to asset freezes and prohibiting the provision of funds or economic resources.
- 74 vessels associated with Russia's "shadow fleet" have been designated, increasing the total number of listed vessels to 153.
- The designated vessels face a port access ban, with updated exclusions for emergencies, safety, humanitarian, or environmental purposes.
Transactions Ban
- Engaging in transactions with certain Russian ports and locks is prohibited, with exceptions for emergencies, safety, humanitarian purposes, and specific transactions related to natural gas, metals, oil, pharmaceuticals, and civil nuclear capabilities.
- The ports that falls into the restriction are those listed in Part A of Annex XLVII Article 5ae of Council Regulation (EU) 2025/395. This includes ports such as Ust-Luga, Primorsk, and Novorossiysk, which are utilized for maritime transport of Russian crude oil or petroleum products by vessels involved in "irregular and high-risk shipping practices." It also encompasses Astrakhan port on the Volga River and Makhachkala port on the Caspian Sea, which are used for transferring Unmanned Aerial Vehicles, missiles, or related technologies supporting Russia's war against Ukraine. Further banned ports are Begishevo, Vnukovo, Zhukovsky, Perm, Kolysovo and Pskov.
These new sanctions are not a prohibition on Vessels sailing into any of the listed ports, however if damage was to occur to a vessel whilst in one of these ports any EU insurers would not be able to make any payments directly or indirectly to the Port (e.g. for Port Fees or damage to a Port), or reimburse liabilities, even if the vessel was in the Port for what is deemed ‘legitimate trade’ (which is restricted to the transportation of specific items such as natural gases, refined petroleum and humanitarian goods).
The only exemption lies in respect of the provision of ‘financing or financial assistance’ (which includes insurance) if a vessel needs assistance seeking a place of refuge, for an emergency port call for reasons of maritime safety, for saving life at sea, or for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety or the environment, or as a response to natural disasters.
Trade Restrictions
- A ban on importing or transporting Russian primary aluminium into the EU, implemented through a phased quota mechanism.
- Expanded dual-use export restrictions to block Russia's access to critical technologies, including chemical precursors, CNC machine tool software, and chromium ores.
- Export restrictions on 53 entities supporting Russia’s military-industrial complex or involved in sanctions circumvention, located in Russia and third countries.
These measures aim to further pressure Russia economically and limit its ability to sustain its military efforts in Ukraine.
UK announces largest sanctions package against Russia since 2022
Similarly to the European Union, also the UK announced its largest sanctions package against Russia since 2022. This comprehensive package includes over 100 new sanctions targeting various sectors and individuals.
Key Targets
- Producers and Suppliers: Companies providing machine tools, electronics, and dual-use goods for Russia's military, including microprocessors used in weapons systems, based in countries like Central Asia, Turkey, Thailand, India, and China.
- North Korean Officials: North Korea's Defence Minister and senior officials involved in deploying DPRK forces to Russia.
- Russian Entities: 13 Russian targets, including LLC Grant-Trade and its proprietors, who have facilitated the transfer of advanced European technology to support Russia's military operations.
- Shadow Fleet: 40 additional oil tankers transporting Russian oil, increasing the total number of UK-sanctioned oil tankers to 133.
Trade and Compliance
Trade involving Russia is heavily regulated, and insurance cover cannot be provided for trade that breaches applicable sanctions. Thorough due diligence is strongly advised throughout the trade process, including vetting parties, cargoes, vessels, and service providers involved in high-risk transactions.
These measures aim to disrupt Russia's military supply chains and economic resources, further pressuring the country to cease its military actions in Ukraine.
All Clubs in the International Group have issued a similarly worded circular.
