Three years after Russia’s full-scale invasion of Ukraine, EU Member States agree to a “phased in” ban on imports of Russian aluminium products and a tightening of existing measures on crude oil.
Shutterstock.com/Rokas Tenys
The EU issued fresh sanctions against Russia today, marking three years since Russia invaded Ukraine.
Welcoming in the EU’s 16th sanctions package, European Commission president Ursula von der Leyen said that the bloc is committed to keeping pressure on the Kremlin and is “clamping down even harder on [sanction] circumvention.”
EU Member States adopted the latest package amid growing fears that transatlantic peace talks will not materialise as tensions brew between Ukraine and the US.
On 18 February 2025, US and Russian officials met in Saudi Arabia to discuss ending the war in Ukraine. European and Ukrainian leaders were not asked to join the discussions. The UK government has warned there can be “no durable peace” without European nations - particularly Ukraine - playing a role in talks to end the war.
“With talks underway to end Russia’s aggression, we must put Ukraine in the strongest possible position. Sanctions provide leverage,” highlighted Kaja Kallas, the EU High Representative for Foreign Affairs and Security Policy.
Lexology PRO examines the new EU restrictive measures on Russian entities and individuals as well as the considerations for EU businesses.
To help companies stay up-to-date and ensure they are compliant, this Lexology PRO timeline outlines the crucial sanctions imposed against Russia by key jurisdictions so far in 2025, along with countersanctions, and an analysis of the most recent updates.
Shadow fleet, ports, aluminium, banks in the firing line
Today’s package details the EU’s ban on Russian aluminium, which will take effect in one year. During the “transitional period,” the EU can import a limited volume of 275,000 tonnes of aluminium. By the end of 2026, no Russian aluminium can be imported into the EU.
The EU’s previous sanctions package – adopted on 16 December 2024 – targeted Russia’s shadow fleet and aimed at weakening the country’s military and industrial complex. Today’s package similarly takes aim at 74 shadow fleet tankers, which Russia uses to bypass the G7-backed price cap to sell oil above the sanctioned limits. The EU has now designated a total of 153 tankers.
For the first time, the EU has imposed a transaction ban on credit or financial institutions established outside Russia that use the ‘system for transfer of financial messages,’ a specialised financial messaging service developed by Russia’s Central Bank. The EU has also rescinded access to SWIFT – a messaging network for banks and financial institutions (FIs) – for 13 regional banks.
The EU has also placed restrictions on any transaction involving certain ports and airports in Russia that the EU considers are used to help Russia circumvent the oil price cap and transfer military-grade weapons and technology. These include two Moscow airports and sea ports on the Baltic, Black, and Caspian seas.
Further transport restrictions include the EU widening its flight ban to air carriers operating domestic flights within Russia. The EU can list third-country airlines operating domestic flights within Russia or supplying aviation goods to Russian airlines. If listed, these companies would face a ban on flying to the EU.
Video game consoles – which the EU believes can be repurposed as controllers for drones – now face restrictions on sales to Russia, impacting companies such as Microsoft, Sony, and Nintendo.
Eight Russian media outlets are also in the firing line, with the EU prohibiting them from broadcasting their content.
48 Russian officials join an already long list of sanctioned high-ranking individuals, such as President Vladimir Putin. A further 35 entities are also now subject to EU sanctions. These individuals and entities face travel bans and asset freezes in the EU.
One notable absent from the list of new measures is Russian liquefied natural gas (LNG). On 13 January 2025 10 EU countries – Czech Republic, Denmark, Estonia, Finland, Ireland, Latvia, Lithuania, Poland, Romania and Sweden – called for sanctions on Russian LNG. The EU has not yet sanctioned Russian LNG as Brussels looks to secure a deal to buy from US LNG before cutting off its existing supplier.
Key considerations for EU businesses
After three years of the war in Ukraine and multiple sanctions packages from the EU and individual Member States, in-house legal and compliance teams in the EU have had to constantly evolve and update compliance programmes to fit the changing regimes.
Companies should stay informed of changes and be ready to adjust programmes to fit new packages.
To stay up to date and compliant with new sanctions, companies should identify their overlapping or conflict sanctions obligations. In-house legal and compliance team should have a thorough understanding of the sanctions regimes to which it might be subject and ensure that employees working with international clients are aware of the differences in what conduct is prohibited.
With new restrictions on Russian airports and ports, EU companies should examine their supply chains and adjust shipping routes to avoid using this sanctioned infrastructure. Similarly, businesses using Russian aluminium should start to identify and conduct due diligence on new suppliers ahead of the ban taking effect next year.
Businesses should adopt screening software to spot changes to the EU’s list of persons, groups, and entities subject to financial sanctions. This technology will prevent companies from working with sanctioned, designated, or blocked entities.
Companies must also understand the risk of breaching EU sanctions. Member States must transpose the EU Directive defining criminal offences and penalties for the violation of restrictive measures by 20 May 2025. Under these rules, prosecutors can hold companies criminally or non-criminally liable for non-compliance with the sanctions regime, with maximum fines of at least 5% of the worldwide turnover or €40 million (US$42 million).