Council of the EU ¦ EU adopts 16th package of economic and individual measures against Russia

EU’s 16th Russia Sanctions Package: What Financial Crime Teams Need to Know Now

The European Union has adopted its 16th sanctions package against Russia, intensifying pressure as the invasion of Ukraine enters its fourth year and tightening controls on circumvention channels that have evolved since early measures were introduced. This package reflects a clear shift from broad trade and financial restrictions toward highly targeted interventions that aim to disrupt specific revenue streams, choke off critical technologies and services used in the war effort, and neutralize evasive tactics across maritime, financial, logistics, energy, and media domains. For compliance teams and financial crime professionals, the package signals a significant step-up in risk exposure across supply chains, shipping, commodity trade finance, technology exports, correspondent banking, and crypto asset services. A standout feature is the aggressive expansion of anti-circumvention tools. The EU has listed 74 additional vessels, bringing the total to 153, focusing on tankers associated with the shadow fleet and those contributing to Russia’s energy revenues. A new listing criterion now targets actors supporting unsafe oil tanker operations, a direct response to the opaque and risky logistics arrangements used to move sanctioned crude. This is coupled with the ability to list third-country carriers engaged in domestic Russian flights or supplying aviation goods for domestic operations—a notable extraterritorial pressure point. Together, these measures heighten sanctions exposure for non-EU operators whose activities facilitate Russian trade, even when routes or operations are nominally domestic within Russia.

On the designations front, the package adds 83 listings — 48 individuals and 35 entities — encompassing actors implicated in military-industrial support, sanctions evasion schemes, crypto exchanges, and maritime operations. The EU has also introduced a broader listing criterion to capture individuals and entities that form part of, support, or benefit from Russia’s military and industrial complex. For screening programs, this widens the scope of potential matches and increases the importance of timely list updates, adverse media monitoring, and network analysis to identify affiliates and beneficial owners.

Trade restrictions have been strengthened in several sensitive areas. The EU has moved beyond processed aluminum bans to a direct import prohibition on Russian primary aluminum. To limit market disruption, a quota of 275,000 tons — around 80% of 2024 import volumes — will be permitted over a 12-month transition, but firms should anticipate a shrinking window for deliveries and stricter scrutiny of certificates of origin and shipping documents. Dual-use and advanced technology controls continue to tighten, with new restrictions on chemical precursors linked to chloropicrin and riot-control agents, software for CNC machine tools, video-game controllers reportedly repurposed to pilot drones, and chromium ores and compounds with military applications. The EU has clarified and narrowed limited derogations for legitimate uses, highlighting a compliance expectation for precise end-use and end-user checks, robust licensing documentation, and verifiable supply-chain attestations. Additional industrial goods — from minerals and chemicals to certain steel, glass materials, and fireworks — have been targeted where authorities identified military significance, closing gaps exploited via innocuous product classifications.

In energy, the EU has closed an important logistical loophole by prohibiting temporary storage and free zone placement of Russian crude and petroleum products at EU ports, even when those cargos comply with the price cap and are destined for third countries. This reduces the utility of European port infrastructure for transshipment and blending activities. The package also widens the ban on goods, technology, and services for project completion: previous prohibitions focusing on Russian LNG projects now extend to crude oil projects such as Vostok, and the software ban now covers oil and gas exploration software. For service providers — engineering, EPC contractors, software vendors, data services — this raises the bar on customer and project due diligence, including identifying project ties within Russia’s upstream sector.

Bastian Schwind-Wagner_Follow "The 16th package deepens the EU’s strategy from broad sanctions toward precise disruption of Russia’s war economy and its evasion architecture. Financial institutions, commodity traders, logistics providers, technology companies, and crypto services must adapt quickly, close remaining gaps in their control frameworks, and prepare for sustained scrutiny. The message is unambiguous: participation in, or tolerance of, circumvention — directly or indirectly — now carries a higher probability of detection, designation, and enforcement."

Transport-related measures expand the EU flight ban framework, enabling the listing of third-country carriers linked to domestic Russian aviation activity or supply chains. On the road transport side, the EU now prevents increases in Russian ownership above 25% in EU undertakings, a structural fix aimed at blocking indirect control or influence that could facilitate logistics circumvention. These changes push compliance teams to examine shareholder structures, voting rights, and control arrangements, not just nominal ownership percentages.

Infrastructure sanctions add a full transaction ban on specific Russian assets, including major airports (Moscow’s Vnukovo and Zhukovsky, plus four regional airports) and key ports across the Caspian, Baltic, and Black Sea regions, such as Astrakhan, Makhachkala, Ust-Luga, Primorsk, and Novorossiysk. The package also prohibits construction services by EU operators in Russia. Logistics firms, insurers, vessel owners, and trade finance providers should adjust routing, port calls, demurrage risk assessments, and policy wordings to reflect these restrictions, while construction and engineering firms must reassess any lingering Russia-facing obligations and exit plans.

Financial sector measures respond to the migration of flows to smaller or less-visible institutions and alternative messaging rails. Thirteen additional financial institutions are now barred from specialized financial messaging services, and three banks face transaction bans due to their use of Russia’s SPFS system to skirt existing sanctions. Importantly, the EU has extended the transaction ban authority to include financial institutions and crypto asset service providers that help circumvent the Oil Price Cap or transact with listed shadow-fleet vessels. This is a direct warning to banks, PSPs, trade finance desks, brokers, and crypto exchanges that facilitation — knowingly or through willful blindness — can result in listing exposure. Risk teams should revisit their policies for Russia-related correspondent relationships, SPFS-linked activity, oil price cap attestations, vessel and cargo screening (including IMO spoofing detection), and blockchain analytics focused on high-risk exchanges and mixers. For crypto businesses, enhanced monitoring of on- and off-ramp flows tied to Russian exchanges, OTC brokers, and nested services is now critical.

The package also targets disinformation infrastructure, suspending eight additional media outlets broadcasting in or toward the EU for supporting or justifying the war. While this measure is not a traditional financial restriction, payment service providers, advertisers, CDN and hosting firms, and monetization platforms should ensure appropriate blocks, cease services where relevant, and document decisions to manage both legal and reputational exposure.

What should compliance teams do now?

For practitioners, several compliance actions follow from this package.

First, update screening and control frameworks promptly: integrate the new designations, vessel lists, port and airport restrictions, and the expanded listing criteria.

Second, enhance trade documentation controls for commodities and dual-use items, ensuring robust end-use certifications, inspection rights, and supplier attestations, with escalation paths for red flags like complex transshipment routes, atypical routing through free zones, or sudden counterparty switches.

Third, strengthen maritime diligence by combining AIS data, satellite analytics, and maritime intelligence to detect dark activities, STS transfers, and shell ownership chains linked to the shadow fleet.

Fourth, recalibrate financial crime models to flag SPFS-linked correspondent patterns, suspect commodity trade finance structures, and crypto flows interacting with newly at-risk entities.

Finally, review governance: train frontline teams on the new prohibitions, re-paper clients where needed to include attestations on oil price cap compliance and sanctions adherence, and document risk appetite changes approved by senior management.

Enforcement risk is clearly rising.

The EU is demonstrating a willingness to list third-country actors that assist evasion and to use infrastructure and service bans to cut off logistical pathways. Firms that previously relied on formalistic checks or narrow jurisdictional interpretations should shift to a risk-based approach that considers the intent of the measures: reducing Russia’s ability to generate revenues, acquire critical technologies, and maintain war-related logistics. Given the expanding scope to target facilitators, complacency around indirect exposure — through layered ownership, transshipment hubs, or alternative messaging systems — invites serious legal and commercial consequences.

Dive deeper

• European Commission ¦ EU adopts 16th package of sanctions against Russia ¦ Link