EU: 18th Sanctions Package Against Russia
- Arne Mielken
- Jul 25
- 8 min read
on 18 July 2025 the EU adopted Sanctions Package 18. It goes after Nord Stream, banks, oil and Russian trade backers + Video - with a reduced oil cap.
The European Union has just adopted its 18th package of sanctions against Russia, intensifying pressure on Moscow’s war economy. The headline measure: a reduction of the Russian oil price cap to $47.60 per barrel, down from the previous G7-agreed level of $60. This marks a new phase in the EU’s sanctions policy—one defined less by global coordination, and more by unilateral resolve.
Key Questions Covered in This Blog
Part I: New Listings
What companies, ships, and banks are to be newly sanctioned?
What third-country entities are listed?
Part II: New Trade Measures
3. What is the EU doing to shut down Nord Stream 1 and 2 permanently?
4. What changes to the oil price cap are proposed?
5. What new export bans are to be put in place, and which sectors are affected?
Part III: Other Measures & Outlook
6. Is the EU preparing secondary sanctions?
7. What are the chances this package gets approved?
8. How might the US, especially under Trump, respond?
Why the delay and what is different now?
"Strength is the only language Russia understands. The EU is finally speaking it fluently."Arne Mielken, Managing Director, Customs Manager Ltd
Video
Downloads & Links
Statement by Ursula Von der Leyen, EU Commission President
Statement by VP Kallas
Abbreviations Used In This Blog
EU: European Union
OFAC: Office of Foreign Assets Control (US)
OFSI: Office of Financial Sanctions Implementation (UK)
SWIFT: Society for Worldwide Interbank Financial Telecommunication
G7: Group of Seven major economies
RDIF: Russian Direct Investment Fund
Fancy a Call?Need clarity on how these new measures could impact your compliance obligations? Book a free expert call today: www.customsmanager.org -> Book Expert Call |
I New Listings Proposed
What ships will be newly sanctioned ?
To better enforce the oil cap, on top of the 342 vessels already listed, the EU plans to list additional 77 vessels that are part of the Russian shadow fleet. These vessels are a means to evade sanctions.
"With our listings, we severely constrain Russia's options to export its oil through a shadow fleet".
More details
In the context of the sanctions against Russia and Belarus, there are designated specific vessels in Annex XLII of Council Regulation (EU) 833/2014.
There are different criteria for when a ship will be listed.
The annex includes vessels that:
(a) transport goods and technology used in the defence and security sector, from or to Russia, for use in Russia or for Russia’s warfare in Ukraine;(b) transport crude oil or petroleum products, as listed in Annex XXV, that originate in Russia or are exported from Russia while practicing irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly resolution A.1192(33);(c) are operated in such a way as to contribute or support actions or policies for the exploitation, development or expansion of the energy sector in Russia, including energy infrastructure;(d) are operated in such a way as to contribute or support actions or policies which undermine or threaten the economic subsistence or food security of Ukraine, such as the transport of stolen Ukrainian grain, or the preservation of cultural heritage of Ukraine, such as the transport of stolen Ukrainian cultural goods;(e) transport goods originating in or exported from the Union listed in Annexes XI, XX and XXIII of this Regulation, or goods originating in Russia or exported from Russia and imported into the Union listed in Annex XXI of this Regulation and thereby enabling Russia’s actions destabilising the situation in Ukraine;(f) are operated in such a way as to facilitate or engage in the violation or circumvention or otherwise significantly frustrate the provisions of this Regulation or of Regulations (EU) No 269/2014, (EU) No 692/2014 or (EU) 2022/263; or(g) are owned, chartered or operated by natural or legal persons, entities or bodies listed in Annex I to Regulation (EU) No 269/2014, are otherwise used in the name of, on behalf of, in relation with or for the benefit of such persons.
In relation to a vessel listed in Annex XLII, the Danish Maritime Authority is the competent authority for the purposes of Article 3(1)(c), Article 3(1)(d), Article 3(1)(e), Article 3(1)(g) and Article 3(1)(h). In relation to ships listed in Annex XLII, it is generally prohibited, directly or indirectly, to:
(a) provide access to ports, anchorage zones and locks in the territory of the Union, and for such a vessel to access them;
(b) import into the Union, purchase or transfer such a vessel;(c) sell, supply, including charter, or export such a vessel;(d) operate or crew such a vessel;(e) provide flag registration for the benefit of such a vessel;(f) provide financing and financial assistance, including insurance, as well as brokering services, including ship brokering;(g) provide technical assistance and other services including bunkering, ship supply services, crew changes services, cargo loading and discharge services, fendering and tug services to the benefit of such a vessel; and(h) engage in ship-to-ship transfers or any other transfer of cargo with, or procure any services from, such a vessel.
It should be noted that a number of exceptions apply - including where there is a danger to safety or the environment, and pilotage services may continue to be provided in the interests of safety at sea.
The prohibitions do not apply if a vessel listed in Annex XLII is in need of assistance in seeking a place of refuge, a place of refuge for reasons of safety at sea, to save lives at sea, for humanitarian purposes or for the immediate prevention or mitigation of an incident which is likely to have a serious and significant impact on human health and safety or the environment, or in response to natural disasters, or for the recognition or enforcement of a judgment or arbitral award rendered in a Member State.
It should be noted that there may be other restrictions relevant to maritime transport companies. It is the responsibility of companies to comply with any applicable sanctions and to seek legal advice if necessary.
What banking measures will be imposed?
The EU is targeting the Russian banking sector by limiting its ability to raise funding and conduct transactions. The EU proposes
to transform the existing prohibition to use the SWIFT system into a full transaction ban.
to apply such a transaction ban to another 22 Russian banks.
to extend the transaction ban to financial operators in third countries that finance
trade to Russia in circumvention of sanctions.
to sanction the Russian Direct Investment Fund, its subsidiaries and its investment projects.
What third-country entities are listed?
This package includes 22 new companies from countries like China and Belarus that directly or indirectly support Russia's military. These are crucial players in the global supply chain that help fill sanctions-induced gaps. Their inclusion sends a clear message: no more looking the other way if your tech ends up in a Russian missile.
EU Sanctions Against Russia (and Belarus) – ONLINE LIVE TRAINING 💻 Virtual | Runs regularly throughout the year 🚨 Understand sanctions. Stay compliant. Avoid costly mistakes. Unlock essential knowledge in our focused online training on EU sanctions targeting Russia and Belarus. This practical session is designed to help you: ✅ Master the core rules and legal framework ✅ Apply sanctions screening and due diligence in real life ✅ Stay ahead of the latest regulatory updates ✅ Avoid enforcement risks and reputational damage 🎯 Perfect for customs managers, compliance officers, import/export professionals, and trade advisors. 📌 Spots fill up fast – secure your place now or book a future session.👉 www.customsmanager.org/events |
II New Trade Measures
What is the EU planning to shut down Nord Stream 1 and 2 permanently?
"For the first time, we propose a transaction ban for Nord Stream 1 and Nord Stream 2. This means that no EU operator will be able to engage directly or indirectly in any transactions regarding the Nord Stream pipelines. There is no return to the past". Ursual Von der Leyen
For the first time, the EU proposes a total ban on transactions related to Nord Stream 1 and 2. This would legally block any EU-based firm from offering services, financing, or maintenance for the pipelines. In essence, the pipelines become untouchable. This move also silences any chatter about reactivation, especially among certain German political circles.
What changes to the oil price cap are proposed?
The EU wants to lower the oil price cap from $60 to $45 per barrel. This reflects today's market reality—Brent crude trades at $67—and aims to further reduce Russia’s revenue. But the real issue is enforcement. Russia’s shadow fleet has made the current cap almost toothless. Including these vessels in sanctions lists is a clear effort to plug that hole.
What new export bans are proposed, and which sectors are affected?
The EU proposes export bans worth over €2.5 billion, covering machinery, metals, plastics, and chemicals used in industrial production. This includes many dual-use items, which can be transformed into drone parts or munitions. The intent is to cripple Russia's domestic weapons production by targeting its industrial base.
III. Other Measures & Outlook
Improving the application of sanctions
Fourth and final, the EU wants the sanctions to be better applied and respected. That is why they widen the scope of the transaction ban that already exists.
Is the EU preparing secondary sanctions?
Yes. A striking inclusion in this package is a transaction ban on financial operators in third countries helping Russia bypass sanctions. While not labelled as "secondary sanctions," it has similar teeth. It’s a historic first for Brussels, whose previous aversion to extraterritorial reach is well-documented. If adopted, compliance officers worldwide must brace for impact.
What are the chances this package gets approved?
Expect resistance. Hungary and Slovakia have historically slowed or diluted EU sanctions. However, 17 prior packages got through, even if some took all-night negotiations. With the G7 Summit looming, political momentum is on the Commission’s side—especially with support from Germany’s Chancellor Merz, who’s backed the Nord Stream ban.
How might the US, especially under Trump, respond?
The Trump factor adds unpredictability. While Congress may applaud the package (especially given Senator Graham’s bill), Trump’s personal stance is unclear. EU leaders are expected to pitch this as aligning with US objectives, hoping to avoid friction. For now, Washington is likely to appreciate Europe stepping up—but we’ll see how that holds up in the Oval Office.
Why the delay and what is diffent now?
Arne’s Takeaway
This package aims not just to sanction Russia—but to outflank its evasive tactics. If passed, it will fundamentally change EU sanctions enforcement and raise the stakes for third-country enablers. Get your compliance protocols ready.
Expert Recommendations
Screen your business partners again. New listings mean new risks.
Review your trade finance exposure. Indirect transactions may now be banned.
Audit your supply chain. Focus on dual-use goods, raw materials, and components.
Reinforce oil-related due diligence. The shadow fleet crackdown is real.
Monitor G7 decisions. They will shape the enforcement landscape.
Stay ahead by signing up for email alerts and premium resources at www.customsmanager.info
Disclaimer
This blog is intended for educational and informational purposes only and does not constitute legal advice. Always consult qualified legal counsel when dealing with sanctions and export control matters.
Comments