New Sanctions Announced by EU and UK on the Third Anniversary of Russia’s Invasion of Ukraine

To mark the third anniversary of Russia’s invasion of Ukraine on 24 February 2025, the EU and the UK announced further sanctions packages against Russia. The EU also introduced new measures against Belarus and Crimea and Sevastopol and certain non-Government controlled areas of Ukraine, broadly mirroring the Russia sanctions measures. These sanctions follow a similar round of EU and UK sanctions that marked the second anniversary of Russia’s invasion, as discussed in a previous Insight available here.

EU Sanctions Package

On 24 February, the European Union announced in its press release that it has published its 16th package of sanctions against Russia, which entered into force on 25 February. The 16^th package targets sectors such as energy, trade, transport, infrastructure, and financial services. It also adds further measures aimed at tackling circumvention. The 16th package includes a wide range of measures including:

• Asset Freezes: The European Union listed an additional 48 individuals and 35 entities as being subject to an asset freeze. These listings have a focus on individuals and entities supporting the Russian military-industrial complex and that are active in sanctions circumvention (such as the cryptocurrency and maritime sectors).
• Expanded “best efforts” requirement: The European Union introduced a “best efforts” requirement as a new provision under Regulation (EU) No 269/2014, requiring EU entities to take steps to ensure entities they own or control do not participate in activities that undermine EU sanctions, namely, dealing with EU designated persons.
• Shadow Fleet: To further curtail sanctions circumvention, the European Union listed an additional 74 vessels in Russia’s ‘shadow fleet’ as subject to bans on port access and the provision of services related to maritime transport. This measure targets non-EU ships used by Russia to circumvent the oil price cap mechanism, support the Russian energy sector, or transport military equipment or stolen Ukrainian grain.
• New Listing Criteria: The 16th package added two new criteria allowing the European Union to target those who (i) support the operations of unsafe oil tankers; or (ii) support or benefit from the Russian military-industrial complex.
• Trade Measures: The European Union has implemented several additional trade measures against Russia:
  • Added 53 new entities to the list of those directly supporting Russia’s military-industrial complex, which means they will be subject to tighter export restrictions concerning dual use goods and technologies, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector. Only a third of the entities are Russian, the remainder are located in third countries (China, Hong Kong, India, Kazakhstan, Singapore Turkey, the United Arab Emirates, and Uzbekistan).
  • Expanded its list of restricted items that contribute to the technological enhancement of Russia’s defence and security sector to include chemical precursors to Chloropicrin and other riot control agents, software related to computer numerical control machines, chromium compounds and controllers used to guide Unmanned Aerial Vehicles (UAVs).
  • Introduced further restrictions on Russian industrial exports (namely, chemicals, certain plastics, and rubber) and increasing restrictions on the import of primary aluminum into the European Union from Russia.
• Broadcasting: The European Union suspended the broadcasting licenses for eight Russian media outlets, preventing them from broadcasting content within the European Union. However, this does not prevent the targeted media outlets from conducting activities in the European Union other than broadcasting, e.g., research and interviews.      
• Finance: The European Union has banned non-Russian financial institutions from transactions using the System for Transfer of Financial Messages (SPFS). SPFS is a specialized financial messaging service developed by the Central Bank of Russia to circumvent EU sanctions. The European Union also extended the prohibition on the provision of specialized financial messaging services to 13 regional banks in Russia.
• Transport: The European Union added further restrictions on the transport sector including:
  • Prohibition on any transaction with certain listed ports, locks, and airports in Russia used for the transfer of UAVs and missile components to Russia or by the Russian shadow fleet.
  • Widening the EU flight ban to listed air carriers operating domestic flights within Russia or exporting aircraft or other aviation parts to Russian air carriers.
  • Prohibition on existing road transport undertakings in the European Union from making any changes to their capital structure that would increase the percentage share owned by a Russian natural or legal person to over 25%.
• Energy: The European Union has added further measures targeted against the Russian energy sector, including restrictions on software used for oil and gas exploration, a prohibition on providing goods, technology, or services for the completion of crude oil projects in Russia, and a ban on providing temporary storage of Russian crude oil and petroleum products within the European Union.
• Diligence on Re-exportation: To counter the re-exportation of sanctioned goods to Russia, EU exporters selling sensitive goods to third countries, other than partner countries, are required to implement due diligence mechanisms, capable of identifying, assessing, and mitigating the risks of such re-exportation to Russia.

In addition to the above measures directly related to Russia, the European Union has expanded its professional services ban currently in place against Russia to also cover Crimea and the non-government-controlled areas of the Ukrainian oblasts of Donetsk, Kherson, Luhansk, and Zaporizhzhia. This prohibits the provision of certain software and 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 to these regions of Ukraine.

The 16th sanctions package further includes various restrictive measures on Belarus mirroring the trade-related sanctions imposed against Russia, as well as restrictions concerning the sale or provision of services and software, deposits and crypto-asset wallets, and transport. The European Union also introduced a new listing criterion targeting persons or entities supporting or benefiting the Belarusian military-industrial complex.

UK Sanctions Package

Also on 24 February, the United Kingdom Foreign, Commonwealth & Development Office (FCDO) announced its largest sanctions package against Russia since 2022. The FCDO announced that, for the first time, it is using its new powers to target foreign financial institutions that are supporting the Russian military-industrial complex, with sanctions against the Kyrgyzstan-based OJSC Keremet Bank. In total, 107 new sanctions targets were listed by the FCDO covering a broad range of sectors. In addition to targeting  Keremet Bank, measures include new sanctions against the following:

• Twenty-two international enablers and suppliers to the Russian defence sector, mostly producers and suppliers of machine tools, electronics, and dual-use goods used by the Russian military. These individuals and entities are located in various third countries, including Central Asian states, Turkey, Thailand, India, and China.
• North Korean Defence Minister No Kwang Chol and other North Korean generals and senior officials instrumental in the deployment of 11,000 North Korean soldiers to Russia to fight in Ukraine.
• Thirteen Russian targets linked to the Russian defense sector, including LLC Grant-Trade, which has funneled advanced European technology into Russia, and its owner, Marat Mustafaev, and his sister, Dinara Mustafaeva.
• A further 40 “shadow fleet” of tankers carrying Russian oil. This brings the total number of oil tankers targeted by the United Kingdom to 133.
• Sanctions against 25 Russian individuals and entities involved in sectors of strategic significance to the Russian economy. This includes S7 Airlines, the largest private airline in Russia, and its owner, Vladislav Filev, and Roman Trotsenko, one of the wealthiest men in Russia, worth £2.2 billion.

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