Beyond the new economic and individual measures targeting Russia, the 16th package also included further sanctions on Belarus and new actions concerning Crimea and Sevastopol, as well as the non-government controlled areas of Ukraine in the oblasts of Donetsk, Kherson, Luhansk and Zaporizhzhia, The following Insight focuses on the measures targeting Russia. A separate Insight will cover these other measures announced with the 16th package. 

The 16^th package of sanctions against Russia were implemented through two Council Decisions, as well as two Council Regulations and one Council Implementing Regulations. We discuss these measures below.

Takeaways:

• The EU confirmed its sanctions policy course vis-à-vis Russia, adopting a significant round of measures, comprising individual actions, sectoral measures, compliance enhancements while increasing the global reach of EU sanctions through new tools. As the Council noted in relation to the suspension of certain broadcasting activities: “[t]hose measures should be maintained until the war of aggression against Ukraine is put to an end, and until Russia and those media outlets cease to conduct propaganda actions against the Union and its Member States.”

• Through these new measures, the EU targeted additional sectors of the Russian economy (aluminium industry and construction sectors among others), continuing to crack down on circumvention through various measures, including information sharing, a new role of the FIUs and the listing of new entities subject to enhanced export controls due to their circumvention activities.

• The Russian industry as a whole is further targeted in order to limit its contributions to Russia’s war efforts by putting in place restrictions. A new listing criterion was added targeting persons forming part of, supporting, materially or financially, or benefitting from Russia’s military and industrial complex. Export controls targeting (i) dual-use items, as well as (ii) advanced technology and (ii) goods contributing to the enhancement of Russian industrial capacities have also been strengthened. 

• The EU continues to respond to Russia’s “shadow fleet” activity in a more targeted manner through (i) listing non-Russian fleets as well as (ii) allowing the listing of financial service providers that are facilitating transactions on behalf of said shadow fleets, and (iii) adding a new 269/2014 listing criterion for persons owning, controlling, managing, operating or providing services to these vessels. 

• Compliance requirements and expectations are heightened through, among other things, the extension of the “best efforts” requirement to regulation 269/2014, the extension of the obligation to implement a risk-based compliance programme to goods as listed in Annex XLVIII, or otherwise tightening select derogations. EU operators are further protected through new right of actions and forum selection principles in litigation cases involving EU sanctions against Russia.  

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1. Individual Restrictive Measures 

New Designations & Listing Criteria 

• Russia’s war efforts – The Council added 83 additional listings, including 48 individuals and 35 entities, to its restricted parties list through Council Regulation 2025/389. The newly-listed persons and entities are subject to asset freezes, as well as travel bans for individuals.
  
  • Among the 83 listings, two individuals from North Korea for their role in coordinating North Korean soldiers and s tactics deployed on the battlefield in Ukraine were sanctioned. The EU also designated one Chinese entity and one Chinese individual, namely a PRC-based firm producing satellite imagery and its chairman. 
  • In total, as of 24 February 2025, 1,927 individuals and 542 entities were designated under the Regulation 269/2014.

• Two further criteria for listing – Two additional listing criteria were introduced, allowing the Council to expand its designations targets: 
  
  • The first criterion concerns persons owning, controlling, managing, operating or providing services to certain vessels transporting Russian crude oil or petroleum products, also known as the “shadow fleet”. 
  • The second criterion concerns persons forming part of, supporting, materially or financially, or benefitting from Russia’s military and industrial complex.

Derogations  

• Addition of new persons to existing derogations – The Council introduced new derogations for the following persons: 
  
  • Tikhomirov Scientific Research Institute of Instrument Engineering, for goods and services related to the Budapest metro delivered in 2018; 
  • Alexander Dmitrievich Pumpyansky, Andrey Igorevich Melnichenko and Viktor Filippovich Rashnikov, for funds or economic resources necessary for the sale and transfer by 30 June 2025 of proprietary rights they own in an entity established in the EU, provided the proceeds are frozen.

• Extension of existing derogations – The Council extended the scope of derogations for payments involving entities owned or controlled by the below-mentioned sanctioned entities, including when the payment is sent from a third country or from the Union: 
  
  • The existing derogation for funds frozen due to the involvement of sanctioned entities acting as intermediary banks during a transfer of those funds from the Russian Federation to the Union; and
  • The existing derogation for funds frozen due to the involvement of sanctioned entities during a transfer of those funds from the Russian Federation to the Union.    

2. Sectoral Sanctions

Financial Sector

• SWIFT ban – The Council added 13 new financial institutions to Annex XIV to Regulation, including Uralsib Bank, National Reserve Bank, and Primsotsbank. These banks will be cut off for SWIFT as of 17 March 2025.  

• Transaction ban (Annex XLV) – The Council further extended the transaction ban prohibiting credit institutions, financial institutions and entities providing crypto assets services to deal with entities listed in Annex XLV (still currently empty):
  
  • Supporting transactions in relation to any listed vessel listed in Annex XLII to Regulation 833/2014 (thus frustrating the prohibition set out in Article 3s of Regulation 833/2014), which aims to limit Russia’s ability to wage war against Ukraine; or 
  • Circumventing the prohibition targeting crude oil or petroleum products as listed in Annex XXV (Article 3n of Regulation 833/2014). 

• Transaction ban against non-Russian banks using SPFS – 
  
  • First designations – The Council added “Bank BelVEB”, “Belgazprombank” and “VTB Bank (PJSC) Shanghai Branch”, established outside of Russia, to the formerly empty Annex XLIV to Regulation 833/2014, due to their use of the Financial Messaging System of the Central Bank of Russia (SPFS) system to circumvent EU sanctions. It is therefore prohibited for EU operators to engage, directly or indirectly, in any transaction with these entities.  
  • New Derogation – The Council introduced a derogation allowing the execution of transactions with the entities included in Annex XLIV to Regulation 833/2014 that are necessary for (i) the repayment of guarantees granted by a Member State, (ii) divestment from Russia or the wind-down of business activities in Russia, (iii) or execution of contracts concluded before 25 February 2025 until 26 August 2025 or until their expiry date, whichever is earlier for beneficiaries located in the EU.

• Deposit – The Council adopted a new derogation for the acceptance of deposits otherwise restricted (i.e., exceeding EUR 100 000) for operations necessary for the restructuring or liquidation of a legal person associated with a sanctioned entity listed in Annex I to Regulation 269/2014.

Export/Import-Related Restrictions

• New import ban on Russian aluminium – The Council introduced further restrictions on the import of unwrought aluminium (CN code: 7601), in addition to the existing imports ban on processed aluminium goods (Annex XXI to Regulation 833/2014). ‍
  • Exemptions – The following quota mechanism has been introduced for the aluminium import ban:
    • The prohibition does not apply if the import of aluminium into the Union is necessary, provided it remains within 275,000 metric tonnes between 25 February 2025 and 26 February 2026.
    • The prohibition does not apply either to the execution from 26 February 2026 until 31 December 2026 of contracts concluded before 25 February 2025 provided it remains within 50,000 metric tonnes.

• Dual-use (Annex I to Regulation 2021/821) and advanced technology items (Annex VII to Regulation 833/2014) 
  • Addition of new items - The prohibition on the export of advanced goods and technology listed in Annex VII to Regulation 833/2014 has been further strengthened to cover chemical precursors to riot control agents (X.A.VIII.020(h)), software related to computer numerical control (CNC) machines (X.D.X.007), chromium compounds (CN codes: 2610 00, 2819 10, 2819 90, 8112 21, 8112 22 and 8112 29) and controllers used to guide UAVs (X.A.III.101 (i)).
  • ‍Limitation of existing exemptions – 
    • The Council removed the exemption allowing the export of dual-use items for personal use of natural persons travelling to Russia or members of their immediate families travelling with them.
    • The Council also limited the exemption to export of dual-use items intended for medical or pharmaceutical purposes, provided that they are not listed in Annex XL to this Regulation (instead of all medical or pharmaceutical purposes previously). 
  • ‍Strengthening of existing derogations – 
    • The Council removed the derogation ground for cooperation between the Union, the governments of Member States and the government of Russia in purely civilian matters.
    • The Council also moved the transactions intended for (i) software updates, (ii) consumer communication devices, and (iii) medical or pharmaceutical purposes, provided that they are listed in Annex XL to this Regulation from being exempted to being subject to derogation. 
    • National Competent Authorities (“NCAs”) are now prohibited from granting authorizations for transactions related to the aviation or the space industry   whether or not they are intended for intergovernmental cooperation in space programmes (which was previously exempted).  
  • ‍Strengthening of the restrictions targeting entities subject to enhanced restrictions in relation to dual-use and advanced technology items (Annex IV to Regulation 833/2014)  ‍
    • New designations – The Council added 53 new entities to the list of natural or legal persons, entities and bodies set out in Annex IV. 
      • Among the listed entities, 1 is in Singapore, 2 are in India, 25 are in PRC and Hong Kong, 3 are in UAE, 1 in Turkey, 1 in Uzbekistan, and 2 in Kazakhstan. As expressly mentioned by the Council in Recital 11 of the Regulation 2025/395, these third countries are considered to indirectly contribute to Russia’s military and technological enhancement through the circumvention of export restrictions, including on unmanned aerial vehicles (UAVs) or missiles.‍
    • Strengthening of the prohibition – 
      • It is now strictly prohibited to directly or indirectly provide technical assistance, brokering services or other services, financing or financial assistance and to sell, license or transfer intellectual property rights or trade secrets related to these controlled items to persons listed in Annex IV. 
      • The carve out authorizing transactions with these listed persons is now limited to the sell, supply, transfer, export, or the provision of technical or financial assistance related to these controlled items, provided it is (i) for the protection of human health and safety, or (ii) related to former contracts.  
  • ‍Sharing of information – The Council specified that the existing obligation for the NCAs and the Commission to share the relevant information on the application of the restrictive measures targeting these above controlled items, shall be made “ without delay”.
• ‍Goods which could contribute to the enhancement of Russian industrial capacities (Annex XXIII and Annex XXXVII to Regulation 833/2014)‍
  • ‍Additional export ban on industrial goods –  ‍
    • Annex XXIII - The Council added additional export restrictions on additional industrial goods, specifically targeting minerals, chemicals, steel, glass materials, and fireworks, with special military significance. These amendments can be found below:‍
      • Extension from specific HS codes to general HS Headings‍
        • 2518 (instead of 2518 20)
        • 2519 (instead of 2519 10)
        • 2520 (instead of 2520 10)
        • 2834 (instead of 2834 10)
        • 4811 (instead of 4811 10, 4811 51, 4811 59, 4811 60, and 4811 90)
        • 6814 (instead of 6814 90)
        • 7007 (instead of 7007 11 and 7007 29)‍
      • New listed CN codes‍
        • 2615
        • 3604
        • 3605
        • 3606
    • ‍Annex XXXVII – The Council further extended the list of goods and technology subject to the prohibition on transit via the territory of Russia.
      • ‍New listed CN codes‍
        • 3811 90
        • 3815 12
        • 7219 21
        • 7225 40
        • 7304 29
        • 7311 00
        • 8425 11
        • 8456 30
        • 8460
        • 8466 20
        • 8467 29
        • 8474 39
        • 8482 99
        • 8483 50
        • 8511 10
        • 8515 19
        • 8543 30
        • 8708 99
        • 9024
  • ‍New exemption – The prohibition to export these controlled items does not apply to the goods falling under the CN codes listed in Annex XXIIID (new Annex listing items under HS Chapters 25, 26, 28, 36, 48, 68, 70, and 73) until 26 May 2025 for contracts concluded before 25 February 2025.
  • ‍Extended derogation –NCAs may now authorise the export of:
    • Safety glass falling under the CN code 7007 19 80 after having determined that such goods or the provision of related technical or financial assistance are necessary for personal household use of natural persons in Russia;
    • Goods falling under the CN code 2920 90 (Esters of inorganic acids of non-metals) and 3920 62 (plates, sheets, film, foil and strip, of non-cellular polyethylene terephthalate); and 
    • Goods falling under CN codes 8517 62 (Machines for the reception, conversion and transmission or regeneration of voice, images or other data) and 8523 52 (smart cards) provided that they are intended for civilian non-publicly available electronic communications networks which are not the property of an entity that is publicly controlled or with over 50 % public ownership.
• ‍Amendment to the diamonds ban – 
  • ‍Certificate – The imports of rough diamonds shall be accompanied by a certificate pursuant to Council Regulation (EC) No 2368/2002 in which the country of mining origin or the countries of mining origin are clearly stated.
  • ‍Traceability – The date of entry into force of the requirement to provide traceability-based evidence for imports of polished/worked diamonds falling under the CN code 7102 39 00, was postponed to 1 January 2026 (instead of 1 March 2025).

Aviation Sector

• ‍New restrictions on drones – 
  • The exemption laid down to land in, take off from or overfly the territory of the Union for certain Russian aircraft is now only limited to “manned aircraft”, de facto excluding the drones. 
  • In parallel, the Council introduced the need for an authorisation by NCAs to allow the landing in, taking off from and overflying the territory of the Union for certain drone operations.‍
• Domestic flights – 
  • The Council extended the flight ban to listed air carriers operating domestic flights within Russia or selling, supplying, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology (as listed under Article 3c(1) of Regulation 833/2014) to a Russian air carrier or for flights within Russia (as listed in Annex XLVI to Regulation 833/2014 – the Annex is empty as of today), as well as to any entity owned or controlled by such air carrier.

Other transports-related sectors 

• ‍Transaction ban on Russian ports and locks and airports –  ‍
  • New transaction ban – It is now prohibited to deal with any ports and locks listed in Part A of Annex XLVII or airports listed in Part B of Annex XLVII to Regulation 833/2014 (used for the transfer of UAVs or missiles or related technology or components thereof to Russia, or for the circumvention of the Oil Price Cap by vessels practicing irregular and high-risk shipping practices or of other restrictive measures).  ‍
    • Designations – The Moscow airports Vnukovo and Zhukovsky are included in the ban as well as the airports of Begishevo, Perm, Koltsovo  and Pskov. In addition, it is also prohibited to enter into direct and indirect transactions with the Makhachkala port on the Caspian Sea, the Volga port Astrakhan, the sea ports Ust-Luga and Primorsk on the Baltic Sea and Novorossiysk on the Black Sea.‍
    • Exemptions – The Council introduced a variety of exemptions notably for (i)  human health and safety protection, (ii) the import or transport of Russia natural gas, titanium, aluminium, copper, nickel, palladium and iron ore, etc.  
• ‍Budapest metro line – The existing derogation for the import of controlled items listed in Annex XXI to Regulation 833/2014 related to the Budapest metro line has been extended to new CN codes (7019, 8415, 8483, 8518 and 8539). 
• ‍Road transport undertaking – In order to minimise the risk of circumvention of restrictive measures, it is now prohibited for entities established in the Union before 8 April 2022 and already operating as road transport undertakings to make any changes to their capital structure that would increase the percentage share owned by a Russian natural or legal person, entity or body, unless that percentage share remains below 25% following such a change.

Restricted Services 

• ‍Construction services – With the goal of preventing EU operators from supporting the development of Russia’s infrastructure, a prohibition on the provision of construction services was put in place. This prohibition also includes civil engineering works. 
• ‍IP rights or trade secrets related to management software – It is now prohibited to sell, license or transfer IP rights or trade secrets related to software for the management of enterprises and software for industrial design and manufacture as listed in Annex XXXIX to Regulation 833/2014 to the Government of Russia or Russian entities. 
• ‍New derogation for consular or diplomatic representation – NCAs may now authorise the provision of the listed restricted services (under article 5n to Regulation 833/2014) after having determined that they are strictly necessary for the functioning of a consular or diplomatic representation of the Russian Federation located in a Member State. 

Energy Sector

• ‍New Russian LNG-related derogation – The Council introduced a new derogation that can be granted by a Member State that is not connected to the interconnected natural gas system when (i) the LNG is purchased, imported or transferred from a terminal located in another Member State that is connected to the interconnected natural gas system (ii) in order to ensure its energy supply.   
• ‍Extension of export prohibition related to Russian crude oil project – The prohibition to provide goods, technology and services for the completion of Russian LNG projects was extended to the completion of crude oil projects in Russia, such as the Vostok oil project. ‍
  • Wind down periods –
    • This new prohibition related to Russian crude oil projects shall be without prejudice to the execution until 26 May 2025 of contracts concluded before 25 February 2025; 
    • This new prohibition shall not apply to oil production projects where regular commercial production was established prior to 25 February 2025.
• ‍New prohibition targeting the temporary storage for Russian crude oil and petroleum products – In order to inflict additional costs on the transport of Russian oil thereby reducing Russian revenues, the Council adopted a new prohibition to temporary store and place under the free zone procedure in the Union Russian crude oil or petroleum products as listed in Annex XXV to Regulation 833/2014, if they originate in Russia or are exported from Russia. ‍
  • Exemptions – This new prohibition does not apply to:
    • Goods already in the Union on 25 February 2025 until 26 May 2025; 
    • Member States that benefit from the exemptions in Article 3m(3), point (d), and in Article 3m(4); and
    • Seaborne crude oil and petroleum products listed in Annex XXV where those goods originate in a third country and are only being loaded in, departing from or transiting through Russia, provided that both the origin and the owner of those goods are non-Russian.
• ‍New designations of vessels contributing to Russia’s energy revenues (Annex XLII to Regulation 833/2014) – 
  • 74 additional vessels have been added to the list of those subject to a port access ban and ban on provision of a broad range of services related to maritime transport. These listing are imposed with the aim of curbing circumvention through the “shadow fleet”.
    • ‍New exemption – The prohibitions to deal with these vessels do not apply for the purposes of an investigation into infringements of the provisions of this regulation or into other illicit activity.
• ‍New exemption of reloading services – Reloading services for the purposes of transshipment operations of Russian LNG (CN code 2711 11 00) are now allowed if necessary for its transport between ports of the same Member State, including from the mainland of a Member State to its outermost regions. The otherwise prohibition on reloading services should indeed not affect imports into the Union or the security of supply of Member States.
• ‍New export ban on software – In order to further restrict Russia’s oil and gas exploration and production capacities, it is now prohibited to sell, supply, transfer, export or provide, directly or indirectly, software (as listed in Annex II to Regulation 833/2014) in or for use in Russia. 
  • ‍Wind down period – It is allowed to provide software that is necessary for the execution until 26 May 2025 of contracts concluded before 25 February 2025. 
• ‍New specific derogations – ‍
  • Druzhba pipeline derogation – The Council introduced a new derogation for the import of certain controlled items listed in Annex XXI to Regulation 833/2014 (CN codes 9026, 9027 and 9031) for the purposes of maintenance, repair or the periodic certification of primary and secondary crude oil measuring points on the Druzhba pipeline into the Union, under certain strict conditions.
    • The Council also introduced a new derogation of the export of those same goods (falling under CN codes 9026, 9027 and 9031) the importation of which had previously been authorised as per the above derogation. 
  • ‍New derogation for Slovakian/Hungarian petroleum products – As of 25 February 2025, NCAs can authorise the export from Slovakia to Hungary or from Hungary to Slovakia of certain petroleum products as listed in Annex XXXI to Regulation 833/2014, which are obtained from crude oil imported by pipeline, in order to ensure security of supply to those landlocked countries.

Mining Sector 

New derogation – The prohibition related to mining and quarrying activities that yield their highest value from, or have as their primary objective, the production of any of the materials listed in Annex XXX is now subject to derogation (instead of being exempted formerly). 

Media Sector 

Well aware that Russia has engaged in a systematic, international campaign of media manipulation and distortion of facts in order to enhance its strategy of destabilisation of its neighbouring countries and of the Union and its Member States, the Council strengthened the restrictions targeting the Russian media outlets.  

• ‍Suspension of additional broadcast licences – 8 additional media outlets have had their broadcasting licences revoked on the basis that they are viewed to support and justify Russia’s war efforts against Ukraine (Annex XV to Regulation 833/2014).
• ‍Removal from exemption – The export of dual-use items intended for the “temporary export of items for use by news media” is now completely prohibited.
• ‍New exemption – The Council introduced an exemption from the prohibition on the sale, supply, transfer or export to Russia of banknotes denominated in any official currency of a Member State, where it is necessary for use in civil society and media activities that directly promote democracy, human rights or the rule of law in Russia under certain conditions.

3. Compliance, Enforcement and Litigation

• ‍Extension of the obligation to implement a risk-based compliance programme – Following the introduction, as part of the 14^th package, of the new obligation to implement a risk-based compliance programme for EU operators, including for non-EU entities that they own or control, who sell, supply, transfer or export Common High Priority (“CHP”) items (Annex XL to Regulation 833/2014), the Council extended this obligation to goods as listed in Annex XLVIII (i.e., Generating sets with spark-ignition internal combustion piston engines (CN code: 8502 20) and other switches (CN code: 8536 50)). ‍
  • Wind-down period: This new obligation for goods listed in Annex XLVIII only applies as of 26 May 2025.
• ‍Extension of the “best effort” obligation to asset freeze measures – Mirroring the 14^th package’s “best effort“ obligation set forth in Regulation 833/2014, EU operators are now required to undertake their best efforts to ensure that any entity established outside the EU that they own or control does not participate in activities that undermine the restrictive measures provided for in Regulation 269/2014 (i.e., funds or economic resources are made available to sanctioned persons).
  • As reminded by the Council (See Recital 11 of Regulation 2025/390), while EU sanctions apply only within the jurisdictional limits defined in the relevant Regulation, if EU operators are able to and effectively assert a decisive influence over the conduct of an entity established outside the EU, they may incur responsibility for actions of that entity that undermine the restrictive measures and should use their influence to prevent those actions from occurring. 
• ‍Fight against circumvention – The Council adopted the following measures against circumvention:    ‍
  • Strengthening of information sharing –  ‍
    • Between the Commission and the Member States – The 16^th package explicitly stressed that the Commission and Member States shall inform each other when they detect instances of breach, circumvention and attempts at breach or circumvention of the prohibitions set out in Regulation 269/2014 and Regulation 833/2014, including through the use of crypto-assets.‍
    • With partner countries - The Commission may now exchange with the competent authorities of a partner country (as listed in Annex VIII to Regulation 833/2014) information concerning third-country trade, transactions and operators for the purpose of preventing circumvention of the prohibitions set out in Regulation 269/2014 and Regulation 833/2014.
  • ‍New FIU’s role - The role of the Member States’ Financial Intelligence Units (FIUs) has been reinforced in the fight against circumvention:
    • FIUs now have the ability to exchange information that is relevant for the purposes of the implementation and enforcement of the restrictive measures set out in Regulation 269/2014 and Regulation 833/2014.  
    • “Obliged entities” as set out in Article 2(1) to Directive (EU) 2015/849, are required to report to FIUs all suspicious transactions related to suspected criminal activity linked to the violation of Union restrictive measures. 
    • To avoid double reporting, Member States can decide that those “Obliged entities” are not required to report the same information to competent authorities other than FIUs.
• ‍Extension of the legal basis for compensation claims in Member State courts – In order to ensure the correct implementation of restrictive measures and the adequate protection of EU operators, EU operators shall be entitled to seek, in judicial proceedings compensation in respect of certain direct or indirect damages incurred due to the application of EU restrictive measures or “Russian counter measures”.  
  • ‍Extension of the legal actions scope - As part of the 14^th package, EU operators were entitled to recover, in judicial proceedings before the competent courts of the Member State, any damages, including legal cost, incurred as a consequence of claims lodged with courts in third countries, in connection (i) with any contract or transaction the performance of which has been affected by Regulation 833/2014 and Regulation 269/2014 by any individual or entity targeted by the “No Claims Clause” (Articles 11(1) of these Regulations), or (ii) with the decision pursuant to “Russian counter measures”. 
    • With the 16^th package, this ability is now open, not only to EU entities, but to entities controlled or owned by them.
    • In addition, these damages may be recovered, not only from the persons targeted by the “No Claims Clause”, but also from the entities they own or control.
  • ‍“Russian counter measures” based legal actions – A reference to Russian legislation (Federal Law No. 470-FZ of 4 August 2023) that allows for the corporate rights of foreign holding structures in economically significant Russian organisations to be restricted, as well as for the direct foreign ownership in such organisations to be acquired by Russian beneficiaries and for them to receive dividends directly, was added to the provision in Regulation 833/2014 entitling EU operators to recover certain damaged in judicial proceedings.
  • ‍New forum necessitatis - Furthermore, a forum necessitatis was granted to courts of Member States, in order to ensure the effective implementation of restrictive measures and to remedy possible situations of denial of justice, on an exceptional basis, to rule on a claim for damages brought pursuant to Article 11a of Regulation 269/2014 or Articles 11a or 11b of Regulation 833/2014, where Union law or the law of a Member State does not establish the jurisdiction of a court of any Member State in particular, under certain conditions.

4. Conclusion 

While significant uncertainty has arisen concerning the direction of U.S. sanctions policy as Russia’s war of aggression entered its fourth year, the 16^th package confirmed the course of EU sanctions policy. The latest package signals that the EU intends, as of the date of this Insight, to place its sanctions policy in the long-run. Implementation and enforcement remains the priority, as the codification of the best efforts requirements and expansion of compliance requirements illustrate. Companies, including non-EU operators, should be mindful of the expanded reach out EU sanctions. EU operators should ensure they perform targeted and up-to-date EU-specific risk assessments. Additional guidance is anticipated. The last version of the European Commission FAQs is 14 February 2025.

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