On 18 July 2025, the EU adopted the 18th package of sanctions (Council Regulations (EU) 2025/1494 and 2025/1472) aimed at further tightening existing economic sanctions against Russia and Belarus.

ENERGY SECTOR

• The EU intensifies efforts to reduce Russia’s energy revenues.
• 105 new vessels added to the list of banned ships, bringing the total to 444, including units from the Russian “shadow fleet.”
• Russian and international companies managing the shadow fleet sanctioned, including a major Indian refinery partly owned by Rosneft.
• For the first time, a Russian LNG vessel, a ship captain, and a private classification registry operator have been sanctioned.
• Ban on imports of refined oil products from Russian crude re-exported through third countries, except from Canada, Norway, Switzerland, the UK, and the US.
• Total transaction ban imposed on Nord Stream 1 and 2 pipelines.
• Oil import exemption for the Czech Republic is revoked.
• The price cap on Russian crude oil is lowered from $60 to $47.6 per barrel.

• Broader sanctions thresholds for financial institutions and crypto service providers in third countries that help evade sanctions or support the war.
• Transaction ban extended to the Russian Direct Investment Fund (RDIF), its holdings, and associated service providers.
• New export restrictions on management software and IT systems used in banking and finance.
• Total transaction bans with 22 additional Russian banks (effective from August 9, 2025), including:
  T-Bank, Yandex Bank, Bank Saint Petersburg, Bank Zenit, Ekspobank, Bank131, Bank DOM.RF, FINAM Bank, SME Bank, Ozon Bank, and others.

• Sanctions strengthened against military-industrial suppliers, including three Chinese companies.
• 26 new entities added to export restrictions, 11 of which are located in China, Hong Kong, and Turkey.
• Additional restrictions worth over €2.5 billion imposed on key components (e.g., CNC machines, chemical propellants).
• Extended ban on transit of strategic goods via Russia for construction and transport sectors.

• New rules protect Member States from unjustified arbitration claims launched by Russian entities under Bilateral Investment Treaties (BITs).
• Measures include non-recognition of such arbitrations and mandatory formal opposition by Member States.

To strengthen enforcement of sanctions, the EU has introduced an optional administrative mechanism through Decision (CFSP) 2025/1495, allowing national authorities to require prior authorization for exports of sensitive goods and technologies (Annex VII of Reg. 833/2014) to third countries, if there are suspicions they may ultimately be diverted to Russia.

This measure does not introduce new blanket bans, but rather offers a flexible tool to prevent circumvention, enabling Member States to apply this mechanism or rely on existing indirect export bans.

New Additions to Controlled Items List (Annex XXIII)

• 72 new customs codes added, significantly broadening the control scope by shifting from 6-digit to 4-digit and 2-digit codes.
• New annexes introduced: Annex XXIII Sexties (183 items) and Septies (8 items) with temporary exemptions:
  • Sexties: exemptions valid until 21 October 2025 for contracts signed before 20 July 2025.
  • Septies: exemptions valid until 21 January 2026 under the same conditions.

Annex VII

• New item added: X.C.VIII.005 – Chemical constituents for propellants.
NOTE: Annex VII items are not correlated with HS/TARIC codes.

Annex VII B

• New NC codes added: 845630, 845650.

Annex XXXVII

• Updated list of goods and technologies prohibited from transiting through Russian territory.

• 8 new Belarusian entities in the military sector added to the sanctions list.
• Trade restrictions strengthened to align with Russia sanctions.
• Extension of the ban on SWIFT-like financial messaging services and new arms embargo.

• [COUNCIL REGULATION (EU) 2025/1494 - Russia – 18 July 2025]
• [COUNCIL REGULATION (EU) 2025/1472 - Belarus – 18 July 2025]

• Review and update your Enhanced Due Diligence (EDD) procedures.
• Verify products, especially those listed in Annex VII and Annex XXIII.
• Apply increased due diligence for exports to countries bordering Russia or known as transshipment points.