On 18 July 2025, the European Union (EU) adopted its anticipated 18th package of sanctions against Russia. The 18th package will particularly impact the energy, banking, and military sectors, as well as trade with the EU. Finnish entities should pay special attention to the updated lists of individuals and entities subject to asset freezes and to prohibitions on making funds or economic resources available to those listed. In addition, the package includes updates to the list of restricted items that contribute to the technological enhancement of Russia's defence and security sector (e.g., Annexes IV, VII, XXIII). The 18th package also addresses anti-circumvention by granting authorities in EU member states an additional tool to scrutinise shipments to third countries. This enables authorities to stop and investigate any suspicious shipments where there is a risk of diversion to Russia, thereby reducing the likelihood of sanctions avoidance or circumvention. Finally, please note that this package also includes additional measures on Belarus.
We have compiled a checklist below to make your first day back at work smoother after the summer holidays:
- Identify Changes in EU Legislation: stay current with new or amended EU sanctions regulations, ensuring your compliance program reflects the latest legal requirements.
- Update Your Sanctions Compliance Program: integrate all relevant legislative updates into your existing policies and procedures to maintain full compliance.
- Review EU Guidance and Best Practices: treat the summer period as an opportunity to re-examine official EU guidance and best practices for sanctions compliance.
- Assess Sanctions-Related Risks: conduct a thorough risk assessment to understand how sanctions might affect your organisation. Implement robust risk control mechanisms based on the identified vulnerabilities.
- Train Personnel: provide regular and targeted training to staff and employees, ensuring they remain alert to sanctions requirements and obligations.
- Prioritise Red Flags for Sanctions Compliance and/or Circumvention: Establish clear processes to identify and respond to potential circumvention indicators, ensuring prompt action when red flags arise.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
