News

The EU’s 18th package of sanctions against Russia: strengthening the regime and new obligations for economic operators

Date : 21 August 2025

Léa Ratel Bertrand Rager

On July 31, 2025, the Council of the European Union adopted the 18th package of sanctions against Russia as part of its ongoing response to the military aggression against Ukraine. This new set of measures reflects the EU’s increased determination to dry up the Kremlin’s sources of funding, target circumvention channels, and impose enhanced due diligence obligations on European and international operators.

Official text: Official Journal of the EU (forthcoming)

  1. Main objectives of the 18th package
  • The measures adopted are based on five strategic pillars:
  • Reducing Russian energy revenues
  • Strengthening the isolation of the Russian banking system
  • Targeting Russian and Belarusian military supply chains
  • Combating circumvention mechanisms (third countries, crypto assets)
  • Accountability mechanisms under international law (deportation of children, cultural violations)
  1. Energy measures: tighter regulation of the oil sector
  • The package introduces several measures to strictly regulate trade in energy products:
  • Reduction of the price cap on Russian crude oil: from $60 to $47.6 per barrel, with automatic adjustment to 15% below the average price of Urals crude oil over the previous six months.
  • Ban on all transactions related to the Nord Stream 1 and 2 gas pipelines.
  • Extension of the import ban to refined products derived from Russian crude oil, even if processed outside Russia.
  • Sanctions against the “shadow fleet”: 105 new vessels blacklisted, bringing the total to 444, with measures prohibiting access to ports and restricting logistics services.
  1. Strengthening financial measures
  • The financial component of the package is significant:
  • Total ban on transactions with 45 Russian banks, including a ban on providing specialized messaging services (e.g., SWIFT).
  • Extension to third-party financial actors (particularly crypto assets) involved in circumventing sanctions or linked to the Russian messaging system.
  • Sanctions against the Russian Direct Investment Fund (RDIF): ban on transactions with its subsidiaries, holdings, and intermediaries.
  • Ban on providing certain banking software to the Russian Federation or public entities.
  1. Trade measures and anti-circumvention measures
  • Addition of 26 new entities (15 Russian, 11 in third countries – Turkey, China, Hong Kong) for their involvement in the military industry or circumvention practices.
  • Extension of export bans: addition of critical products for energy and construction.
  • Targeted “catch-all” mechanism: allows Member States to block exports to third countries in cases of suspected re-export to Russia.

Useful reference: Regulation (EU) No 833/2014 – Sanctions regime against Russia (consolidated)

  1. Accountability and ISDS disputes (Investor-State Dispute Settlement)

The package introduces preventive measures against arbitration disputes brought by persons sanctioned under bilateral investment treaties (ISDS), allowing Member States to:

  • Refuse compensation to sanctioned investors;
  • Recover damages caused by abusive litigation based on the effects of sanctions.
  1. Extension of the regime to Belarus

New measures are also being adopted against Belarus, including:

  • A ban on the acquisition of weapons;
  • Extension of the ban on banking services to a general ban on transactions;
  • Addition of industrial entities linked to the Russian military-industrial complex.

Companies exposed to international flows or complex supply chains must:

  1. Review their country/customer risk mapping;
  2. Rigorously monitor relationships with third parties located in Turkey, China, the United Arab Emirates, or India (identified circumvention zones);
  3. Apply enhanced due diligence procedures, including on crypto-assets and indirect relationships;
  4. Update their contractual clauses on sanctions compliance.

 

Useful links:

 

Make an appointment