The European Union is expected to roll out its 16th package of restrictive measures against Russia, coinciding with the third anniversary of the Russia-Ukraine conflict. While Russia is by far the most sanctioned nation, the EU is not short of ideas of what can be included in the next sanctions package.
Details of the new sanctions package
It has been reported that the EU is looking to ban import of Russian aluminium, although some exceptions will apply during the transitional period. The EU is also planning to restrict sales of video game consoles and accessories, as they are believed to be used for operating military equipment, such as drones.
Further measures are proposed to tackle sanctions circumvention, including a so- called ‘transaction ban’, with the aim of targeting entry/exit points in Russia that are allegedly being used for transporting military equipment and circumventing the G7 oil price cap. These measures will include restrictions on access to facilities and provision of services to vessels and aircraft. Additionally, a new ban on the export of software used in oil exploration will be introduced.
The EU is going to sanction around 50 people and companies, including some Russian regional banks, along with scores of oil tankers from the Russian ‘shadow fleet’. Proposals to ban Russian LNG have been excluded from this package.
EU officials are looking to exert further pressure on Russia by shifting their efforts to tackle sanctions evasion and circumvention via third countries, such as China. In fact, it has now emerged that the EU is looking to introduce sanctions against at least 25 Chinese companies for their role in helping Russia to source components and materials that can be used in weapons production for its war in Ukraine.
Implications for businesses
The 16th sanctions package will inevitably impose further obligations on businesses, as it may require them to enhance their compliance and/or adjust their business models. As the EU introduces new and extensive sanctions packages, identifying further risks may become problematic and require additional training of staff. The overlapping of various sanctions regimes poses an additional challenge to those engaged in the international trade of sensitive items. Violation of sanctions regimes may result in civil or criminal liability, large fines and reputational damage. Companies are advised to review their current sanctions and wider compliance policies and update their existing systems and training programmes.
Updated: 18 February 2025
How Gherson can assist
Gherson Solicitors LLP has a European office located in Brussels and, with its EU counsel, can advise on EU sanctions challenges, as well as compliance with EU sanctions law. In addition, our UK office can assist with various UK sanctions matters.
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