Anti-Circumvention in EU's 18th Sanctions Package
- Madni Laghari
- Jul 24
- 4 min read
Updated: Jul 25
The EU's catch-all provision got an upgrade! It targets indirect exports and circumvention like never before. Are you prepared to comply?
In July 2025, the European Union escalated its sanctions strategy by introducing a sweeping anti-circumvention measure in its 18th sanctions package. This isn't just another technical tweak — it's a strategic pivot that significantly expands the scope of export controls. If you’re involved in EU export control, sanctions compliance, or global trade operations, this change could reshape your risk exposure overnight.
Key Questions Covered in This Blog
What is the new "catch-all provision" introduced in the 18th EU sanctions package?
Why was it introduced now, and what political context supports it?
Which goods and technologies does it cover?
How does this provision empower national authorities?
What should exporters and compliance professionals do now?
"The EU’s catch-all provision is not just an enforcement tool — it’s a political signal that circumvention won’t be tolerated. Exporters must shift from reactive compliance to proactive risk management."Arne Mielken, Managing Director, Customs Manager Ltd
Abbreviations Used In This Blog
CFSP – Common Foreign and Security PolicyOJ – Official Journal of the European UnionAnnex VII – A list of dual-use and sensitive items subject to indirect export controls under Regulation (EU) No 833/2014
What is the redrafted "catch-all provision" in the 18th EU sanctions package?
The EU's 18th sanctions package introduces an administrative mechanism — known informally as the "catch-all provision" — designed to address indirect exports of Annex VII items via third countries. It empowers Member State authorities to require prior authorisation for the export of sensitive goods when there's credible risk that they might ultimately end up in Russia.
This mechanism enables authorities to scrutinise shipments more closely and intervene before a breach occurs, rather than responding only after sanctions have been violated.
Why was it introduced now, and what political context supports it?
The EU has made stopping circumvention one of its top political priorities. After 17 rounds of restrictive measures, authorities were still seeing dual-use and high-risk items — such as electronics, drones, and semiconductors — finding their way into Russia through countries like Turkey, the UAE, and Central Asian states.
The new catch-all rule is explicitly aimed at disrupting these supply chains.
According to Decision (CFSP) 2025/1495, the provision ensures that Member States can act preventively where there’s a reasonable suspicion of diversion to Russia.
Which goods and technologies does it cover?
This measure applies to goods and technologies listed in Annex VII of Regulation (EU) No 833/2014 — many of which are dual-use or military-adaptable. These include electronics, aircraft parts, machine tools, sensors, navigation equipment, and software.
Even when exported under the guise of civilian use, these items can contribute to Russia’s military and technological capabilities. That’s precisely the risk this provision was built to address.
How does this provision empower national authorities?
Authorities in each EU Member State can now block or delay shipments where the end-use or end-destination raises red flags. If there is sufficient reason to suspect that the exported items might be used by Russian entities, or even reach Russia via third countries, they can require a licence or prohibit the export entirely.
Importantly, this is not a new blanket ban. It’s a targeted, flexible tool for proactive enforcement.
What should exporters and compliance professionals do now?
You must treat the catch-all rule as a core part of your export control programme.
This means:
1. Enhancing due diligence: Go beyond end-user certificates. Scrutinise the entire supply chain — intermediaries, shippers, final destinations.
2. Updating risk assessments: Flag third-country exports involving Annex VII goods for manual review. Maintain evidence for all clearance decisions.
3. Training your teams: Ensure staff can recognise circumvention red flags and know when to escalate.
4. Engaging with national authorities: When in doubt, consult your licensing agency. Better to delay than risk enforcement.
5. Keeping detailed records: Log every risk-based decision — this is your shield if enforcement comes knocking.
Arne’s Takeaway
The EU has made it clear: export controls aren't just about direct trade anymore. Circumvention via third countries is now a central compliance concern. If you're moving Annex VII items and aren’t prepared to assess diversion risk proactively, you’re already exposed.
Start integrating this provision today. Not tomorrow.
Expert Recommendations
Conduct a circumvention audit of your export routes and third-country customers
Add a circumvention clause to your end-use declarations
Subscribe to catch-all notifications from your national authority
Consider software that flags circumvention risk patterns in customs data
Sources & Further Information
Regulation (EU) No 833/2014 – Consolidated
Sign up for updates: www.customsmanager.info
Disclaimer
This blog is for educational and informational purposes only and does not constitute legal advice. Consult a qualified legal professional for advice on specific cases.
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