The EU has announced its 16th Russia Sanction Package. It appears that other countries are preserving a firm grip on sanctions applied so far, and those sanctions are becoming more and more strict with each package announced.
This new package aims to prevent the circumvention ways of sanctions on Russia, and have the sanctions to reach the EU’s main goals without being broken by commercial loopholes.
The EU has declared additional restrictions that mainly aim at the energy, industrial, and financial sectors. The key points can be stated are as follows:
The unwrought aluminium export from Russia and Belarus has been banned.
Although there had been restrictions for the oil and gas trade, those restrictions have been expanded with this new package.
74 vessels have been added to Russia's shadow fleet, and the number of sanctioned vessels increased to 153.
Any direct or indirect transaction with ports, locks, and airports in Astrakhan, Makhachkala, Ust-Luga, Primorsk, Novorossiysk, Begishevo, Vnukovo, Zhukovsky, Perm, Koltsovo and Pskov is prohibited. This restriction might be the most effective for international trade and may require all interested parties to alter their prior trade methods.
As of 17 March 2025, providing financial messaging services, financial data exchange, with entities owned more than 50% by entities listed in the package is prohibited.
13 Russian Banks have been excluded from the SWIFT payment system.
Restrictions on dual-use items have been expanded.
Export of industrial items such as minerals, chemicals, glasses, steel, and fireworks that have military significance are now subject to additional restrictions.
The sanctions regimes against Belarus, Crimea, Sevastopol, and certain non-governmental regions of Ukraine have been updated and strengthened.
53 entities are now sanctioned who tried to circumvent the sanctions, 1 of those entities is established in Turkey, 25 in China, 2 in India, 2 in Kazakhstan, 2 in UAE, 1 in Uzbekistan, and 1 in Singapore.
The total number of sanctioned entities stated in Annex IV is now 760.
In addition to the above, Exports of Common High Priority Items, which are dual-use or strategic items, destined for medical or pharmaceutical use, are subject to prior authorization; new reporting obligations for the use of the remaining exemptions for dual-use and strategic items to Russia and Belarus shall be adopted.
The new package has increased the necessary caution and due diligence obligations of interested parties since it is so comprehensive. Within this new package, it seems necessary to be priorly advised by legal experts in order not to lose any coverage provided by companies such as insurance, alliance etc.