The EU's 18th sanctions package and other key sanctions updates

This Sanctions Alert provides an overview of the EU's 18th sanctions package, as well as other recent key sanctions developments across the EU, US, UK, and Norway.

The EU's 18th sanctions package

Today, on 18 July 2025, the Council of the European Union approved its 18th package of sanctions against Russia. According to Kaja Kallas, High Representative for Foreign Affairs and Security Policy, the EU's 18th package is "one of its strongest sanctions packages against Russia to date". Adoption of the package followed several rounds of negotiations, reportedly due to disagreements regarding the oil price cap and concerns from Slovakia about the EU's REPowerEU Plan to reduce European dependency on Russian fossil fuels by the end of 2027. 

The 18th package involves the listing of 55 individuals and entities, including the largest Rosneft refinery in India, as subject to EU asset freeze provisions. New measures have also been implemented, primarily targeting two key sectors in Russia - the energy sector and the banking sector - alongside certain non-sector-specific measures. 

Within the energy sector, key measures include:

• A ban on all transactions regarding the Nord Stream 1 and 2 pipelines
• A ban on imports of refined products based on Russian crude oil
• Introducing a new dynamic oil price cap mechanism, setting the price of Russian oil exported to third countries at 15% lower than the average market price for Russian crude oil. In practice, this lowers the oil price cap from USD 60 to approximately USD 47.60 per barrel, with automatic adjustments every six months and the possibility of ad-hoc reviews
• The listing of an additional 105 shadow fleet vessels involved in violations of the oil price cap

Key measures targeting the banking sector include:

• Extension of the existing prohibition on using the SWIFT system to a full transaction ban
• Extension of the full transaction ban to an additional 22 Russian banks, as well as financial operators in third countries involved in sanctions circumvention
• Sanctioning of the Russian Direct Investment Fund, and its subsidiaries and investment projects

Additionally, the EU is expanding export bans on critical technology, industrial goods, and raw materials worth more than EUR 2.5 billion. This includes certain machinery, metals, plastics, chemicals, and technologies used in the production of drones, missiles, and other weapon systems. Furthermore, a total of 26 Russian and foreign companies supporting Russia's military and industrial complex have been made subject to tighter export restrictions concerning dual-use goods and technologies. 

Other EU updates

Three days before the agreement on the 18th sanctions package, on 15 July 2025, the Council of the European Union also expanded its restrictive measures targeting Russian hybrid threats. Nine individuals and six entities were listed for destabilising actions in the EU and Ukraine, including activities related to Foreign Information Manipulation and Interference (FIMI) affecting political processes in foreign states. The listings included, among others, the Russian state-owned Television and Radio Broadcasting Network. Updates were also made to Regulation (EU) 2024/1485 concerning internal repression and human rights violations in Russia, with the sanctioning of five new individuals. 

The EU has also added eight individuals and one entity to its sanctions list under the EU Global Human Rights Sanctions Regime, on the basis of their involvements in human rights violations and transnational repression related to Iran. Together with the UK, the EU has also given Iran a deadline to curtail its nuclear programme, underpinned by a threat to reinstate UN sanctions on Iran from 29 August 2025. 

Further, the EU has added three individuals to its sanctions programme against Haiti, as well as seven individuals and three entities to its restrictive measures concerning Moldova. 

Implementation of EU listings into Norwegian law

Effective 10 July 2025, the EU's listings from its 17th sanctions package of 20 May 2025 have been implemented into Norwegian law. The listings cover 21 natural persons and 6 entities. This includes the fishing companies Norebo JSC and Murman SeaFood, due to connections to Russian state-sponsored intelligence and sabotage against critical infrastructure in the North and Baltic Seas. 

Pursuant to the Norwegian regulation implementing the listings (FOR-2025-07-08-1505), exceptions to the asset freeze measures and the prohibition on making funds available are provided specifically for Norebo JSC and Murman SeaFood if their vessels call at Svalbard or are located within the territorial waters of Svalbard. This exception does not apply to Norwegian persons and entities.

US updates

On 9 July 2025, the US Department of the Treasury's Office of Foreign Assets Control (OFAC) designated 22 entities based in Hong Kong, the UAE, and Türkiye for facilitating the sale of Iranian oil benefitting the Islamic Revolutionary Guard Coros-Qods Force. This represents the second round of US sanctions targeting Iran's 'shadow banking' infrastructure, following the issuance of the National Security Presidential Memorandum 2 on 4 February 2025 and the US strikes on Iranian nuclear facilities on 22 June 2025. OFAC has also sanctioned additional persons and entities involved in smuggling Iranian oil and petroleum products under Executive Orders 13902 and 13846.

US sanctions against Syria have also been further relieved. Under Executive Order 14312, OFAC revoked the US sanctions program against Syria effective 1 July 2025, terminating the Syria Sanctions Regulations (31 C.F.R Part 542) and most Syria-related executive orders and general licenses. However, Executive Order 13894, as amended by Executive Order 14142, remains in place, allowing for asset freeze designations of individuals and entities associated with the former Assad regime or contributing to instability in Syria. Additionally, the export ban on dual-use items on the Commerce Control List of the US Export Administration Regulations (EAR) and weapons on the Munitions List of the US International Traffic in Arms Regulations (ITAR), per Section 5(a)(1) of the Syria Accountability Act, has been lifted. Export restrictions issued directly under the EAR or ITAR, however, remain applicable.