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26

Feb
2025

Legal news

Banking and financial law

International and European law

Commercial law

Compliance

26/ Feb
2025

Legal news

Banking and financial law — International and European law — Commercial law — Compliance

Ukraine ● 16th EU sanctions package (sectoral and individual restrictive measures)

By Decision (CFSP) 2025/394 of 24 February 2025, the Council of the EU adopted the 16th sanctions package, which includes sectoral and individual restrictive measures. including the freezing of funds and economic resources.

Strategic sectors of the Russian economy (energy, trade, transport, infrastructure and financial services) are targeted, and additional anti-circumvention measures have been introduced. Sanctions are also targeted at Belarus and the occupied Ukrainian territories.

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INDIVIDUAL RESTRICTIVE MEASURES

  1. The Decision (CFSP) adds 53 new entities to the list of natural or legal persons, entities or bodies supporting Russia's military and industrial complex, on which stricter restrictions are imposed on the export of dual-use goods and technologies and goods and technologies likely to contribute to the technological reinforcement of Russia's defence and security sector. In addition, there are entities from other third countries that indirectly contribute to Russia's military and technological development by circumventing export restrictions, including on unmanned aerial vehicles (UAVs) and missiles
  2. Council Implementing Regulation (EU) 2025/389 of 24 February 2025 adds 83 additional entries (48 persons and 35 entities supporting the Russian military complex, active in sanctions circumvention, Russian crypto-asset trading platforms and the maritime sector) to the list of natural and legal persons, entities and bodies to be subject to a measure freezing funds and economic resources (Annex I to Regulation (EU) No 269/2014 on restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty or independence of Ukraine). These entries were included in Monaco in the national list by decision of the Minister of State no. 2025-15 of 24 February 2025, pursuant to Sovereign Order no. 8.664 of 26 May 2021, as amended.

SECTORAL RESTRICTIVE MEASURES

  1. Restrictions on legal persons, entities or bodies established outside Russia using the financial messaging system of the Central Bank of Russia. Extension of restrictive measures regarding the provision of specialised financial messaging services to certain Russian credit institutions or entities subscribing to financial messaging services or to Russian subsidiaries of third-country credit institutions relevant for the Russian financial and banking system.
  2. Extension of the prohibition on transactions to financial or credit institutions and entities providing crypto-asset services in support of transactions involving any listed vessel; Restrictions on listed legal persons, entities and bodies established outside the EU that are financial or credit institutions or entities providing crypto-asset services or involved in transactions that facilitate, directly or indirectly, the circumvention of the prohibitions.
  3. Reinforcement of the ban on the export of dual-use goods and technologies, as well as goods and technologies likely to contribute to the technological reinforcement of the Russian defence and security sector. Restrictions on the export of software related to oil and gas exploration. A ban on the supply of goods, technologies and services for the completion of Russian LNG and crude oil projects.
  4. Extension of the list of items that could contribute to Russia's military and technological reinforcement or to the development of its defence and security sector, which contribute to the development or production of its military systems (chemical precursors for riot control agents, software linked to computer numerically controlled (CNC) machine tools, chromium compounds, controllers used to guide UAVs, etc.).
  5. Restrictions on the export of goods that could help strengthen Russia's industrial capacity (chemicals, certain plastics and rubber; anti-circumvention measure to extend the list of goods and technologies subject to a ban on transit through Russian territory.
  6. Restrictions on imports of primary aluminium, which generates significant revenue for Russia.
  7. Ban on the temporary storage of Russian crude oil and petroleum products in the EU, regardless of the purchase price of the oil and the final destination of these products.
  8. Ban on entities established in the EU before 8 April 2022 and already operating as road transport companies from making any changes to their capital structure that would increase the percentage share held by a Russian natural or legal person, entity or body, unless this percentage share remains below 25% following the said change.
  9. Ban on imports of Russian LNG through EU LNG terminals not connected to the interconnected natural gas network, unless an exemption is granted.
  10. Imports of rough diamonds must be accompanied by a certificate clearly indicating the country or countries of origin of extraction.
  11. Ban on the provision of construction services, including civil engineering works.
  12. Prohibition on the sale, supply, transfer or export, directly or indirectly, of software for business management, industrial design and manufacturing to the Russian government or to legal persons, entities or bodies established in Russia. Prohibition on the sale, licensing or other transfer of intellectual property rights or trade secrets relating to such software.
  13. Ban on all transactions with ports, locks and airports in Russia that are used for the transfer to Russia of UAVs or missiles, or related technologies or their components, or for the circumvention of oil price caps by vessels engaged in illegal and high-risk shipping practices or other restrictive measures.
  14. Implementation of due diligence mechanisms by EU operators selling, supplying, transferring or exporting sensitive goods to third countries other than the listed partner countries, capable of detecting and assessing the risks of re-export to Russia and mitigating those risks.
  15. Restrictive measures to suspend the broadcasting activities of certain media in the EU or towards the EU.

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