The EU’s 16th Sanctions Package and new UK sanctions – Heavy impact on trade and aviation?!

EU sanctions remain at the core of the EU’s response to Russia’s military aggression against Ukraine. Three years into the war, the Council has adopted what it calls the 16th Russia sanctions package. Here are some of its key elements.

Shipping and trade

The 16th sanctions package presents further measures to prevent circumvention. The so-called shadow fleet – which includes ships that have been proven to be involved in the transportation of Russian crude oil or Russian crude oil products, arms deliveries, grain theft or support for the Russian energy sector – remains one focal point. The 16th package targets 74 additional vessels, bringing the total number of listed vessels to 153. They are subject to a ban on access to EU ports and services.

A novelty is the full transaction ban on specific Russian infrastructures. As per Council Decision (CFSP) 2025/394 of 24 February 2025 it

“shall be prohibited to engage in any transaction, directly or indirectly, with ports and locks listed in Part A of Annex XXI” and “airports listed in Part B of Annex XXI”.

This affects the following:

In addition to the prohibition for imports of processed aluminium goods from Russia, already in place, the 16th package includes a ban on EU imports of primary aluminium from Russia. This follows similar UK restrictions on primary aluminium that were introduced in December 2023.

The EU has also decided to completely prohibit temporary storage or the placement under free zone procedures of Russian crude oil or petroleum products in EU ports, which was until now allowed, if the oil complied with the price cap and went to a third country. 

The 16th package also extends the prohibition to provide goods, technology and services for the completion of Russian LNG projects to also apply to crude oil projects in Russia, such as the Vostok oil project. 

Aviation

As per Council Decision (CFSP) 2025/394 of 24 February 2025 it

“shall be prohibited for air carriers operating domestic flights within Russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft, or any of the goods or technology referred to in Article 4d (1) to a Russian air carrier or for flights within Russia, as listed in Annex XX, as well as for any entity owned or controlled by such air carrier, to land in, take off from or overfly the territory of the Union.”

The intention is to enable the extension of flight bans to third-country carriers conducting domestic flights within Russia or supplying aviation goods to Russian airlines or for domestic flight in Russia. 

Extension of the sanctions list

The 16th sanctions package also includes 83 additional listings, including 48 individuals and 35 entities, such as those supporting the Russian military complex, active in sanctions circumvention, Russian crypto assets exchanges and in the maritime sector. For trade to and from Germany, the recognisable trend of including additional actors from China in the list remains particularly noteworthy.

New UK sanctions

On Monday 24 February, the UK also made similar designations to mark the third anniversary of the war in Ukraine. These include asset freezes against 34 individuals and 33 entities, along with specifying an additional 40 shadow fleet vessels.

Of note is the increasing number of third country entities that have been targeted for their role in assisting Russia’s military. Producers and suppliers of critical goods from China, Hong Kong, Turkiye, Thailand and India have been designated. The UK has also for the first time designated a third country financial institution, OJSC Keremet Bank of Kyrgyzstan, for its involvement in Russia’s financial sector. This entity is now subject to an asset freeze as well as correspondent banking restrictions.

Finally, while many shadow fleet vessels have been sanctioned by both the UK and EU in line with their common aim of reducing Russia’s oil revenues, there remain a number of vessels that are sanctioned by only one of the UK or EU. Businesses should carefully consider their sanctions compliance procedures, especially where UK and EU jurisdiction is engaged.