The new 18th EU sanctions package against Russia was adopted on 18 July 2025. The measures are set out in regulations and implementing regulations. The legal acts regarding Russia can be found here and here, and the legal acts regarding Belarus can be found here and here.
Below, we have summarized the most significant changes.
Additional listings
Further listings have been added to Annex I of Regulation 269/2014 of asset freezes on entities and individuals providing direct or indirect support to Russia's military industrial complex or engaging in sanctions circumvention, including entities and individuals in Russia as well as in other third countries.
Energy sector
The price cap for crude oil has been lowered from USD 60 to USD 47.6 per barrel. A new automatic and dynamic adjustment mechanism has been introduced, ensuring the cap remains 15% below the average market price of crude oil over the previous six months.
With effect from 21 January 2026, an import ban applies to refined petroleum products made from Russian crude oil and coming from a third country. Such third countries include all non-EU member states, except Canada, Norway, Switzerland, The United Kingdom and The United States.
Furthermore, a full transaction ban is imposed on Nord Stream 1 and 2 which prevents completion, maintenance, operation and any future use of the Nord Stream 1 and 2 pipelines.
The previous exemption allowing Russian oil imports into Czechia has been revoked.
Shadow fleet
Targeting the shadow fleet value chain, 105 additional vessels will be subject to a port access ban and a ban on a broad range of services related to maritime transport. The total number of EU-listed vessels is now 444.
Also, the new sanctions package targets Russian and international companies managing shadow fleet vessels, traders of Russian crude oil as well as a customer of the shadow fleet with sanctions such as asset freezes, travel bans and bans on providing services. One company operating in the LNG sector has also been listed.
Banking sector
A full transaction ban against a total of 45 Russian banks has been imposed. This upgrades the existing prohibition on providing EU-based specialised financial messaging services that 23 banks were already subject to. As a result, no EU-operator is able to collaborate or transact with these 45 banks.
In addition, the threshold for sanctioning third-country financial and credit institutions and crypto-asset service providers has been lowered, as the EU has amended the conditions for the transaction ban targeting persons, entities or bodies connected to the System for Transfer of Financial Messages (SPFS).
Additionally, a ban is imposed on carrying out any transaction with the Russian Direct Investment Fund (RDIF) and its sub-funds and companies, and an instrument has been established to extend such a ban to certain companies in which the RDIF has invested and to entities providing investment services or other financial services to the RDIF itself. Such companies and financial institutions will be selected in due course.
Lastly, the EU has placed a new ban on selling, supplying, transferring and exporting certain software management systems and software used in the banking and financial sector, e.g. enterprise resource planning (ERP), customer relationship management (CRM), business intelligence (BI) and supply chain management (SCM) systems.
Export restrictions
The EU has expanded the export restrictions and bans to include additional advanced technologies, which might contribute to the technological enhancement of Russia's defence and security sector, e.g. chemicals for propellants.
In addition, a new requirement has been introduced with regards to advanced technology items (Annex VII items) where an authorization is required for exports to any third country other than Russia, if the exporter has been informed by the competent authority of the Member State where the exporter is resident or established that the items in question are or may be intended, in their entirety or in part, for any natural or legal person, entity or body in Russia, or for use in Russia. This provision has also been introduced with respect to Belarus.
Protection against arbitration proceedings
The EU has introduced measures to protect member states from illegitimate arbitration proceedings under Bilateral Investment Treaties launched by Russian companies and individuals. These measures include damage recovery provisions and non-recognition provisions in the EU for those arbitration proceedings.
Sanctions against Belarus
In addition to the above-mentioned sanctions, EU has imposed further restrictive measures on Belarus' trade. Also, the existing prohibition to provide specialised financial messaging services to certain Belarusian credit institutions and their Belarusian subsidiaries is expanded to a full transaction ban. Furthermore, an embargo on import of arms from Belarus is introduced. The above-mentioned protection against arbitration proceedings is also introduced against Belarus.
How Gorrissen Federspiel can assist
Gorrissen Federspiel closely follows the developments of export controls and sanctions, and we can assist with interpretation of and compliance with applicable sanctions as well as the implementation of measures to ensure that sanctions are observed. If you have any questions, please feel free to contact a member of our Compliance & Sustainability team.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel's newsletters of 21 May 2025, 25 February 2025, 19 December 2024, 25 June 2024, 27 February 2024, 19 December 2023, 26 June 2023, 27 February 2023, 19 December 2022, 7 October 2022, 8 June 2022, 11 April 2022, 16 March 2022, 10 March 2022, 2 March 2022, 28 February 2022, and 24 February 2022.
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.
