Three years of war: New sanctions adopted by the EU and the UK

European Commission President Ursula von der Leyen and EU High Representative Kaja Kallas welcomed the new sanctions package. "The EU is clamping down even harder on circumvention by targeting more vessels in Putin's shadow fleet and imposing new import and export bans", von der Leyen posted on X last week, emphasising "We are committed to keep up the pressure on the Kremlin".

Kaja Kallas added, "For three years now, Russia has relentlessly bombed Ukraine, attempting to steal land that isn't theirs to take. This new round of sanctions not only targets the Russian shadow fleet but those who support the operation of unsafe oil tankers, videogame controllers used to pilot drones, banks used to circumvent our sanctions, and propaganda outlets used to spout lies. There is no doubt about who the aggressor is, who should pay and be held accountable for this war. Every sanction package deprives the Kremlin of funds to wage war. With talks underway to end Russia's aggression, we must put Ukraine in the strongest possible position. Sanctions provide leverage."

UK Foreign Secretary David Lammy emphasise the UK's commitment to Ukraine, "As the world marks the grim milestone of Putin's full-scale invasion entering its fourth year, we cannot and will not turn our backs on Ukraine in their fight for our shared security."

Click here to read the press release from the Council of the European Union and from the European Commission. We expect that the new measures included in the 16th sanctions package will be published in the EU Journal shortly. The new asset freeze targets are already published in Council Implementing Regulation (EU) 2025/389. 

The UK press release is available here, and the new asset freeze targets are published here. 

Key Components of the EU's 16th Sanctions Package

The EU's 16th sanctions package against Russia strengthens its efforts to disrupt the Kremlin's war apparatus and demonstrates robust support for Ukraine. With these enhanced measures, the EU reaffirms its commitment to maintaining pressure on Russia, ensuring that the international community continues to address the ongoing conflict effectively.

This latest package includes several significant components aimed at further isolating Russia economically and operationally:

• Individual listings: The Council adopted listings for 83 individuals, including 48 persons and 35 entities responsible for actions undermining or threatening Ukraine's territorial integrity, sovereignty, and independence.
• Import ban on aluminium: A complete ban on Russian primary aluminium imports, including unwrought aluminium, will be phased in, aiming to reduce European reliance on Russian metal.
• Expansion of shadow fleet sanctions: An additional 74 vessels identified as part of Russia's "shadow fleet" are now blacklisted, increasing the total number to over 150. These vessels, which include not only tankers but also other types of vessels, have been used to circumvent Western trade restrictions, most notably restrictions on oil trade. Many of these vessels are registered in third countries, highlighting the extensive network Russia employs to bypass sanctions.
• Export restrictions: New bans have been placed on exporting chemicals, chrome, and other products essential for precision machine tools, crucial for Russia's industrial and military capabilities.
• Service ban for oil and gas: A ban on servicing oil and gas refineries to hinder Russia's energy sector. Extended restrictions on goods and technologies related to oil and gas exploration and the completion of crude oil projects in Russia.
• Financial and media sanctions: Thirteen additional Russian banks have been expelled from the SWIFT system, and the broadcasting licences of eight Russian media outlets have been suspended.
• Broadcasting ban: The EU suspended licences for eight Russian media outlets critical for the Kremlin's war propaganda and destabilising activities. These include EADaily, Fondsk, Lenta, NewsFront, RuBaltic, SouthFront, Strategic Culture Foundation, and Krasnaya Zvezda/Tvzvezda.
• Transaction ban: The EU impose today a transaction ban on credit and financial institutions outside Russia utilising the Central Bank of Russia's SPFS system. Furthermore, 13 regional Russian banks have been sanctioned.
• Military and industrial complex sanctions: The list of entities supporting Russia's military and industrial complex was expanded with 53 new entries, imposing tighter export restrictions on dual-use goods and technologies, including entities from third countries like China, India, and Turkey. The entities on this list are now subject to stricter export restrictions. This means they will face additional limitations on the export of goods and technologies that have both civilian and military applications (known as dual-use goods). The purpose of these restrictions is to prevent these entities from supplying Russian with critical technology and materials that could enhance its military capabilities.
• Port, lock, and airport restrictions: Transactions with certain Russian ports, locks, and airports used for transferring military goods or circumventing sanctions have been prohibited.
• Transport restrictions: A widened EU flight ban targets listed air carriers within Russia, and restrictions on road transport involving Russian ownership have been enhanced.
• Construction service ban: The EU have prohibited the provision of construction services in occupied Ukrainian territories and implemented due diligence for operators to prevent unlawful re-exportation of sanctioned goods.
• Energy measures: The EU has completely prohibited the temporary storage or placement under free zone procedures of Russian crude oil or petroleum products in EU ports. The prohibition on providing goods, technology, and services for the completion of Russian LNG projects now also applies to crude oil projects in Russia, such as the Vostok oil project. Additionally, the package extends the existing software ban to restrict the export, supply, or provision of oil and gas exploration software to Russia.

Additionally, today's decision expands the list of restricted items that contribute to the technological enhancement of Russia's defence and security sector. This includes components critical for the development and production of Russia's military systems, such as chemical precursors for riot control agents like Chloropicrin, software related to computer numerical control (CNC) machines, various chromium compounds, and devices used for guiding Unmanned Aerial Vehicles (UAVs).

Also, the EU has introduced further restrictions on the export of goods that support Russia's industrial capabilities. This includes certain chemicals, types of plastics, and rubber, the new measures also impose stricter controls on the transit of these goods through Russia and impose additional restrictions on the import of primary aluminium, which provides significant revenue for Russia.

Comparison to the 15th Sanctions Package

The new sanctions package particularly focuses on further restricting Russia's economic and military capabilities by targeting critical sectors and closing existing loopholes. Notably, it targets Russia's shadow fleet, industrial and military sectors with particular emphasis on dual-use technology, and the financial and media sectors.

Noteworthy advancements distinguish the 16th package from the prior sanctions package enforced on 16 December 2024:

• Increased maritime restrictions: Unlike the 15th sanctions package, which sanctioned 52 vessels in addition to 27 already blacklisted, the 16th package significantly expands this list with 74 additional ships. This extensive inclusion targets a broader portion of Russia's shadow fleet, illustrating the EU's reinforced focus on combating the methods used by Russia to evade oil trade restrictions.
• Extended export bans: The latest sanctions includes more diverse export bans. Newly restricted items specifically target critical sectors of Russia's economy and military, such as chemicals, chromium-based products, and components essential for precision machine tools. This ensures that Russia's access to vital industrial and military resources continues to be eroded.
• New categories for export restrictions: In response to Russia's continued use of dual-technologies, the 16th sanctions package introduces new categories of export controls. These include items like video game consoles and flight simulators, which can potentially repurposed for military applications. The introduction of these categories exemplifies the EU's proactive approach to mitigating dual-use risks.
• Additional financial and media sanctions: The financial restrictions now encompass 13 additional regional banks, crucial to Russia's financial infrastructure. Similarly, media sanctions were extended, with licences suspended for eight more Russian outlets accused of propagating war propaganda. The inclusion of these new targets demonstrates the EU's comprehensive strategy in tackling Russia's information warfare and financial networks.
• Broadened transportation and port restrictions: The new measures also impose a broadened set of restrictions on transportation, including stricter bans on transactions with certain Russian ports, locks, and airports used for military goods and sanction circumvention. Enhanced road transport restrictions have been implemented to limit Russian ownership and control within the EU's transport sector. The package extends the flight ban to enable the listing of third-country carriers conducting domestic flights within Russia or supplying aviation goods to Russian airlines for domestic flights. If listed, these airlines will not be allowed to fly to the EU. The road transport prohibition now also prevents increasing Russian ownership above 25% in EU road transport undertakings, thereby closing potential loopholes for circumventing existing sanctions.
• Expanded trade restrictions: The 16th package introduces tighter controls on goods that contribute to the enhancement of Russia's industrial capabilities. This includes chemicals, certain plastics, and rubber, as well as further limitations on the import of primary aluminium, seen as a significant revenue stream for Russia.

The 16th sanctions package also targets systematically important sectors of the Russian economy such as energy, trade, transport infrastructure, and financial services. It adds new measures aimed at curbing the circumvention of sanctions by mirroring certain provisions in the Belarus sanctions regime. Additionally, the EU has strengthened its sanctions concerning Crimea and Sevastopol, and non-government-controlled areas of Donetsk, Kherson, Luhansk, and Zaporizhzhia oblasts.

The UK's largest package of sanctions since 2022 

Simultaneously, the UK has announced its largest package of sanctions against Russia since 2022, underscoring that we are now "facing a once in a generation moment for the collective security of our continent". The new measures aim to put Ukraine in the best position to achieve peace through strength. 

According to OFSI's press release, the new measures target: 

• Producers and suppliers, including in third countries, of machine tools, electronics and dual-use goods for Russia's military. Entities in the Central Asian states such as Turkey, Thailand, India and China are among those targeted as the largest suppliers of critical goods to Russia's military.
• North Korean generals and senior officials responsible or complicit in deploying DPRK forces to Russia. 
• Russian companies that are funnelling advanced European technology into Russia. 
• Foreign financial institutions supporting Russia's war machine. 

Diplomatic Context and Future Implications

The diplomatic situation around the EU's latest sanctions package is complex. A key issue is the ongoing peace talks between the United States and Russia. US Secretary of State Marco Rubio has said that the EU will need to be involved in these negotiations because of the significant impact of EU sanctions on Russia. This creates a concern that the US might make a deal with Russia that could weaken the collective efforts of the EU and its allies.

Nevertheless, the new sanctions go further than previous ones by targeting more vessels and expanding import and export bans. This aims to disrupt Russia's military and financial operations by closing loopholes. It is a signal that the EU is serious about maintaining their stance, even as diplomatic discussions continue. These actions also show that the EU is ready to further use economic measures to support stability and security in the region.