EU-Russia Sanctions – Update July 2025: EU Adopts 18th Sanctions Package

(Supplement to our Insight of 18 June 2025)

On 18 July 2025, the Council of the European Union adopted the 18th sanctions package against Russia. The aim is to further weaken the economic foundations of the Russian warfare – especially through new measures in the energy, financial, and technology sectors.

The main core contents at a glance:

1. Tightening of the oil price cap and energy sanctions

• Reduction of the oil price cap for Russian crude oil to US$ 47.60 per barrel – in the future dynamically linked to the average market price for Urals crude oil.

• Transaction ban on all business related to the Nord Stream pipelines.

• Import ban on refined oil products from Russian crude oil – even when processed in third countries.

2. Shadow fleet and port access

• EU sanctions list expanded by 105 to 444 ships of the so-called shadow fleet.

• Asset freezes, service bans, and port access bans for listed ships and operators.

3. Financial sanctions and transaction bans

• Complete transaction and message transmission bans with another 22 Russian banks; a total of 45 institutions are now listed.

• Prohibition of transactions with financial actors from third countries, particularly in connection with sanctions circumventions or the Russian financial transaction system SPFS.

• New sanctions against the Russian Direct Investment Fund (RDIF) and related holdings and financial service providers.

4. Extended export bans and "Catch-all" rule

• Additional export restrictions for advanced technologies, machinery, dual-use goods, and military-use chemical precursors.

• Transit ban for economically critical goods (e.g., for construction and energy industry) over Russian territory.

• Implementation of a "Catch-all" regulation for suspicious exports via third countries.

5. Listings, accountability, and investment arbitration

• Numerous new listings of companies/organizations that are part of the military-industrial supply chain of Russia or involved in circumventing sanctions; outside Russia, particularly companies in China/Hong Kong, Turkey, and Belarus.

• Measures against propaganda actors and those responsible for the deportation of Ukrainian children.

• EU protective measures against investment arbitration by listed persons.

What does this mean for your company?

The 18th sanctions package also shows:

The requirements for sanctions compliance for EU companies, particularly in the export business, continue to tighten. Those working with international partners, particularly in third countries, should now:

• Check the currency of sanctions list screening, KYC processes, and contract clauses,

• Analyze supply and value chains with regard to prohibited transactions and transit over Russia,

• Further develop compliance structures – particularly concerning export control, best-effort obligations, the so-called No-Russia clause (see our Insight of 27 April 2024), and CHP goods.

Further recommendations for sanctions compliance can be found in our previous Insight of 18 June 2025.