On 18 July 2025, the EU announced the 18th sanctions package against Russia and Belarus. The legislative texts were published on 19 July 2025. As of this date, the latest restrictions indicate a misalignment between the EU / UK, and other G7 members, including the United States.

The EU’s new measures will have notable impacts on the energy and financial sectors, in particular:

  • 105 vessels have been added to Article 3s listings, as part of the Russian “shadow fleet”.
  • 14 individuals and 41 entities are subject to asset freeze restrictions as of 19 July 2025, including those associated with 2Rivers (which is already subject to UK asset freeze restrictions), and Nayara Energy Limited. No wind-down applies to these new listings.
  • As of 3 September 2025, the EU and UK will lower the price cap for crude oil from USD 60 to USD 47.6 per barrel. There will be a transitional period until 18 October 2025.
  • The EU Commission will be tasked with monitoring Russian crude oil prices to ensure that there is a dynamic mechanism of updating the price cap.
  • There is currently no change to the price cap for petroleum products under CN Code 2710.
  • From 21 January 2026, EU operators will be prohibited from purchasing, importing or transferring CN Code 2710 products from third countries refined from Russian origin CN Code 2709 00.
  • A transaction ban has been imposed in relation to Nord Stream 1 and 2.
  • Banks that were previously subject to restrictions on relating to the provision of specialized financial messaging services are now subject to a full transaction ban. The list of banks has also been expanded.

The legislative texts were published on 19 July 2025, and can be accessed with the following links:

Russia

Belarus

This client alert highlights some of the headline measures as follows:

  1. New asset freeze listings
  2. Price cap and dynamic price cap amendments
  3. Restrictions on goods being provided to Russia
  4. Transaction ban on Nord Stream and Nord Stream 2
  5. Other new transaction bans
  6. Updates to existing transaction bans
  7. Shadow fleet listings

A. New asset freeze listings

The EU imposed asset freeze restrictions on a further 14 individuals and 41 entities as of 19 July 2025, including those associated with 2Rivers (which was already subject to UK asset freeze restrictions), and Nayara Energy Limited.

No wind-down period has been provided for these new asset freeze targets.

B. Price cap and dynamic price cap amendments

In a coordinated approach, the EU and the UK announced that the relevant price cap for Russian origin crude (CN Code 2709 00) will be reduced from USD 60 to 47.6 per barrel. The new price cap will take effect on 3 September 2025. At this stage, it is unclear whether the U.S. or the other members of the G7 will follow suit.

The UK transitional period is clear, “[f]or any trades with an effective date of contract before 23:01 (BST) Tuesday, 2 September 2025 and which are compliant with the existing price cap of USD 60 per barrel, there will be a wind-down period of 45 days. After a wind-down period of 45 days, the lower price cap of USD 47.60 per barrel takes effect.”

The EU position will doubtless be clarified by FAQ but the amended regulation suggests that contracts otherwise prohibited by Article 3n(1) and 3n(4), entered into on or after 20 July 2025, may rely on the USD 60 per barrel cap, but must be wound down by 2 September 2025. Relevant contracts entered into before 20 July 2025 must be concluded by 18 October 2025.

The price cap of petroleum products under CN Code 2710 has not been amended and remains at the current prescribed levels for Discount to Crude and Premium to Crude.

The EU Commission will be tasked with monitoring Russian crude oil prices by reference to price assessments provided by “authorised reporting agencies,” and will calculate the average market price of Russian crude oil over periods of 22 weeks starting from 15 July 2025.

The price cap will then be set equal to the calculated average market price less 15%, save that if the newly calculated price varies by 5% or less from the current applicable price cap, no amendments will be made.

The EU Commission will publish a notice of the relevant average market price and amend the price cap on 15 January 2026 and every six months thereafter. The amended price cap will apply as of the first day of the month following the month of entry of the relevant implementing regulation.

C. Restrictions on goods being provided to Russia

The list of goods that are subject to restrictions from being provided to Russia under various restrictions, including Article 2a and Article 3k, has also been expanded. These include (without limitation) the following CN Codes:

  • 2613 Molybdenum ores and concentrates
  • 2707 Oils and other products of the distillation of high temperature coal tar; similar products in which the weight of the aromatic constituents exceeds that of the non-aromatic constituents
  • 2801 Fluorine, chlorine, bromine and iodine
  • 2802 Sulfur, sublimed or precipitated; colloidal sulfur
  • 2803 Carbon (carbon blacks and other forms of carbon not elsewhere specified or included)
  • 2804 Hydrogen, rare gases and other non-metals
  • 2817 Zinc oxide; zinc peroxide
  • 2821 Iron oxides and hydroxides; earth colors containing 70% or more by weight of combined iron evaluated as Fe2O3
  • 2822 Cobalt oxides and hydroxides; commercial cobalt oxides
  • 2823 Titanium oxides
  • 7315 Chain and parts thereof, of iron or steel
  • 7326 Other articles of iron or steel
  • Ex 74 Copper and articles thereof, except CN code 7401 00 00
  • 76 Aluminum and articles thereof

D. Transaction ban on Nord Stream and Nord Stream 2

A new Article 5af has been introduced, which imposes a transaction ban, in the similar approach to the existing transaction bans (e.g. Articles 5aa and 5ae), in relation to the natural gas pipelines Nord Stream and Nord Stream 2. These apply to transactions relating to (1) the completion, operation, maintenance or use of the pipelines; and (2) the financing concerning the completion, operation or use of the pipelines.

Certain exceptions and grounds for derogations have been published. However, the intent behind these new provisions is to enable EU operators to unwind their existing transactions unless it relates to safety, maritime shipping or the environment or as a response to natural disasters.

E. Other new transaction bans

TwTwo non-EU credit and financial institutions providing crypto asset services are also now subject to transaction bans under Article 5ad. These are:

  • Heihe Rural Commercial Bank Co. Ltd.
  • Heilongjiang Suifenhe Rural Commercial Bank Co. Ltd.

The new Article 5ag also imposes transaction bans against the Russian Direct Investment Fund and relevant listed entities or associated entities.

Article 5h has also been revamped. Previously, EU operators were prohibited from providing specialized financial messaging services with such listed banks. However, this has now been changed into a full transaction ban, with additional banks being listed.

F. Updates to existing transaction bans

In continuation with the EU’s “firewall program”, the latest package also adds an exception for entities established in the EU and acting on behalf of or at the direction of Article 5aa(1)(a) and Article 5aa(1)(b) entities, so long as a competent authority has imposed a public trusteeship or similar public firewall measure on such an entity or a similar firewall measures is authorized by competent authorities in order to ensure their continued functioning and compliance with restrictive measures.

In respect of the transaction ban against listed ports under Article 5ae (which was introduced in the EU’s 16th sanctions package), the EU has also formalized its EU FAQ derogation for non-Russian coal by way of a new exception under Article 5ae(3)(g).

G. Shadow fleet listing

Three vessels were de-listed:

  • North Moon
  • North Ocean
  • North Light

The following vessels were added to the list of vessels subject to Article 3s restrictions:

  • Venetians
  • Jacklyn
  • Sea Marine I
  • Diva I
  • Hulda
  • Jaldhara
  • Vision
  • Nagarjuna
  • Sandhya
  • Himalaya
  • Sea Honor
  • Ru Yi
  • Sealion I
  • Achilles
  • Hu Po
  • Pearl
  • Valera
  • Sirius I
  • Cordelia Moon
  • Virat
  • Themis
  • Deneb
  • Olia
  • Tasta
  • Cross Ocean
  • Ricca
  • Golden Eagle
  • Akar West
  • Fiesta
  • Bivola
  • Kai Fu
  • Lion I
  • Monte I
  • Samadha
  • Blue Talu
  • Maisan
  • Sofia K
  • Proxima
  • Saraswati
  • Monarch I
  • Evita
  • Utaki
  • Lebre
  • Smyrtos
  • Kusto
  • Seasons I
  • Pierre
  • Prisma
  • Rymo
  • Maria
  • Sanar 18
  • Destan
  • Elephant
  • Kaluga
  • Kira K
  • Nautilus
  • Pate (formerly Shaanxi)
  • Vernal
  • Gogland
  • Feliks
  • Katran
  • Leruo
  • Listiga
  • Akhty
  • Armada Explorer
  • Flura
  • MT Konstantinovsk
  • Nizami Ganjavi
  • Sergey Terskov
  • Nova Energy
  • Yanhu
  • Tango
  • Topaz
  • Volgoneft 251
  • Volgoneft 160
  • Saint
  • Arctic Mulan
  • Viper
  • Wu Tai
  • Lark (formerly Lea I)
  • Marble
  • Seginus
  • Peace
  • Ailama
  • Dorin (formerly E Mei Shan)
  • Sooraj
  • Elise
  • Vision
  • Aura
  • Dignity
  • Lumin
  • Minion
  • Cetus
  • Arabela
  • Karabakh
  • Aulis
  • Naxos
  • Indri
  • Mariel
  • Marlin
  • Skadi
  • Mars 6
  • Shusha
  • Oilstar
  • Mikati