18th EU SANCTIONS PACKAGE

18th EU SANCTIONS PACKAGE

Sanctions adopted following Russia’s military aggression against Ukraine. 

The European Union (EU) continues to adopt further packages of economic sanctions against Russia due to the continuance of its military aggression against Ukraine, the latest of which is summarised below. The relevant legal framework is EU Regulation 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (“Regulation 269”) and EU Regulation 833/2014 concerning restrictive measures in view of Russia's actions destabilising the situation in Ukraine (“Regulation 833”) (hereinafter collectively referred to as the “EU Sanctions”).

Note: The position is constantly evolving. Additional sanctions may be introduced in the coming days and these will be the subject of future articles. 

This information is:

• of a general nature only and is not intended to address the specific circumstances of any particular individual or entity;

• not necessarily comprehensive, complete, or up to date;

• not professional or legal advice (if you need specific advice, you may consult us).

18th SANCTIONS PACKAGE

A new sanctions package, one of the strongest packages (the 18th package) was adopted on 18th of July 2025 by the European Union in response to Russia’s ongoing war against Ukraine, through Council Regulation (EU) 2025/1494 of 18 July 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine and through Council Regulation (EU) 2025/1476 of 18 July 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.

The 18^th package aims to weaken Russia’s war capabilities and includes measures targeting the energy, banking, and military sectors, as well as individual listings and trade restrictions.

Key Components:

• Energy

• Oil price cap lowered from $60 to $47.6 per barrel.

• 105 additional vessels have been added to sanctions for being part of Russia’s shadow fleet.

• Ban on Russian oil products has been refined in third countries (except select allies).

• Full transaction ban on Nord Stream 1 & 2 pipelines has been implemented.

• Czechia’s exemption for Russian oil imports has been removed.

• Banking

• 22 more Russian banks subject to a full transaction ban.

The EU is upgrading the existing prohibition on providing EU-based specialised financial messaging services to certain Russian banks to a full transaction ban. This will apply to 22 additional Russian banks, on top of the 23 banks already subject to the ban.

The EU is lowering the threshold for sanctioning third-country financial and credit institutions and crypto-asset service providers that are frustrating sanction measures against Russia, supporting Russia’s war of aggression or are connected to the System for Transfer of Financial Messages (SPFS), the Russian alternative financial messaging service, developed by the Central Bank of Russia and used to shield Russian banks from the impact of EU sanctions.

The EU is also expanding the transaction ban on third countries’ financial and credit institutions and crypto-asset service providers which, through their actions, frustrate EU sanctions or support Russia’s war of aggression against Ukraine. The transaction ban on third-country operators that circumvent oil-related prohibitions has also been widened.

Additionally, a ban is imposed on carrying out any transaction with the Russian Direct Investment Fund (RDIF) and its sub-funds and companies, and EU Council has established an instrument to extend such a ban to certain companies in which the RDIF has invested and to entities providing investment services or other financial services to the RDIF itself. Such companies and financial institutions will be selected by the Council; four Russian entities in which the RDIF has invested are already listed. This measure further limits Russia’s access to global financial markets and foreign currency.

Lastly, the Council is setting in place a new ban on selling, supplying, transferring and exporting software management systems and software with certain uses in the banking and financial sector.

We note that through this new sanction package, paragraph 2 of Article 5ac of the EU regulation 833/2014 has been replaced as follows:

It shall be prohibited to engage, directly or indirectly, in any transaction with a legal person, entity or body established outside Russia as listed in Annex XLIV. Annex XLIV shall include the legal persons, entities or bodies established outside Russia that use the SPFS of the Central Bank of Russia or equivalent specialised financial messaging services set up by the Central Bank of Russia or the Russian State.’

Annex XLIV of EU regulation 833/2014 still includes the banks included as of May 2025 and the names of the new banks have not been included yet in the Annex.

• Military Industry

• Sanctions have been imposed on 26 entities, including 11 outside Russia (in China, Hong Kong, Turkey), which have been involved in dual-use tech and UAVs.

• Export bans worth over €2.5 billion have been also imposed, including tech used in Russian weapons production.

• Sanctions have been additionally imposed on companies in Belarus supporting Russia's war efforts.

• Accountability

• EU imposed sanctions on individuals involved in the deportation and indoctrination of Ukrainian children, bringing the total to over 90.

• Additional listings include Russian proxies, a businessperson, and a propagandist in occupied Ukrainian territories.

• Belarus

• Trade and military sanctions on Belarus now closely mirror those in Russia.

• Full transaction ban on financial messaging and a weapons import embargo have been imposed by EU.

• Legal Protections

• EU adopts new measures with purpose to shield member states from illegitimate Bilateral Investment Treaty (BIT) arbitration proceedings launched by Russian companies and individuals.

Next Steps

MPC Legal monitors developments within the EU closely and expects that additional rounds of sanctions may be imposed as events unfold.