On February 24 2025, marking the third anniversary of Russia’s illegal invasion of Ukraine, the European Union adopted its 16th sanctions package against Russia. This comprehensive set of measures aims to further pressure the Russian regime by targeting critical sectors of its economy and addressing sanction circumvention tactics.

These measures are contained in (i) EU Council Regulation 2025/395 which amends (ii) EU Council Regulation 833/2014

Import and Export Restrictions

• Ban on Primary Aluminium Imports: A phased ban on Russian primary aluminium imports has been introduced, with a limited volume permitted during the first year. This measure aims to reduce revenue streams critical to Russia’s economy.

This ban will be phased in over a 12-month transition period, during which imports are limited to a quota of 275,000 tons, equating to 80% of EU imports in 2024. Therefore, the full ban on primary aluminium imports from Russia will commence on February 24, 2026

• Export Bans: The EU has expanded its list of export bans to include items such as video game consoles, joysticks, and flight simulators, which could potentially be repurposed for military use, notably in drone operations.

Financial Sector Measures

• SPFS Transaction Ban: The EU has imposed a transaction ban on foreign financial institutions utilizing Russia’s financial messaging system, SPFS, to further isolate Russia’s financial network.
• SWIFT Restrictions: Thirteen additional Russian banks and three financial institutions have been disconnected from the SWIFT international payment system, intensifying financial isolation.

Shadow Fleet Crackdown

The EU has sanctioned an additional 73 vessels, primarily oil tankers suspected of circumventing existing sanctions and oil price caps, bringing the total number of restricted vessels to over 120.

Individual and Entity Sanctions

The EU has sanctioned an additional 48 individuals and 35 entities, implementing asset freezes and travel bans to further pressure those supporting Russia’s military aggression.

Transportation and Commodity Sanctions

Port and Airport Restrictions: One of the most notable changes under Article 5ae of the EU 16th Package is the imposition of a full transaction ban on five Russian ports:

• Astrakhan – Used for the transfer of UAVs or missiles.
• Makhachkala – Used for the transfer of UAVs or missiles.
• Ust-Luga – Used for the maritime transport of crude oil or petroleum products, employing irregular and high-risk shipping practices.
• Primorsk – Used for the maritime transport of crude oil or petroleum products, employing irregular and high-risk shipping practices.
• Novorossiysk – Used for the maritime transport of crude oil or petroleum products, employing irregular and high-risk shipping practices.

Additionally, two Moscow airports (Vnukovo and Zhukovsky) and four regional airports are also subject to the full transaction ban.

Article 5ae of Council Regulation (EU) 2025/395 introduces comprehensive prohibitions on transactions with specific Russian ports, locks, and airports, aiming to curtail activities that support Russia’s military operations or facilitate sanctions evasion. Here’s a detailed breakdown of the prohibitions and their exceptions:​

A list of the Russian ports, locks, and airports can be found in Annex XLVII. This includes a broad range of interactions, extending beyond direct dealings with port or airport authorities. The listed infrastructures are believed to be involved in:​

• Transferring unmanned aerial vehicles (UAVs), missiles, related technologies, or components supporting Russia’s aggression against Ukraine.​
• Transporting goods and technology used in Russia’s defence and security sectors or in warfare against Ukraine.​
• Maritime transport of crude oil or petroleum products originating in Russia, especially when using vessels practicing irregular and high-risk shipping practices as defined by the International Maritime Organization.​
• Transporting goods that enable Russia’s destabilizing actions in Ukraine.​
• Facilitating the violation or circumvention of EU regulations concerning restrictive measures against Russia.​

Exemptions

While a full port transaction ban applies to the named Russian ports, there are six key exemptions under Article 5ae(3) of Council Regulation (EU) No 833/2014:

1. Taking refuge at said port/preservation of life.
2. Transactions strictly necessary for the purchase/import/transport of specific commodities, including natural gas, titanium, aluminium, copper, nickel, palladium, and iron ore from Russia to the EU, Switzerland, or the Western Balkans.
3. Transactions related to oil trade, unless prohibited under Articles 3m and 3n.
4. Transactions necessary for the purchase, import, or transport of pharmaceutical, medical, agricultural, and food products, including wheat and fertilizers.
5. Transactions involving seaborne crude oil and petroleum products of non-Russian origin, transiting through Russia.
6. Transactions for civil nuclear capabilities.

Importantly, coal cargoes are not included within the exemptions, and in this respect further clarifications are awaited. 

Reporting Requirement for Exempted Transactions

Operators relying on an exemption under Article 5ae(3) must report the transaction to the competent authority of the Member State where they are incorporated within two weeks of its conclusion. It remains unclear whether this requirement applies to non-EU operators; however, based on current wording, it appears to be an obligation on EU operators and companies.

Implications for the Shipping Industry

The inclusion of additional ports and vessels in the sanctions list underscores the EU’s commitment to enforcing measures and preventing circumvention. We must all exercise heightened due diligence to ensure compliance, as violations could result in severe legal and financial repercussions.

The EU’s 16th sanctions package represents a robust response to ongoing Russian aggression, targeting key economic sectors and addressing previous loopholes. Stakeholders are encouraged to review these new measures carefully and implement necessary compliance strategies. We await the consolidated Regulation from the EU to assess the full extent of prohibitions and applicable exceptions.

The International Group have issued a circular on the subject; Circular 2725/2025

Further information:

EU Council Press Release

Q&As on the 16th Package