On 18 July 2025, after lengthy negotiations, the Council of the EU adopted the 18th sanctions package against Russia and Belarus, which had been announced several months earlier. With the new sanctions package, the EU is sticking to its policy of gradually increasing economic pressure on Russia. In addition to extending existing measures, the sanctions package therefore also contains new sanctions. The 18th sanctions package focuses in particular on the energy, arms and financial sectors. The sanctions against Belarus have also been extended.
With regard to sanctions against Russia, the 18th sanctions package consists of Regulation (EU) 2025/1494 amending Regulation (EU) No 833/2014 (‘Reg. (EU) 833/2014’) and Implementing Regulation (EU) 2025/1476 amending Regulation (EU) No 269/2014 (‘Reg. (EU) 269/2014’). With regard to Regulation (EC) No. 765/2006 against Belarus (‘Reg. (EC) 765/2006’), it consists of Regulation (EU) 2025/1472 and Implementing Regulation (EU) 2025/1469.
The following overview summarises the main adjustments and additions:
Sanctions in the energy sector
To further limit Russia’s profits from the energy sector, the current oil price cap of USD 60 will be lowered to USD 47.60 per barrel of crude oil from 3 September 2025. In addition, the EU Commission will in future use an ‘automatic and dynamic mechanism’ to review the need to adjust the oil price cap every six months to keep it 15% below the average market price for Russian crude oil in the long term (Art. 3n (11) Reg. (EU) 833/2014).
The new ban on the import and purchase of petroleum products (Art. 3ma Reg. (EU) 833/2014) obtained from crude oil of Russian origin in third countries, which will come into force on 21 January 2026, is intended to prevent indirect access of Russian crude oil to the EU in this way. This sanction is accompanied by bans on certain services, financial assistance and insurance.
When importing petroleum products, proof of the origin of the crude oil from which the products were extracted must be provided. The EU Commission has already announced that it will issue guidelines on the requirements for providing proof. Exceptions apply to imports from Canada, Norway, Switzerland, the United Kingdom and the United States, as well as to countries that are considered ‘net exporters of crude oil’.
By adding to Annex XLII of Reg. (EU) 833/2014, a further 105 ships have been assigned to the Russian shadow fleet, which are denied access to ports and locks in the EU (Art. 3s Reg. (EU) No 833/2014). These vessels are also subject to prohibitions on acquisition, sale and chartering, as well as further prohibitions on maritime transport, ship supply and other services.
Regarding the Nord Stream and Nord Stream 2 natural gas pipelines, there is a comprehensive ban on transactions related to the completion, operation, maintenance or use of these pipelines (Art. 5af Reg. (EU) 833/2014). The EU has thus clearly rejected the resumption of operation of this pipeline.
Sanctions in the financial sector
A significant change in the financial sector is the tightening of the previous ban under Article 5h of Reg. (EU) 833/2014 regarding the provision of specialised messaging services for payment transactions (SWIFT) to a comprehensive ban on transactions with the banks listed in Annex XIV and their Russian subsidiaries. Annex XIV now also includes further 22 Russian banks.
In addition, the Russian financial sector is also subject to a comprehensive ban on transactions with the Russian Direct Investment Fund (RDIF), its subsidiaries and the companies and institutions listed in Annexes XLIX and L of Regulation (EU) 833/2014 (Art. 5ag of Reg. (EU) 833/2014).
Regarding the existing transaction ban pursuant to Art. 5ad of Reg. (EU) 833/2014 concerning banks and organisations providing crypto-asset services, Annex XLV, which was previously empty, now contains for the first time two affected banks from China that are said to have made a significant contribution to the circumvention of the sanctions measures.
In addition, the 18th sanctions package also extends the sales and export ban under Article 5n(2b) of Reg. (EU) 833/2014 for certain software products listed in Annex XXXIX to include software for the banking and financial sector. This includes, in particular, software for online banking, ATMs, POS systems and investment banking.
Sanctions in the defence and other industrial sectors
In addition to the existing prohibition in Article 2a(1) of Reg. (EU) No 833/2014, the new paragraph 1aa provides for a ‘catch-all rule’ for the export of goods listed in Annex VII to third countries outside Russia to further restrict circumvention. Such exports are now subject to authorisation if the competent authority has informed the exporter that the goods are or may be intended, in their entirety or in part, for persons, organisations or entities in Russia or for use in Russia. Annex VII has also been supplemented by certain chemical components for fuels and two additional types of machine tools.
Significant expansions of the range of sanctioned goods also affect Annex XXIII, among others, through the new Annexes XXIIIE and XXIIIF, which cover numerous raw materials, means of production and industrial equipment. For these newly covered goods, there are grandfathering provisions that exempt the sale and export of these goods from the prohibition in Article 3k of Reg. (EU) 833/2014 for a transitional period.
Additions to the sanctions lists
Fourteen individuals and 41 companies or organisations are affected by financial sanctions due to the renewed extension of Annex I of Reg. (EU) 269/2014. In particular, no funds or other economic assets may be made available to these individuals and companies. This also affects sanctioned individuals and companies in China, Hong Kong, India, Iran, Mauritius and the United Arab Emirates, among others.
Furthermore, 26 individuals and companies have been added to Annex IV of Regulation (EU) 833/2014. The export of goods listed in Annex I of the EU Dual-Use Regulation and Annex VII of Reg. (EU) 833/2014 to these individuals and companies now covered by Annex IV, which are not only located in Russia, is strictly prohibited.
Tightening of sanctions against Belarus
In addition to extending the personal financial sanctions against eight companies from the Belarusian arms industry by including them in Annex I of Reg. (EC) No 765/2006, the list of sanctioned goods in Annex XVIII was also expanded to align with the additions to Annex XXIII of Reg. (EU) No 833/2014, so that these goods may not be exported or sold to Belarus in accordance with Article 1bb of Regulation (EC) 765/2006.
For the goods listed in Annex Va to Reg. (EC) No 765/2006, a ‘catch-all rule’ will apply in future in accordance with Article 1f(1aa), as established for Russia in Article 2a (1aa) of Reg. (EU) No 833/2014. Notification of the competent authority will then result in an authorisation requirement for exports to third countries outside Belarus.
In addition, further sanctions against Belarus have been introduced in order to achieve the best possible alignment with the sanctions against Russia and to limit circumvention via Belarus.
Conclusion
The 18th sanctions package differs significantly from the previous one and intensifies measures against Russia, but also against actors in third countries, in order to make it more difficult for Russia to finance its war against Ukraine and to further restrict its military capabilities. Combating the circumvention of sanctions remains a key focus of the EU’s sanctions strategy.
Internationally active EU economic operators in particular must therefore familiarise themselves with the new provisions of the 18th sanctions package in order to meet compliance requirements, identify circumvention risks and counteract them with appropriate measures. Vischer Voss is happy to support you in improving your company’s individual export control and sanctions compliance and minimising liability risks.
