Posted: 05/03/2025
On 24 February 2025, the third anniversary of Russia’s invasion of Ukraine, both the EU and the UK adopted further sanctions on Russia.
The EU Council adopted a 16th package of sanctions. The EU package targets Russia’s trade, energy, transport and infrastructure sectors, whilst the UK has broadened its existing measures to incorporate entities that supply Russia’s military, with the aim of reducing Russia’s energy revenue, targeting Russia’s financial networks and closing certain loopholes.
This article summarises the additions and amendments to both sets of sanctions regimes, focusing on the impact and commercial considerations pertinent to the shipping sector.
The EU’s 16th package aims to strengthen the present sanctions regime and reduce circumvention measures, including by targeting Russia’s ‘shadow fleet’ (vessels used to facilitate the export of Russian crude oil and petroleum to evade the sanctions regime) and those who support the operation of unsafe oil tankers. In addition, to reduce the risk of EU sanctions being bypassed, certain provisions in the 16th package have introduced further measures against Belarus, Crimea, and Sevastopol, as well as to non-government-controlled regions of Ukraine, including Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts.
The 16th package modifies Council Regulation (EU) numbers 269/2014 and 833/2014, introducing further anti-circumventive measures, including additional services, import, export and transit restrictions, alongside additional designated individual listings. The new listings strive to constrain individuals and entities supporting Russia’s military complex and Russia’s shadow fleet. Council Regulation 269/2014 has been updated by Council Regulations 2025/389 and 2025/390. Council Regulation 833/2014 has been updated by Council Regulation 2025/395.
Regulation 269/2014: individual sanctions
The 16th package adds two new criteria for the listings of individuals and entities in annex I, to enable the designation of entities and individuals participating in activities concerning both Russia’s military-industrial complex and Russia’s shadow fleet.
The EU’s 16th package includes 83 additional sanctions listings to annex I under Council Implementing Regulation (EU) 2025/389, including 48 individuals and 35 entities subject to travel bans, asset freezes and a prohibition on making funds and economic resources available to them. Whilst the listings cover a diverse range of persons and entities, the 16th package aims to target Russia’s maritime sector and its military-industrial complex. Certain nationals and companies from third countries, including Turkey and North Korea, allegedly involved in the circumvention of the sanctions regime, also form part of the new listings.
A ‘best efforts’ requirement has now been introduced into Regulation 269/2014, which requires EU entities to ensure that any legal person, entity or body that they own or control does not participate in activities that undermine the restrictive measures imposed by sanctions.
Regulation 833/2014: sectoral sanctions
The below amendments to Regulation 833/2014 have been made under Council Regulation 2025/395.
The 16th package adds 74 vessels to annex XLII of Regulation 833/2014 , bringing the total number of listed vessels that are subject to a port access ban and a ban on the provision of services related to maritime transport to 153. This measure targets non-EU tankers forming part of Russia’s shadow fleet that are responsible for transporting military equipment for Russia, circumventing the oil price cap mechanism or supporting the energy sector of Russia.
There is now a prohibition on entering into any transaction with certain listed ports, locks and airports in Russia that are used for the transfer of UACs, missiles and related technology and components for Russia, or for the circumvention of the oil price cap or of other restrictive measures by vessels practising irregular and high-risk shipping practices. There are, however, exemptions relating to pharmaceuticals, fertilisers, food and particular goods for EU import.
The measures also add a new listing criterion, targeting those who support the operations of unsafe oil tankers. This is a strong response to the use of the shadow fleet, as it targets the network behind the unsafe oil tankers that now widely support Russian oil exports.
The 16th package imposes targeted export restrictions on 53 new companies supporting Russia’s military-industrial complex (including entities in the UAE, Kazakhstan, India, Hong Kong and China) or engaged in sanctions circumvention. This includes 34 companies in countries other than Russia.
Article 5ae introduces a full transaction ban on specific Russian infrastructures: this includes the seaports of Ust-Luga and Primorsk on the Baltic Sea and Novorossiysk on the Black Sea as they are used to transport Russian crude oil via the shadow fleet, circumventing the oil price cap mechanism. The transactions ban also applies to the Volga port Astrakhan, and the Makhachkala port on the Caspian Sea, as well as to two Moscow airports (Vnukovo Airport and Zhukovsky Airport) and four regional ones. The aim is to target Russian ports and airports that are used to transport drones and other combat-related goods and technology that directly contribute to Russia’s military efforts or provide revenue to fund the war.
A new import ban on aluminium exported from or originating in Russia has been introduced to annex XXI by adding CN code 7601 (‘Unwrought aluminium’) to the list of goods that generate substantial revenue for Russia. During a transitional period, economic operators will still be able to import aluminium, subject to an overall volume limit (quota) corresponding to less than one year of imports from Russia. This quota mechanism will allow 275,000 tonnes, which equates to 80% of EU imports in 2024, to be used over a 12-month period. By the end of 2026, no Russian aluminium can be imported into the EU.
The EU has introduced a complete prohibition on the temporary storage of Russian crude oil or petroleum products within the EU, which was until now allowed, provided the oil complied with the price cap and went to a third country. The aim of this measure is to inflict additional costs on the transport of Russian oil thereby reducing Russian revenue. The package extends the prohibition to provide goods, technology and services for the completion of Russian LNG projects to crude oil projects in Russia, such as the Vostok oil project.
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 or for domestic flights in Russia. If listed, these airlines would not be allowed to land in, take off from, or fly over the territory of the EU.
To prevent the circumvention of the road transport prohibition already in place, there is now a distinct ban on road transport undertakings established in the EU (before 8 April 2022) from altering their capital structure in a way that would result in increasing the share owned by a Russian entity or individual above 25%.
The existing prohibition on providing services now extends to that of construction services, including civil engineering works.
On 24 February 2025, the UK implemented its largest sanctions package against Russia since the invasion in 2022. Some 107 new sanctions were implemented under the UK Russia (Sanctions) (EU Exit) Regulations 2019. The sanctions aim to further weaken Russia’s energy revenues, a significant source of funding for its war against Ukraine. The sanctions include the new designations of 67 individuals and entities, and the specification of a further 40 vessels forming part of Russia’s shadow fleet carrying Russian oil. These vessels have collectively carried over $5 billion worth of Russian oil and oil products in the last six months alone. The additional listings bring the total number of oil tankers sanctioned by the UK to 133, the highest of any European nation.
The primary aim of the new sanctions is to weaken and target those supporting Russia’s war efforts, including:
The amendments and further additions to both the EU and UK sanctions regimes serve to reinforce the interdependent nature of the geopolitical landscape and sanctions. For those in the shipping sector, it is imperative to keep abreast of this moving landscape and the consequent impact on sanctions to ensure against falling foul of the ever-changing rules and regulations.
© 2025 Penningtons Manches Cooper LLP.
All rights reserved.
Website design by Frontmedia / Dynamic Pear
Penningtons Manches Cooper LLP is a limited liability partnership registered in England and Wales with registered number OC311575 and is authorised and regulated by the Solicitors Regulation Authority under number 419867.
Return to news headlines 
