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The EUās 16th sanctions package on Russia represents a significant expansion of measures, including additional restrictions on Russian banks, further oil and gas related restrictions, and new export and import restrictions.
The updated UK sanctions include new designations targeting Russia's military supply chains as well as political figures.
EU
The EU’s 16th sanctions package introduces significant changes to the EU's Russia and Belarus sanctions regulations.
Notably, the EU has strengthened several trade sanctions. These include export restrictions such as an expanded ban on exporting industrial goods of military significance and an expanded export prohibition on dual-use and strategic goods. The trade sanctions measures introduced also include further restrictions on the import of primary aluminum.
Heightened due diligence obligations have been introduced for EU operators, with new requirements to prevent goods from reaching Russia and additional “best efforts” clauses requiring EU parent companies to ensure their non-EU subsidiaries do not undermine EU sanctions restrictions.
A number of sector-specific restrictions were also introduced in the 16th package. Energy measures include a ban on the temporary storage of Russian crude oil in EU ports and restrictions on providing goods and technology for Russian energy projects, while financial sector measures introduced a regime to target Russian institutions and crypto asset providers circumventing sanctions.
The sanctions package also includes new transport and infrastructure measures, a range of new asset-freeze designations, including 83 persons/entities subject to restrictive measures for supporting Russia’s military complex, and the adoption of similar sanctions against Belarus.
Certain EU sanctions targeting Syria's economy have been suspended.
UK
The UK, on the same day, also updated its sanctions regulations to include new designations, mainly targeting Russia’s military supply chains and political figures. Notably, the UK package included the designation of Kyrgyzstan-based OJSC Keremet Bank, a non-Russian financial institution carrying on business in the Russian financial sector.
A list of links to the new regulations and designations is available at the end of the overview.
The EU introduced additional export and import restrictions, expanded due diligence requirements, and new measures affecting the energy and financial sectors. Transport restrictions have been strengthened, and new designations have been made targeting individuals and entities involved in Russia's war economy. Similar sanctions have also been imposed on Belarus, bringing the EU's Belarus sanctions regime more in line with its Russia regime.
Key measures include:
The EU has adopted new sanctions against Belarus mirroring certain provisions of the 16th sanctions package against Russia. These include:
The sanctions regimes concerning (a) Crimea and Sevastopol and (b) the non-government-controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts are also strengthened in the 16th sanctions package, particularly to address circumvention.
Key changes include:
On 24 February 2025, the UK introduced a new package of sanctions designations, described by the UK government as its "largest sanctions package against Russia since 2022". 107 individuals, entities and ships were added to the UK's sanctions list. These designations target:
On 24 February 2025, the EU also suspended the restrictive measures on key sectors of the Syrian economy, as part of the EU's efforts to support a political transition and recovery within Syria. Key updates include the suspension of import restrictions on oil from Syria andexport restrictions on jet fuels, fuel additives, and oil and gas-related technology from the EU to Syria. Exemptions to the prohibition on establishing banking relations between Syrian banks and Member State financial institutions were also introduced. All other prohibitions and restrictions remain in place. They include individual asset freezing measures for persons connected to the former al-Assadās regime or active in the chemical weapons sector and illicit drug trade, as well as several sectoral measures, especially on arms trade and dual-use goods.
HM Treasury Notice, Russia, 24/02/2025, and Russia Sanctions Targets.
Authored by Aline Doussin, Lourdes Catrain, Kate Poppitt, Pierre Estrabaud, Alp Y Ozturk, Chris James, Nina Spieler, Florence Yiu, and Vittorio Santaniello.
Given the broad scope of the EU’s 16th sanctions package and its significant impact across various industries, such as pharmaceuticals, energy, financial services and tech, it is essential that companies undertake a thorough review of their operations to ensure ongoing compliance with the EU's updated sanctions regime. Such a review may also identify key opportunities arising from the updated sanctions package, such as the use of widened licensing grounds for the export of certain goods.
The extension of the "best efforts" obligation on EU companies with non-EU subsidiaries, has further implications for non-EU companies operating outside of the EU. Such companies should also therefore review their activities in light of the EU's 16th sanctions package.
Companies should also review the UK's updated sanctions designations in order to ensure that ongoing operations do not breach UK sanctions in light of this.
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