Review on the 16th EU Package of Sanctions Against Russia

While President Trump is trying to achieve a peace agreement with Russia regarding Ukraine through “muscular diplomacy”, French President Emmanuel Macron, who spoke on behalf of the EU at a joint press conference on 24 February 2025 at the White House, stressed the need to provide “security guarantees” to Ukraine.

In parallel, the European Council has just adopted the 16^th Russia sanctions package on 24 February 2025 exactly 4 years after the beginning of the invasion of Ukraine by Russia.

This 16th package targets systemically important sectors of the Russian economy such as energy, trade, transport, infrastructure and certain financial services (e.g. 13 financial institutions specialized in financial messaging services are added to the list).

Dual-use export restrictions have also been extended to additional items in order to cut Russia’s access to key technologies.

The package adds further measures aimed at tackling circumvention of EU sanctions and certain provisions are now also mirrored in the Belarus sanctions regime.

This 16^th sanction package also imposes targeted export restrictions on 53 new companies supporting Russia’s military-industrial complex or engaged in sanctions circumvention. This includes 34 companies in countries other than Russia.

In addition, the 16^th wave of sanctions adds listed persons and entities to the frozen asset list including 74 additional vessels which are part of the shadow fleet of Russia or which contribute to Russia’s energy revenues.

The latest package of EU sanctions also provides for another new criterion for listing individuals and entities that are part of Russia’s military and industrial complex, support it, or benefit from it. It details the obligations, which apply both to EU persons and entities, imposed on them so they can make their best efforts to prevent the undermining of the restrictive measures.

Moreover, the EU has updated and strengthened its sanctions regimes concerning Crimea and Sevastopol, and the non-government-controlled areas of Donetsk, Kherson, Luhansk and Zaporizhzhia oblasts.

Our France based team remains available should you need legal advice adapted to your specific needs.

This summary is provided for informational purposes only and is not intended to constitute legal advice nor does it create an attorney-client relationship with Rimon, P.C. or its affiliates.

Stephanie De Giovanni is an accomplished international and litigation attorney with over 20 years of experience practicing commercial law and complex commercial litigation. Ms. De Giovanni has a background in international distribution law and spent her early career focused on commercial agency and the setting-up of distribution networks. For the duration of her legal career, she has dealt with termination issues and the disputes arising therefrom. Read more here.

Elia El Kouh is an Associate in Rimon’s Paris office. Ms. El Kouh focuses on international law, commercial law, litigation, and compliance. She has prior experience in law firms in Paris and Morroco advising clients on matters relating to commercial law, criminal business law, economic law, contract law, litigation, and arbitration.  Ms. El Kouh also has experience serving as in-house counsel for the legal department of an automotive manufacturer, where she advised on issues relating to contract law, competition law, distribution, and consumer law. Read more here.