16th package of EU sanctions: EU reaction to Russian invasion of Ukraine (regularly updated)

Since the Russian invasion of Ukraine in February and March 2014 and the subsequent annexation of Crimea and Sevastopol to the Russian Federation (Russia) on 16 March 2014, declared illegal also by the UN General Assembly (UNGA/11493, 27 March 2014), the EU has adopted, under articles 29 of the TEU and 215 of the TFEU, a series of restrictive measures against persons and entities for their role in actions threatening the territorial integrity, sovereignty and independence of Ukraine[1].

Following Russia’s recognition of the Luhansk and Donetsk People’s Republics’ independence on 21 February 2022 and its further invasion of Ukraine on 24 February 2022, the EU adopted a first package of sanctions.

In view of the gravity of the situation, and in response to Russia’s continued military aggression against Ukraine, the EU has adopted a series of new restrictive measures.

More than three years after Russia’s invasion and war of aggression against Ukraine, on February 24, 2025, the EU adopted its 16th package of sanctions against Russia and mirroring measures against Belarus.

The following are among the main measures implemented to crack down on Russia’s shadow fleet, fight against sanctions circumvention and disinformation, and tighten restrictions on exports, imports, transit and services, and tackle financial loopholes:

16^th package of sanctions

Council Decision (CFSP) 2025/388 of 24 February 2025 amending Decision 2014/145/CFSP, Council Regulation (EU) 2025/390 of 24 February 2025 amending Regulation (EU) No 269/2014, and Council Implementing Regulation (EU) 2025/389 of 24 February 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine:[2]

• Addition of 48 persons and 35 entities to the list of persons/entities subject to restrictive measures (asset freezes and travel bans) set out in Annex I to Regulation (EU) No 269/2014 for supporting the Russian military complex, circumventing sanctions, trading in Russian crypto-assets and the maritime sector;
• Two additional listing criteria applying to:
  • Persons, entities or bodies owning, controlling, managing or operating vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing irregular and high-risk shipping practices (e.g., operating with inadequate or inexistent insurance) or that otherwise provide material, technical or financial support to the operations of such vessels (Putin’s shadow fleet).
  • Persons, entities or bodies forming part of, supporting, materially or financially, or benefitting from Russia’s military and industrial complex.
• From May 2025,[3] obligation for “obliged entities” referred to in Article 2(1) of Directive (EU) 2015/849 (such as credit and financial institutions, auditors, estate agents) to report to Financial Intelligence Units (FIUs) all suspicious transactions related to suspected criminal activity linked to the violation of Union restrictive measures pursuant to Directive (EU) 2024/1226 and article 33 of Directive (EU) 2015/849.
• Introduction of a forum necessitatis clause to remedy possible situations of denial of justice allowing a court of a Member State, on an exceptional basis, to rule on a claim for damages brought pursuant to Article 11a of Regulation (EU) No 269/2014[4] where Union law or the law of a Member State does not establish the jurisdiction of a court of any Member State in particular (provided that the case has a sufficient connection with the Member State of the court seised).
• EU operators are required to undertake their best efforts to ensure that legal persons, entities and bodies established outside the Union that they own or control do not participate in activities that undermine the restrictive measures provided for in Regulation (EU) No 269/2014.
  • Best efforts can include the implementation of appropriate policies, controls and procedures to mitigate and manage risk effectively, considering factors such as the third country of establishment, the business sector and the type of activity of the legal person, entity or body that is owned or controlled by the Union operator, while being feasible for the Union operator in view of its nature, its size and the relevant factual circumstances, in particular the degree of effective control over the legal person, entity or body established outside the Union.

Council Decision (CFSP) 2025/394 of 24 February 2025 amending Decision 2014/512/CFSP, and Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine:[5]

• Suspension of the EU broadcasting licences of the following eight Russian media outlets under the permanent control of the Russian leadership, and the prohibition on broadcasting their content:
  • ‘EADaily / Eurasia Daily
  • Fondsk
  • Lenta
  • NewsFront
  • RuBaltic
  • SouthFront
  • Strategic Culture Foundation
  • Krasnaya Zvezda / Tvzvezda
• Introduction of a forum necessitatis clause to remedy possible situations of denial of justice allowing a court of a Member State, on an exceptional basis, to rule on a claim for damages brought pursuant to to Articles 11a and 11b of Regulation (EU) No 833/2014, where Union law or the law of a Member State does not establish the jurisdiction of a court of any Member State in particular (provided that the case has a sufficient connection with the Member State of the court seised).

Trade-related measures:

• Addition of 53 new entities to the list, set out in Annex IV to Decision 2014/512/CFSP, of those directly supporting Russia’s military and industrial complex on which tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector, are imposed
  • Two thirds of these entities are located in third countries other than Russia (namely: China including Hong Kong, India, Kazakhstan, Singapore Türkiye, the United Arab Emirates and Uzbekistan) and indirectly contributed to Russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles (UAVs) or missiles.
• Addition of 74 vessels to the list, set out in Annex XVI to Decision 2014/512/CFSP, of those subject to a port access ban and ban on provision of a broad range of services related to maritime transport (bringing the total of Putin’s shadow fleet to 153 vessels).
• Expanded list of advanced technology itemsthat may contribute to Russia’s military and technological enhancement or to the development of its defence and security sector (Annex VII to Regulation 833/2014) by adding:
  • Chemical precursors to produce chloropicrin and other riot control agents used as chemical weapons by Russia in violation of the Chemical Weapons Convention.
  • Software related to Computer Numerical Control (CNC) machine tools used to manufacture weapons, and video-game controllers used by the Russian army to pilot drones on the battlefield.
  • Chromium ores and compounds due to their military applications.
• Further restrictions on exports of goods which contribute to the enhancement of Russian industrial capabilities, such as chemicals, some plastics and rubber (Annex XXIII to Regulation 833/2014), as well as their transit through Russia.
• Further restrictions on the import of primary aluminium, which generates significant revenues for Russia, in addition to the current import ban on processed aluminum goods from Russia.
• EU operators exporting to third countries–other than the partner countries listed in Annex VIII to Regulation (EU) No 833/2014 as applying a set of export control measures substantially equivalent to those of Regulation (EU) No 833/2014– are required to implement due diligence mechanisms (capable of identifying, assessing and mitigating the risks of re-exportation to Russia), as well as to ensure that legal persons, entities or bodies established outside of the Union and over whose conduct they can exercise decisive influence implement such mechanisms to prevent them from undermining EU restrictive measures.

Transport-related measures:

• Extended flight ban to listed air carriers operating domestic flights within Russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to Russian air carriers and their controlled entities.
• Tightening of the existing ban on the transport of goods by road within the territory of the EU, including in transit, by EU operators owned for 25% or more by a Russian natural or legal person.

Energy-related measures:

• Further restriction on exports of goods and technology, in particular software related to oil and gas exploration, in order to further restrict Russia’s oil and gas exploration and production capacities.
• Prohibition on the provision of temporary storage for Russian crude oil and petroleum products within the Union, irrespective of the purchase price of the oil and of the final destination of those products.
• Extended prohibition to provide goods, technology and services for the completion of crude oil projects in Russia (such as the Vostok oil one), in addition to the completion of LNG projects already in place (without prejudice to the temporary derogations granted to certain landlocked Member States for the purchase and import of Russian crude oil).

Infrastructure-related measures:

• Ban on construction services provided by EU operators in Russia (as already in place in illegally occupied parts of Ukraine), except for services strictly necessary for the functioning of a Russian consular or diplomatic representation located in a Member State.
• Prohibition on any transaction with the following ports and locks and airportsin Russia that are used for the transfer of UAVs, missiles and related technology and components to Russia, or for the circumvention of the Oil Price Cap by vessels practicing irregular and high-risk shipping practices or of other restrictive measures:
  • Moscow’s two airports Vnukovo and Zhukovsky, and four regional airports (Begishevo, Perm, Koltsovo, and Pskov Airport);
  • The Volga port Astrakhan and Makhachkala port on the Caspian Sea;
  • The sea ports Ust-Luga and Primorsk on the Baltic Sea and Novorossiysk on the Black Sea.

Financial measures:

• From May 2025, obligation for “obliged entities” referred to in Article 2(1) of Directive (EU) 2015/849 (such as credit and financial institutions, auditors, estate agents) to report to Financial Intelligence Units (FIUs) all suspicious transactions related to suspected criminal activity linked to the violation of Union restrictive measures pursuant to Directive (EU) 2024/1226 and article 33 of Directive (EU) 2015/849.
• Transaction ban on credit or financial institutions established outside Russia using the ‘System for Transfer of Financial Messages’ (SPFS) of the Central Bank of Russia to circumvent EU sanctions.
• Extended prohibition on the provision of specialised financial messaging services to 13 Russian regional banks facilitating significant cross-border payments.
• Further extension of the transaction ban on credit and financial institutions and entities providing crypto assets services that support transactions related to any listed vessel, so facilitating the circumvention of EU restrictive measures.

Council Decision (CFSP) 2025/396 of 24 February 2025 amending Decision (CFSP) 2022/266 and Council Regulation (EU) 2025/398 of 24 February 2025 amending Regulation (EU) 2022/263 concerning restrictive measures in response to the illegal recognition, occupation or annexation by the Russian Federation of certain non-government controlled areas of Ukraine; and Council Decision (CFSP) 2025/397 of 24 February 2025 amending Decision 2014/386/CFSP and Council Regulation (EU) 2025/401 of 24 February 2025 amending Regulation (EU) No 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol:[6]

• New restrictions on the provision to the “non-government controlled areas” (i.e., the oblasts of Donetsk, Kherson, Luhansk and Zaporizhzhia illegally occupied by Russia) of accounting, auditing, bookkeeping, tax consulting, business and management consulting, public relations, construction, architectural, engineering, legal advisory, IT consultancy, market research and public opinion polling, technical testing and analysis and advertising services, with the objective of inhibiting their integration into the Russian Federation, and preventing circumvention of EU sanctions.
• Prohibition on providing the non-government controlled areas with certain software for the management of enterprises and software for industrial design and manufacture, and of related intellectual property rights or trade secrets.
• Prohibition on supplying the non-government controlled areas with banknotes denominated in any official currency of a Member State.
• Restrictions on the export to the non-government controlled areas of certain goods and technology that are also restricted by Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014.

In response to Belarus’s involvement in Russia’s unprovoked invasion against Ukraine, the EU has introduced the following new measures.

8th package of sanctions

Council Decision (CFSP) 2025/391 of 24 February 2025 amending Decision 2012/642/CFSP, and Council Regulation (EU) 2025/392 of 24 February 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine:[7]

• New listing criterion applying to persons, entities or bodies supporting or benefiting from the military and industrial complex of Belarus.
• Restrictions concerning the sale or provision of services and software, deposits and crypto-asset wallets, and transports.
• Restrictive measures mirroring those adopted against Russia in the 16^th package of sanctions in relation to trade, transport, energy, construction and finance sectors under Council Decision (CFSP) 2025/394 of 24 February 2025 amending Decision 2014/512/CFSP and Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.

Council Decision (CFSP) 2025/391 of 24 February 2025 amending Decision 2012/642/CFSP, and Council Regulation (EU) 2025/392 of 24 February 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine:[8]

• The restrictive measures set out in Council Decision 2012/642/CFSP are prolonged until 28 February 2026.

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[1] Council Decision 2014/145/CFSP of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 16–21; and Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 6–15;

Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine OJ L229, 31.7.2014, p. 13–17; and Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 229, 31.7.2014, p. 1–11.

[2] Council Decision (CFSP) 2025/388 of 24 February 2025 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2025/388, 24.2.2025;

Council Regulation (EU) 2025/390 of 24 February 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2025/390, 24.2.2025; and

Council Implementing Regulation (EU) 2025/389 of 24 February 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2025/389, 24.2.2025.

[3] End of the transposition period of Directive (EU) 2024/1226 of the European Parliament and of the Council of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673 by its article 20.

[4] Namely, contract or transaction the performance of which has been affected, directly or indirectly, in whole or in part, by the measures imposed under Regulation (EU) No 269/2014.

[5] Council Decision (CFSP) 2025/394 of 24 February 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L, 2025/394, 24.2.2025; and Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L, 2025/395, 24.2.2025.

[6] Council Decision (CFSP) 2025/396 of 24 February 2025 amending Decision (CFSP) 2022/266 concerning restrictive measures in response to the illegal recognition, occupation or annexation by the Russian Federation of certain non-government controlled areas of Ukraine, OJ L, 2025/396, 24.2.2025;

Council Regulation (EU) 2025/398 of 24 February 2025 amending Regulation (EU) 2022/263 concerning restrictive measures in response to the illegal recognition, occupation or annexation by the Russian Federation of certain non-government controlled areas of Ukraine, OJ L, 2025/398, 24.2.2025;

Council Decision (CFSP) 2025/397 of 24 February 2025 amending Decision 2014/386/CFSP concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol, OJ L, 2025/397, 24.2.2025; and Council Regulation (EU) 2025/401 of 24 February 2025 amending Regulation (EU) No 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol, OJ L, 2025/401, 24.2.2025.

[7] Council Decision (CFSP) 2025/391 of 24 February 2025 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2025/391, 24.2.2025; and

Council Regulation (EU) 2025/392 of 24 February 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2025/392, 24.2.2025.

[8] Council Decision (CFSP) 2025/391 of 24 February 2025 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2025/391, 24.2.2025; and

Council Regulation (EU) 2025/392 of 24 February 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2025/392, 24.2.2025.