The 18th sanctions package against Russia and Belarus

I. Background

It was not until May 2025 that the EU member states decided on minor financial and economic sanctions against Russia in the 17th Sanctions Package. The focus was primarily on further measures against Russia's “shadow fleet” and an expansion of the list of goods that contribute to Russia's military and technological strengthening or to the development of its defense and security sector and are therefore subject to certain export restrictions. Several individuals and companies or organizations were also subject to individual sanctions (financial sanctions).

The current package of sanctions builds on these past regulations and significantly supplements and expands them.

II. The 18th Sanctions Package

On July 19th, 2025, the EU member states adopted Regulation (EU) 2025/1494 with regard to Regulation (EU) 833/2014, the Implementing Regulation (EU) 2025/1476 with regard to Regulation (EU) 269/2014 (both concerning Russia) as well as Regulation (EU) 2025/1469 and Implementing Regulation (EU) 2025/1469 with regard to Regulation (EC) 765/2006 (both concerning Belarus) on further individual and economic sanctions. These came into force on the day of their announcement (July 19th, 2025).

The package of measures focuses on the following details:

• Sanctions imposed on 105 additional ships belonging to the so-called Russian shadow fleet. The aim is to cover the entire value chain of the fleet. The ships are therefore banned from entering European ports and are prohibited from receiving various services. This means that 444 ships are now sanctioned by name.
• Refined petroleum products are subject to an import ban. It does not matter whether they are imported from a third country. Exceptions to this are Canada, Norway, Switzerland, the United Kingdom, and the United States.
• Introduction of a dynamic oil price cap. Which was previously set at US$60 per barrel and will now be adjusted dynamically and is reduced initially to US$47.6 per barrel. The European Commission will in future be able to determine the oil price cap according to a predefined calculation method. The mechanism is separate from future legislative procedures and is thus intended to effectively curb circumvention of the price cap by using non-transparent trading structures such as the Russian shadow fleet.
• Extension of the existing transaction ban to 22 additional Russian banks. In addition, financial, credit, and crypto services from third countries that thwart EU sanctions or support Russia's war in Ukraine through their actions will be sanctioned. Specifically, the focus was on the Chinese Heihe Rural Commercial Bank Co. Ltd. and the Heilongjiang Suifenhe Rural Commercial Bank Co. Ltd.
• Imposition of comprehensive sanctions against Russian military suppliers. Three companies based in China and eight companies from Belarus are specifically named. In addition, 26 new organizations will be subject to strict export restrictions on dual-use goods. Eleven of these organizations are based in third countries (China, Hong Kong, and Turkey).
• Extension of export restrictions on goods that contribute to strengthening Russia's defense and security sector. Annex VII to Regulation (EU) No 833/2014 imposes export bans on six different chemical components for fuel, certain machinery and equipment (such as CNC machines) and certain plastics that are or can be used for the development and manufacture of military capabilities.

III. Conclusion and Outlook

The sanctions of the current 18th package mark another milestone in European measures against Russia and Belarus, which were imposed in response to Russia's war of aggression against Ukraine, now in its fourth year. This package sends a clear message from the EU: "Europe's support for Ukraine will not waver. The EU will continue to increase pressure until Russia ends its war. “

The comprehensive package of measures once again poses a challenge for the internal export control of European companies. They are obliged to record the ever-increasing number of listed individuals, companies, and organizations as part of their internal compliance programs to ensure that they avoid any ”interactions" with them. In addition, the increasing sanctions against companies or organizations in third countries (outside Russia and Belarus), such as the banks mentioned above, pose additional hurdles for European companies.

European companies should therefore continuously adapt their internal export control programs to reflect the current requirements in their processes. In view of the severe penalties for violations of the sanctions requirements, legal advice in this context is clearly recommended.

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

Council Implementing 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

Council Regulation (EU) 2025/1472 of 18 July 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

Council Implementing Regulation (EU) 2025/1469 of 18 July 2025 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine