EU Adopts 16th Package of Russia Sanctions, February 24, 2025

On February 24, 2025, the Council of the European Union (EU) adopted the 16th package of EU sanctions against Russia. The Council decisions and regulations amend legal authorities that the EU adopted originally in 2014 as a response to Russian actions in Ukraine and which the Council subsequently expanded and strengthened after the Russian invasion of Ukraine in February 2022.

The purpose of the 16th package is to enable the EU to impose additional restrictions on important Russian economic sectors including energy, trade, transport, infrastructure, and finance, further degrade Russian military-industrial capabilities, and reduce entities’ ability to circumvent restrictive measures and acquire sought-after commodities and sensitive items.

The amended sanctions entered into effect on February 25, the day following the publication of legal amendments in the Official Journal of the European Union.

Here SECURUS analyzes many of the notable changes dealing with Russia-related travel bans, asset freezes, and financial, trade, transport, and other business restrictions. It is important for companies doing business in the EU or trading with EU Member States to be aware of the changes in the Russia restrictive measures because of their strictness, extensiveness, wide-reaching applicability, and dynamic nature.

Amendments to Council Decision 2014/145/CFSP and Council Regulation (EU) No 269/2014

Council Decision 2014/145/CFSP, as amended, establishes a travel ban in the EU on designated persons and entities. It requires EU Member States to take necessary measures to prevent entry into or transit through their territories of designated natural persons responsible for or participating in certain activities. These include undermining Ukraine’s independence, conducting transactions with separatist groups in the Donbas region, materially or financially supporting or benefiting from the Russian government, facilitating infringements of the prohibition against circumvention of the restrictive measures, and benefiting from the compulsory transfer of ownership or control of entities established in Russia that were previously owned or controlled by entities established in the EU. Persons subject to the travel ban are designated in the Annex of the decision.

Council Decision 2014/145/CFSP and Council Regulation (EU) No 269/2014, as amended, freeze the funds and economic resources belonging to or owned, held, or controlled by designated natural or legal persons, entities, or bodies responsible for or participating in specified activities. These include undermining or threatening Ukraine’s sovereignty, supporting or benefiting from Russian decision makers responsible for annexation of Crimea or destabilization of Ukraine, providing a substantial source of revenue to the Russian government, facilitating infringements of the prohibition against circumvention of the restrictive measures, and holding a Russian weapons and military-equipment license. These statutes also prohibit making funds or economic resources directly or indirectly available to or for the benefit of listed persons, entities, or bodies or persons, entities, or bodies associated with them. Listed natural and legal persons, entities, or bodies are found in the Annex of the decision and Annex I of the regulation.

On February 24, the Council amended Council Decision 2014/145/CFSP and Regulation (EU) No 269/2014 in:

• Council Decision (CFSP) 2025/388 of 24 February 2025 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine;

• Council Regulation (EU) 2025/390 of 24 February 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine; and

• Council Implementing Regulation (EU) 2025/389 of 24 February 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 following is an overview of selected changes these statutes make:

• Designated persons and entities in the Annex of Council Decision 2014/145/CFSP and Annex I of Council Regulation (EU) No 269/2014 now include:

  • Natural or legal persons, entities, or bodies that own, control, manage, or operate vessels that transport crude oil or petroleum products, originating in Russia or exported from Russia, while practicing “irregular and high-risk shipping practices” or that otherwise provide material, technical, or financial support to such vessels’ operations; and

  • Natural or legal persons, entities, or bodies forming part of, materially or financially supporting, or benefiting from Russia’s military-industrial complex, including by being involved in the development, production, or supply of military technology and equipment.

• There are several additional circumstances under which competent authorities may release certain frozen funds, economic resources, or payments.

• Natural and legal persons, entities, and bodies now must undertake their “best efforts” to ensure that any legal person, entity, or body established outside the EU that they own or control does not participate in activities that undermine the restrictive measures. “Best efforts” are understood to comprise “all actions that are suitable and necessary to achieve the result of preventing the undermining of the restrictive measures in Regulation (EU) No 269/2014.” They comprise “only actions that are feasible for the Union operator in view of its nature, its size and the relevant factual circumstances, in particular the degree of effective control over the legal person, entity or body established outside the Union.”

• There is now a total of 1,927 persons and 542 entities on the travel ban and asset freeze list.

Amendments to Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014

Council Decision 2014/512/CFSP and Council Regulation (EU) No 833/2014, as amended, prohibit financial transactions with designated Russian and Russia-linked natural and legal persons, entities, bodies, and services, trade activities involving a range of items and services that could enable or enhance Russian military and industrial capabilities or facilitate sanctions evasion, and other business activities. Among the activities they prohibit are:

• Financial activities including purchasing, selling, providing investment services for or assisting in the issuance of or any other dealing with respect to certain financial instruments, transferable securities, and money-market instruments with Russia, the Russian government, the Russian Central Bank, listed Russian entities, and certain associated parties;

• Directly or indirectly engaging in transactions with listed legal persons, entities, or bodies established in Russia that are publicly controlled or have more than 50% ownership or in which Russia, the Russian government, or the Russian Central Bank has the right to participate in profits or some other substantial economic relationship;

• Connecting with Russia’s System for Transfer of Financial Messages (SPFS) or an equivalent service linked to the Russian Central Bank or associated parties or engaging directly or indirectly with listed persons and entities that use the SPFS or equivalent service;

• Engaging directly or indirectly with listed entities providing crypto assets services that are involved in efforts to facilitate Russian procurement of specified controlled items;

• Directly or indirectly providing a variety of professional services such as accounting, tax consulting, public relations, architectural, engineering, and advertising services to the Russian government or legal persons, entities, or bodies established in Russia;

• Directly or indirectly selling or providing arms and materiel or related services such as technical assistance, brokering, and financial services to Russia or to any legal or natural person, entity, or body in Russia or for use in Russia;

• Directly or indirectly importing, purchasing, or transporting arms and materiel from Russia or using their flag vessels or aircraft;

• Directly or indirectly selling or providing dual-use items or related services or selling, licensing, or transferring related intellectual property rights (IPR) or trade secrets to any natural or legal person, entity, or body in Russia or for use in Russia, or transiting Russian territory with dual-use items exported from the EU;

• Directly or indirectly selling or providing a variety of other types of items or related services, IPR, or trade secrets to any natural or legal person, entity, or body in Russia or for use in Russia, including:

  • Those that could contribute to Russia’s military and technological enhancement or defense and security sector development, or transiting Russian territory with such items exported from the EU;

  • Those suited to certain types of exploration and production projects, oil refining, natural gas liquefaction, aviation, or the space industry;

  • Firearms, their parts, essential components, and ammunition;

  • Maritime navigation items;

  • Luxury items;

  • Items that could contribute to enhancement of Russian industrial capacity; and

  • Other listed items;

• Directly or indirectly selling or transferring tankers for transport of certain listed crude oil or petroleum products to any natural or legal person, entity, or body in Russia or for use in Russia;

• Providing reloading or certain other services related to liquefied natural gas (LNG) originating in Russia or exported from Russia;

• Directly or indirectly purchasing, importing, or providing related services in cases in which items originated in or were exported from Russia:

  • Iron or steel products;

  • Crude oil or petroleum products;

  • Gold and some related products; and

    Diamonds and some related products;

• Directly or indirectly purchasing, importing, or transferring goods that generate significant revenue for Russia as well as providing related services;

• Directly or indirectly purchasing, importing, transferring, selling, supplying, or exporting or providing related services with respect to Ukrainian cultural property and other goods of archaeological, historical, cultural, rare scientific, or religious importance if there is reason to believe the items were removed from Ukraine without the necessary approvals;

• A variety of transport and related activities, including:

  • Landing in, taking off from, or overflying EU territory by Russian air carriers, Russian-registered aircraft, or non-Russian-registered aircraft controlled by a Russian natural or legal person, entity, or body;

  • Providing access to locks in EU territory to any vessel registered under the Russian flag and for such vessels to access ports and locks; and

  • Transporting goods in EU territory by road undertakings established in Russia; and 

• Broadcasting, enabling, facilitating, or otherwise contributing to broadcast content, or advertising any products or services in any content produced or broadcast, by listed legal persons, entities, or bodies.

On February 24, the Council amended Council Decision 2014/512/CFSP and Regulation (EU) No 833/2014 in:

• Council Decision (CFSP) 2025/394 of 24 February 2025 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine; and

• Council Regulation (EU) 2025/395 of 24 February 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.

The following is an overview of selected changes these statutes make.

Financial and Sanctions-Evasion Transactions

• Competent authorities may authorize the execution of transactions with entry number 1 in Annex XLIV of Regulation 833/2014 under conditions they deem appropriate and after determining the transactions are necessary for: repayment of export credits guaranteed; divestment from Russia or the wind-down of business activities in Russia by August 26, 2025, which was covered by export credit guarantees by a Member State; or execution of contracts concluded between February 25 and August 26, 2025, or until their expiry date, whichever is earlier for beneficiaries in the EU.

• It is generally prohibited to engage directly or indirectly in any transaction with a listed legal person, entity, or body established outside the EU that is a credit or financial institution or crypto services provider involved in transactions that directly or indirectly facilitate the export, sale, supply, transfer, or transport to Russia of: items on the EU List of Dual-Use Items, goods and technologies listed in Annexes VII (Russian military, technological, or defense-security-sector enhancement), XI (aviation- and space-related), XX (jet fuel-related), and XXXV (firearms and other arms) of Regulation 833/2014, the List of Common High-Priority Items (in Annex XL of the regulation), and firearms and ammunition listed in Annex I of Regulation (EU) No 258/2012. Listed institutions will appear in Part A of Annex XLV of Regulation 833/2014.

• Moreover, it is now generally prohibited to engage directly or indirectly in any transaction with a listed legal person, entity, or body established outside the EU that is a credit or financial institution or crypto services provider that is involved in “frustrating” the prohibitions on providing access to EU ports and locks, flag registration, ship brokering, and other related activities through transactions related to any vessel listed in Annex XLII of Regulation 833/2014. Listed institutions will appear in Part B of Annex XLV of the regulation.

• It is also generally prohibited to engage in transactions with listed institutions that circumvent the prohibitions on providing services to third countries with respect to specified crude oil or petroleum products that originated in or were exported from Russia. Listed institutions will appear in Part C of Annex XLV.

• The prohibitions in the three previous bullets also apply to legal persons, entities, or bodies acting on behalf or at the direction of a listed entity.

• It is now generally prohibited to engage directly or indirectly in any transaction with listed Russian ports, locks, or airports that are used for the transfer or transport of a variety of sensitive or controlled products, including unmanned aerial vehicles (UAVs), missiles, items used in the Russian defense and security sector, and listed crude oil and petroleum products, and are also used to facilitate or enable circumvention of the restrictive measures. Prohibited ports and locks appear in Part A of Annex XLVII of Regulation 833/2014, and airports appear in Part B.

• The prohibition on the sale, supply, transfer, or export of banknotes denominated in an official currency of an EU Member State to Russia or to any natural or legal person, entity, or body in Russia or for use in Russia no longer applies to cases in which the transaction is necessary for civil society and media activities that directly promote democracy, human rights, or the rule of law in Russia which receive public funding from the EU, Member States, or certain partner countries.

• The list of legal persons, entities, and bodies to which it is prohibited to provide specialized financial messaging services has expanded from 10 to 23.

Trade in Items on the EU List of Dual-Use Items

• Prohibitions do not apply to the sale, supply, transfer, or export of dual-use goods or technology or the related provision of technical or financial assistance, for non-military use and for a non-military user, that is/are intended for medical or pharmaceutical purposes, so long as the items are not on the List of Common High-Priority Items (found in Annex XL of Regulation 833/2014).

• Temporary exports of dual-use items intended for use by news media and export, supply, etc. of dual-use items intended for software updates or personal use by natural persons traveling to Russia or members of their immediate families traveling with them are now generally prohibited.

• However, competent Member State authorities may authorize the sale, supply, transfer, or export of some of those items and related services for a non-military use and a non-military end-user. These authorization requirements apply to dual-use goods and technology intended for software updates, consumer communication devices, or medical or pharmaceutical products that appear on the List of Common High-Priority Items, as well as other items.

• When deciding on requests for dual-use trade authorizations, competent authorities no longer take into consideration whether dual-use items are intended for cooperation between the EU, Member State governments, and the Russian government in purely civilian matters.

• Moreover, competent authorities will not grant an authorization if they have reasonable grounds to believe that the sale, supply, transfer, or export of dual-use goods or technology or provision of related technical or financial assistance is intended for aviation or the space industry.

• It is now generally prohibited to directly or indirectly sell, supply, transfer, or export dual-use goods or technology, whether or not they originate in the EU, or provide related services, IPR, or trade secrets to any natural or legal person, entity, or body listed in Annex IV of Regulation 833/2014 (the list of Russia military end-users, entities in Russia’s military-industrial complex, and entities that support Russia’s defense and security sectors).

• Competent authorities may authorize a transaction with an entity on the Annex IV list, however, after determining that the items or related services are necessary for urgently preventing or mitigating an event that could seriously affect human health, safety, or the environment or are due under certain previously-concluded contracts.

Trade in Items That Could Contribute to Russia’s Military and Technological Enhancement or Development of Its Security Sector (Items in Annex VII of Regulation 833/2014)

• There are several changes to the Annex VII list of items that might contribute to Russia’s military and technological enhancement or development of its defense and security sector.

  • One notable change is the addition in Category III, Part 1 “Telecommunications” of X.A.III.101.i., which applies to “Video game controllers, gaming controllers, flight simulator controllers, gamepads, joysticks and other input units, for video game consoles or entertainment systems, either corded or cordless.”

  • Another is the addition in Category VIII “Miscellaneous Items” of X.A.VIII.021.h., which applies to “Chemical precursors to Riot Control Agents (RCAs) or irritating substances, as follows…”

  • A third change is the addition in Category X “Materials Processing” of X.D.X.007, which applies to “Software for the development, production, or use of CNC [computer numerical control] equipment controlled by X.A.X.002 or required for the development of software controlled by X.D.X.002.” 

  • A further change to note is the addition of chromium to the chemicals, metals, alloys, and other advanced materials in Part B(8).

• Prohibitions do not apply to the sale, supply, transfer, or export of Annex VII goods or technology or the related provision of technical or financial assistance, for non-military use and for a non-military user, that is/are intended for medical or pharmaceutical purposes, provided the items are not on the List of Common High-Priority Items.

• Temporary exports of Annex VII items intended for use by news media and export, supply, etc. of Annex VII items intended for software updates or personal use by natural persons traveling to Russia or members of their immediate families traveling with them are now generally prohibited.

• However, competent Member State authorities may authorize the sale, supply, transfer, or export of some of those items and related services for a non-military use and a non-military end-user. These authorization requirements apply to Annex VII goods and technology intended for software updates, consumer communication devices, or medical or pharmaceutical products that appear on the List of Common High-Priority Items, as well as other items.

• When deciding on requests for Annex VII trade authorizations, competent authorities no longer take into consideration whether Annex VII items are intended for cooperation between the EU, Member State governments, and the Russian government in purely civilian matters.

• Competent authorities will not grant an authorization if they have reasonable grounds to believe that the sale, supply, transfer, or export of Annex VII goods or technology or provision of related technical or financial assistance is intended for aviation or the space industry.

• It is generally prohibited to directly or indirectly sell, supply, transfer, or export Annex VII goods or technology, whether or not they originate in the EU, or provide related services, IPR, or trade secrets to any natural or legal person, entity, or body listed in Annex IV of Regulation 833/2014.

• However, competent authorities may authorize a transaction with an entity on the Annex IV list after determining that the items or related services are necessary for urgently preventing or mitigating an event that could seriously affect human health, safety, or the environment or are due under certain previously-concluded contracts.

• A total of 760 persons or entities now appear in the Annex IV list. Previously there were 707 persons or entities on the list. The list now includes 34 entities in countries other than Russia that the EU found to have assisted in the circumvention of EU export restrictions on military-applicable items.

Public Financing or Financial Assistance for Trade with or Investment in Russia

• It is generally prohibited to provide public financing or financial assistance for trade with or investment in Russia up to a total amount of 10 million euros per project benefiting small and medium-sized enterprises established in the EU. Previously, these transactions were exempted from prohibition. Such transactions are now subject to authorization by competent authorities “under such conditions as they deem appropriate…”

Trade in and Transport of Oil, Gas, and Petroleum Products

• It is now generally prohibited to directly or indirectly sell, supply, transfer, export, or provide, directly or indirectly, specified software related to oil and gas drilling and pipelines to any natural or legal person, entity, or body in Russia or for use in Russia. The software subject to the prohibition is listed in Annex II of Regulation 833/2014.

• The prohibition on providing technical assistance, brokering, financial, and other services related to Annex II-listed oil-and-gas-related goods and technologies now applies to Annex II-listed software as well.

• It is now generally prohibited to directly or indirectly sell, license, or transfer IPR or trade secrets or grant rights to access or reuse any material protected by IPR or trade secrets related to Annex II-listed oil-and-gas-related goods, technologies, and software to any natural or legal person, entity, or body in Russia or for use in Russia.

• The software prohibition does not apply to the sale, supply, transfer, export, or provision of software necessary for the execution of certain contracts.

• Competent authorities may authorize export, supply, etc. of Annex II-listed oil-and-gas-related software under the same circumstances that they may authorize transactions involving goods, technologies, related services, and provision of IPR or trade secrets.

• Temporary storage and placement under the free zone procedure of crude oil and petroleum products listed in Annex XXV of Regulation 833/2014 are now generally prohibited if the goods originate in Russia or were exported from Russia. This prohibition does not apply under certain circumstances, including in the case of listed seaborne crude oil and petroleum products that originated in a third country and are only being loaded in, departing from, or transiting Russia, provided that both the origin and owner of the goods are non-Russian.

• Prohibitions on reloading services in EU territory for purposes of transshipment operations for certain LNG products originating in or exported from Russia, as well as related services, no longer apply if the reloading is necessary for the transport of the products between ports of the same Member State.

• It is now prohibited to directly or indirectly sell, supply, transfer, or export goods or technologies or provide related services to any natural or legal person, entity, or body in Russia when the items or services are for the completion of crude oil projects in Russia such as exploration and production projects.

• Competent authorities may authorize the purchase, import, or transfer of LNG in the EU Combined Nomenclature (CN) code 2711.11.00 that originated in or was exported from Russia in cases in which an LNG terminal is not connected to the interconnected natural gas system and the authorities determine that the LNG is purchased, imported, or transferred from a terminal located in another Member State that is connected to the interconnected natural gas system and the transaction is to ensure energy supply.

Trade in Goods That Generate Significant Revenue for Russia (Items in Annex XXI of Regulation 833/2014)

• Goods in the CN heading 7601 (unwrought aluminum) are added to the list of Annex XXI goods, whose direct or indirect purchase, import, or transfer or provision of related services, if the items originate in or are exported from Russia, is generally prohibited.

• The EU is taking a phased approach to implementing this prohibition, and incremental quota mechanisms provide exceptions to the prohibition. The prohibition does not apply to goods in CN 7601 if the import, purchase, or transport or provision of related technical or financial assistance is necessary for the import into the EU of 275,000 metric tons of unwrought aluminum between February 25, 2025, and February 26, 2026. Furthermore, the prohibitions on direct or indirect purchase, import, or transfer or provision of related services with respect to unwrought aluminum will not apply to the execution from February 26, 2026, to December 31, 2026, of contracts concluded before February 25, 2025, for a total volume of imports into the EU of up to 50,000 metric tons of such goods.

Trade in Goods That Contribute to Enhancement of Russian Industrial Capabilities (Items in Annex XXIII of Regulation 833/2014)

• A new Annex XXIIID to Regulation 833/2014 is created. Annex XXIIID contains selected items in CN headings 2518-2520, 2615, 2834, 3604-3606, 4811, 6814, 7007, and 7320. The prohibitions on direct or indirect sale, supply, transfer, or export of, provision of services, IPR, or trade secrets related to, and transit through Russian territory of such items exported from the EU will not apply to the goods in Annex XXIIID until May 26, 2025, with respect to the execution of contracts concluded before February 25, 2025.

• Competent authorities now may authorize the sale, supply, transfer, or export or provision of related technical or financial assistance with respect to goods in CN 7007.19.80 if they determine that the goods or services are necessary for personal household use of natural persons in Russia. In the 2025 Combined Nomenclature, 7007.19.80 applies to toughened “tempered” safety glass (excl. enameled, colored throughout the mass, opacified, flashed or with an absorbent or reflecting layer, glass of size and shape suitable for incorporation in motor vehicles, aircraft, spacecraft, vessels and other vehicles, and lenses for spectacles and goggles, etc., and for clocks and watches).

• In addition, competent authorities now may authorize the sale, supply, transfer, or export of or provision of technical or financial services related to goods in CN codes 2920.90 (esters of certain inorganic acids of non-metals and their salts), 3917.10 (artificial sausage casings of hardened protein or cellulose materials), and 3920.62 (certain types of plates, sheets, film, foil, and strip) if they determine that the goods are to be sold, supplied, transferred, or exported strictly for production of food items for human consumption in Russia.

• Competent authorities also may authorize the export and transfer of goods in the CN codes 8517.62 (machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus) and 8523.52 (smart cards) if they are intended for civilian non-publicly available electronic communications networks that are not the property of an entity that is publicly controlled or with over 50% public ownership.

• The Annex XXXVII list of goods that could contribute to the enhancement of Russian industrial capacities and which cannot transit Russia after having been exported from the EU has grown from 14 CN codes to 33.

Trade in Diamonds and Related Products (Items in Annex XXXVIIIA of Regulation 833/2014)

• For persons importing items in CN 7102.31.00 (non-industrial diamonds, unworked or simply sawn, cleaved or bruted) and 7102.10.00 (unsorted diamonds) that were processed in a third country and consist of diamonds of specified carats that originated in Russia or were exported from Russia, it is now necessary to submit for verification “without delay” to the Federal Public Service Economy at the Diamond Office in Brussels a Kimberley Process certificate clearly identifying the country or countries of mining origin.

• As of March 1, 2025, the traceability-based evidence for products listed in Part A of Annex XXXVIIIA CN codes 7102.10.00 and 7102.31.00 must include a certificate certifying that the diamonds were not mined, processed, or produced in Russia.

• The traceability-based evidence for products in Part A of Annex XXXVIIIA CN code 7102.39.00 must include a similar certificate starting January 1, 2026.

Other Transport-Related Measures

• An exception to the prohibition on landing, take-off, and overflight by aircraft operated by Russian air carriers, Russian registered aircraft, or non-Russian-registered aircraft owned or chartered or otherwise controlled by a Russian natural or legal person, entity, or body now specifically extends to small manned aircraft used for “non-commercial” flights, as well as private and non-corporate flights, within the EU for recreational purposes or private-pilot-license training.

• It is now generally prohibited for air carriers operating domestic flights within Russia or directly or indirectly selling, supplying, transferring, or exporting aircraft or any of the aviation-, space-, or jet-fuel-related goods or technologies found in Annexes XI and XX of Regulation 833/2014 to a specified Russian air carrier or for flights within Russia or for any entity owned or controlled by such an air carrier, to land in, take off from, or overfly EU territory. The specified air carriers and Russian flights will be identified in the new Annex XLVI of Regulation 833/2014. This prohibition does not apply in the case of an emergency landing or overflight.

• As an exception to that prohibition, competent authorities may authorize an aircraft to land in, take off from, or overfly EU territory if they determine that the action is required for humanitarian purposes or any other purpose consistent with Regulation 833/2014.

• Additionally, competent authorities now may authorize certain unmanned aircraft (drones) used for private, non-commercial, non-corporate flights carried out within EU territory and airspace for recreational purposes to land in, take off from, or overfly EU territory.

• It is now prohibited for any legal person, entity, or body established in the EU which has 25% or more ownership by a Russian natural or legal person, entity, or body to be admitted as a road transport undertaking that transports goods by road within EU territory, including in transit.

• Furthermore, it is also prohibited for any legal person, entity, or body established in the EU before April 8, 2022, that is already a road transport undertaking in the EU to make any changes to its capital structure that would increase the percentage share owned by a Russian natural or legal person, entity, or body, unless the share remains under 25%.

• Prohibitions on port and lock access and other specified activities involving vessels listed in Annex XLII of Regulation 833/2014 no longer apply in cases in which there is an investigation into infringements of the provisions of the regulation or into other illicit activity.

• The list of vessels whose access to EU ports, anchorage zones, and locks and which are subject to other restrictions has grown from 79 entries to 153.

• There are now three entries in the list of legal persons, entities, and bodies established outside Russia with which persons subject to the EU restrictive measures are prohibited from engaging.

• The new Annex XLVII contains lists of five ports and locks (Part A) and six airports (Part B) that persons subject to the EU restrictive measures are prohibited from engaging.

Other Business Services

• It is generally prohibited to directly or indirectly provide construction services to the Russian government or legal persons, entities, or bodies established in Russia.

• It is also generally prohibited to sell, license, or transfer IPR or trade secrets or grant rights to access or re-use any material or information protected by IPR or trade secrets related to enterprise management, industrial design, or manufacture software listed in Annex XXXIX of Regulation 833/2014 to the Russian government or legal persons, entities, or bodies established in Russia.

Trade in “Other Sensitive Goods”

• The amendments introduce a new Annex XLVIII in Regulation 833/2014 that consists of items in CN 8502.20 (generating sets with spark-ignition internal combustion piston engines) and 8536.50 (other switches), which Decision 2025/394 refers to as “other sensitive goods.” Special due diligence requirements will apply to some persons doing business in these items.

• Beginning May 26, 2025, natural and legal persons, entities, and bodies that sell, supply, transfer, or export these items must take appropriate steps, proportionately to their nature and size, to identify and assess the risks of these items’ exportation to Russia or for use in Russia and ensure that the risk assessments are documented and kept up to date. They also must implement appropriate policies, controls, and procedures to mitigate and manage effectively the risks of such exports. This requirement is intended in part to help combat the re-exportation of these goods to Russia.

• These requirements do not apply to natural or legal persons, entities, or bodies that sell, supply, or transfer the “other sensitive goods” only within the EU or to specified partner countries.

• Natural and legal persons, entities, and bodies must ensure that any legal person, entity, or body established outside the EU that they own or control that sells, supplies, transfers, or exports the “other sensitive goods” implement the due diligence requirements starting May 26, 2025, though this does not apply to cases in which an owner is not able to exercise control over a company or entity it owns.

Persons Affected and SECURUS Services

The EU restrictive measures are extensive and detailed. They touch upon many diverse economic and industry sectors, including finance, energy, telecommunications, industrial machinery, aluminum, luxury goods, and transport. Moreover, they have wide-reaching applicability:

• Within EU territory;

• On board any aircraft or vessel under the jurisdiction of an EU state;

• To any Member State national, whether they are inside or outside EU territory;

• To any company, organization, or other entity or body incorporated or constituted under the law of an EU state, whether they are inside or outside EU territory; and

• To any company, organization, or other entity or body doing business in whole or in part within the EU.

SECURUS Strategic Trade Solutions, LLC provides guidance, training, and information to companies and individuals seeking to understand and navigate international trade rules and regulations.

If you have questions about how the EU restrictive measures could affect your business, please contact SECURUS Strategic Trade Solutions at Info@SECURUSTrade.com for a consultation.

Author: Richard Glen Young, Richard.Young@SECURUSTrade.com, March 10, 2025