EU tightens sanctions against Russia with 18th package of measures

On July 19, 2025, the 18th package of sanctions under Regulation (EU) 833/2014 (“Russia Sanctions Regulation”) was published in the Official Journal of the European Union. The new regulations particularly affect foreign trade with Russia and contain various adjustments and extensions to existing measures. 

Introduction of a catch-all clause 

A new element is the introduction of a catch-all clause reminiscent of the Dual-Use Regulation: if exporters have been informed by the competent authorities that certain goods they plan to trade with third countries are or may be intended, in whole or in part, for Russian individuals or legal entities, organizations, or institutions, or for use in Russia, the transaction is subject to authorization. 

Several measures have been tightened in the energy sector. The oil price cap has been revised downwards. Transactions related to Nord Stream 1 and 2 will be prohibited in future. In addition, sanctions against the so-called Russian shadow fleet have been extended, affecting companies along the relevant value chains. Import bans on refinery products from third countries have been extended to include those produced from Russian crude oil. Importers will now have to provide proof of origin for the crude oil used, with exceptions for so-called partner countries. This obligation to provide proof is already familiar from trade in iron and steel products. 

Extended export and import bans 

In addition, further goods have been added to the list of export bans, including chemicals and certain metals such as aluminum. Fiscal policy measures have been expanded as well. One of the objectives is to prevent circumvention via third countries. The Russian Direct Investment Fund is now also subject to sanctions. The previous ban on providing specialized messaging services for payment transactions to listed Russian banks has been converted into a comprehensive transaction ban. 

Strengthening Member States in investor disputes 

Member states now also have stronger legal positions in investor-state disputes. Additional companies and persons – including those from third countries – have been added to the sanctions lists. The listing of certain organizations is intended to prevent the undermining of embargo regulations. In this context, China has already publicly announced countermeasures. 

Finally, the measures against Belarus were also further aligned with the Russia Sanctions Regulation in accordance with Regulation (EU) 765/2006.