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On 18 July 2025, the European Union adopted its 18th sanctions package against Russia by means of Regulation (EU) 2025\/1494.<\/strong> We provide you with an overview of the most important changes below:<\/p>\n\n\n\n 1. Extension of the goods and personal listings<\/strong> Annex VII has been expanded overall. Of particular note is the extension covering numerically controlled machine tools and chemical components of fuels.<\/p>\n\n\n\n 2. Optional administrative mechanism<\/strong> 3. Import ban on petroleum products derived from Russian oil<\/strong> 4. Nord Stream and Nord Stream 2<\/strong> 5. Financial sector: SPFS, transactions, and circumvention provisions<\/strong> The transaction prohibition under Article 5ac has also been extended to persons and organisations outside Russia that use the Russian financial messaging system SPFS<\/strong>. The persons and organisations concerned are listed in Annex XLIV.<\/p>\n\n\n\n 6. Crude oil price cap and the shadow fleet<\/strong> At the same time, a further 105 vessels<\/strong> belonging to the so-called “shadow fleet<\/strong>,” used to transport sanctioned Russian energy products, have been added to the sanctions list.<\/p>\n\n\n\n 7. Further measures<\/strong> The 18th sanctions package is aimed, in particular, at the Russian energy and financial sectors. This is intended to further curtail Russia’s sources of revenue, prevent circumvention of the existing sanctions, and thereby further increase the pressure on Russia.<\/p>\n\n\n\n
This package once again contains far-reaching tightening of the existing restrictive measures, in particular in the areas of export control, energy, financial transactions, and third-country circumvention. For companies, this results in new due diligence obligations and a considerable need for adjustment.<\/p>\n\n\n\n
The 18th sanctions package adds further persons, organisations, and entities to Annex IV. This lists persons, organisations, and entities that are military end users, that belong to Russia’s military-industrial complex, that maintain connections with Russia’s defence and security sector, or that otherwise support it. They are subject to stricter export restrictions for so-called dual-use goods, as well as for listed goods under Annex VII. In particular, third-country organisations involved in circumvention deliveries for unmanned aerial vehicles (UAVs), or drones, have been added.<\/p>\n\n\n\n
The Regulation introduces an optional administrative mechanism<\/strong>: in the case of deliveries of Annex VII goods to third countries, national authorities may notify the exporter that there is sufficient reason to believe that the final destination of the intended delivery is Russia. Once notified, the company concerned becomes obliged to obtain an export authorisation.
The aim is to achieve an EU-wide harmonised interpretation and legal certainty for exporters. The mechanism is similar to the catch-all authorisation requirement under Article 4 of the Dual-Use Regulation.
In addition, the transit prohibitions applicable to Russia<\/strong> have been extended to cover machinery, chemicals, metals, and plastics.<\/p>\n\n\n\n
The new sanctions package provides for an import ban on petroleum products <\/strong>manufactured in third countries from Russian crude oil. Exceptions apply for certain partner countries listed in Annex LI <\/strong>(currently Canada, Norway, the United Kingdom, the United States of America, and Switzerland), as well as for states that are net exporters of crude oil. Commission guidelines are planned for the implementation of the ban, in particular with regard to the evidence importers of petroleum products will be required to provide.<\/p>\n\n\n\n
The Regulation prohibits all transactions<\/strong> connected with Nord Stream and Nord Stream 2, including the completion, operation, maintenance, and use of the pipelines.<\/strong><\/p>\n\n\n\n
The previous “mere” disconnection from the SWIFT system is being converted into a full transaction prohibition. Exceptions remain possible, under strict conditions, for the withdrawal of investments or the winding-down of business activities in Russia. In addition, a further 22 institutions <\/strong>have been added to the list of sanctioned banks<\/strong>.
The transaction prohibition applicable to financial institutions now also extends to crypto-asset service providers and oil traders who circumvent the prohibitions under Articles 3m, 3n, and 3s.<\/p>\n\n\n\n
The existing price cap on Russian crude oil <\/strong>is being replaced by an automatic adjustment mechanism,<\/strong> recalculated on a regular basis, designed to remain permanently 15% below the average market price.<\/p>\n\n\n\n
Further measures include a prohibition on providing software solutions <\/strong>in the banking sector (Article 5n), a transaction prohibition against the Russian Direct Investment Fund (RDIF)<\/strong> and companies in which the fund holds a significant interest (Article 5ag), and restrictions on the recognition and enforcement of judgments<\/strong> of Russian courts and arbitral tribunals (Article 11).<\/p>\n\n\n\n