By: Tommaso Fonti LL.M., Lucia Boccarossa, Cristina Piangatello
On 18 July 2025, the European Union published its 18th package of sanctions against Russia, further tightening the existing sanctions regime.
The new package introduces significant operational changes affecting trade, logistics, finance, and technology, expanding both the list of sanctioned individuals/entities and the categories of goods and activities subject to restrictions.
Impacts on Businesses
The new measures increase risks and restrictions for companies operating in sectors such as exports, supply chains, logistics, and financial services.
It is therefore essential to:
- Verify counterparties and end users.
- Map supply chains and trade flows.
- Monitor goods and technologies subject to restrictions.
- Review contracts to ensure full compliance.
Key New Measures
Strengthening of individual sanctions
- The list of sanctioned individuals and legal entities has been expanded, including non-EU entities (e.g. in China, India, Iran, Turkey, UAE) involved in sanctions circumvention.
- Restrictions also apply in cases of indirect control by already sanctioned parties.
Extension of bans on “dual-use” and “quasi-dual-use” goods
- The number of entities subject to export bans on sensitive goods has increased.
- A new clause requires prior authorisation for exports to third countries where there is a risk of re-exportation to Russia.
New bans on strategic materials and machinery
- The export to Russia of industrial materials—such as copper, aluminium, nickel, rubber, plastics, and chemicals—is now prohibited.
- The ban also extends to machinery and technologies used in packaging, labelling, and industrial processing.
- Temporary exemptions apply for contracts signed before 20 July 2025.
Financial operations and cryptocurrencies
- All transactions with 22 Russian banks are now prohibited.
- The ban also applies to non-EU entities using alternative payment systems (e.g. SPFS) or operating in cryptocurrencies to circumvent sanctions.
Measures on Russian oil
- As of 3 September 2025, the price cap on Russian crude oil will be reduced.
- From 21 January 2026, the import of refined petroleum products derived from Russian crude oil will be prohibited, even if processed in third countries.
- Exemptions apply for partner countries such as Canada, Norway, the UK, the US, and Switzerland.
Total ban on transactions with the Russian Direct Investment Fund
- This ban has been extended to non-EU entities controlled by, linked to, or acting on behalf of the fund.
- Derogations are possible in the case of divestments or medical supplies.
How We Can Support You
The professionals at Bacciardi Partners are ready to assist you in assessing the impact of the new sanctions on your international operations, updating contracts and internal procedures, and ensuring full regulatory compliance. Contact us for a tailored compliance review or to receive dedicated insights.
Tommaso Fonti, LL.M. – Head of Tax, Customs Law and Global Mobility
Lucia Boccarossa – Senior Associate Tax
Cristina Piangatello – Of Counsel