This Client Alert is published in the context of ongoing developments and should be read in conjunction with Latham’s previous sanctions updates. This Client Alert is not intended to take the form of official legal advice. Given the frequency with which different jurisdictions impose new sanctions, and the detailed and nuanced nature of the sanctions updates, businesses exposed to sanctions-related developments should obtain up-to-date legal advice before taking any steps that may have legal consequences.
During 18-19 July 2025, the EU unveiled its 18th “package” of sanctions launched against Russia since Russia’s invasion of Ukraine in February 2022. Among these measures, the EU seeks to close an apparent loophole by which Russian-origin oil could enter EU markets after first being “processed” in other countries. (Relatedly, the EU imposed a stringent “asset freeze” measure on an India-based oil refinery.) The package also adds certain types of banking-related software to categories of software banned for provision to Russia by persons under EU jurisdiction.
The EU’s actions follow waves of EU and UK measures in recent months, many of which have also targeted Russia’s oil and business sectors. This Client Alert summarises the key Russia-related updates imposed by these measures, starting with the EU’s so-called 15th package.
Each of the EU’s 15th, 16th, 17th, and 18th packages have placed asset freezes, transaction bans, and export restrictions on ever-larger numbers of individuals, entities, and vessels alleged to have been involved in assisting Russia’s actions against Ukraine. Increasingly, this covers persons and entities from countries other than Russia, including China, Turkey, and India.
The EU’s 15th package, released on 16 December 2024, provided the first instances of these rounds of measures. Via Council Implementing Regulation (EU) 2024/3183, the EU updated Council Regulation (EU) No. 269/2014 (Regulation 269), which contains the majority of the EU’s so-called asset freeze sanctions relating to Russia. This update designated more than 80 persons and entities, including a Chinese businesswoman, several China-based companies, and even an EU national alleged to have repeatedly traded Russian-origin oil above the so-called oil price cap (OPC) maintained by the EU and others in the OPC Coalition.
Elsewhere in the package, the EU introduced additional measures. Via Council Regulation (EU) 2024/3192, the EU updated Council Regulation (EU) No. 833/2014 (Regulation 833), which contains the majority of the EU’s trade-related sanctions relating to Russia. Among these updates, the EU:
In February 2025, on the third anniversary of Russia’s 2022 invasion of Ukraine, the EU released its 16th package. Among the asset freeze updates in Regulation 269, the EU used Council Implementing Regulation (EU) 2025/389 to sanction more than 80 new persons. These included Garantex, a cryptocurrency exchange based in Russia.
As with many other packages, the EU broadly aligned its sanctions against Belarus with those it had already placed over Russia. For this package, Council Regulation (EU) 2025/392 updated Council Regulation (EC) No. 765/2006 (Regulation 765), which contains the EU’s main sanctions against Belarus. Among these alignments, the EU prohibited the provision of “crypto-asset wallet, account or custody services” to Belarussian nationals or persons and entities located in Belarus (with limited exceptions). This is contained in Article 1u of Regulation 765 and parallels a similar provision used in Regulation 833 against Russia.
The 16th package also extended the “best efforts” obligation — previously limited to the trade-related sanctions contained in Regulation 833 — to the other EU sanctions regulations relating to Russia’s invasion of Ukraine. As described in this Latham Client Alert, the best efforts provision requires natural and legal EU persons who own or control non-EU companies to undertake best efforts to ensure that the non-EU companies do not “participate in activities that undermine” EU sanctions. The EU has now incorporated this requirement into:
The 16th package also introduced changes to the trade restrictions in Regulation 833 (via Council Regulation (EU) 2025/395), including by:
On 20 May 2025, the EU released its 17th package. Among its asset freeze-related updates to Regulation 269, the EU sanctioned the major Russian oil producer Surgutneftegaz (through Council Implementing Regulation (EU) 2025/933).
The EU also imposed other asset freeze sanctions on a range of persons and entities by updating other sanctions regimes containing significant numbers of Russia-related persons, namely:
In addition, the EU updated the Annexes of Regulation 833 via Council Regulation (EU) 2025/932. This included significant restrictions on dealing with a large number of listed vessels (as listed in Annex XLII of Regulation 833).
During 18-19 July 2025, the EU released its 18th package. Several of the package’s measures heighten restrictions on Russian oil, including on those who deal with it. Notably, the EU placed asset freeze sanctions on an Indian oil refinery that is 49% owned by Russia’s “Rosneft” and alleged to be a “major refiner of Russian crude oil”. The EU implemented this and other asset freezes as updates to Regulation 269 via Council Implementing Regulation (EU) 2025/1476. The EU also expanded the trade-related sanctions contained in Regulation 833 through Council Regulation (EU) 2025/1494.
Those new measures include an attempt to prevent Russia’s oil from reaching the EU market “through the back door”, as described in this EU press release. The EU aims to achieve this by introducing Article 3ma to Regulation 833. Specifically, the EU directs that, from 21 January 2026, it shall be prohibited to “purchase, import or transfer, directly or indirectly into the [EU]” any “petroleum products falling under CN code 2710 obtained in a third country from crude oil falling under CN code 2709 00 originating in Russia”.
Effectively, this means that the EU will generally prohibit the import of Russian crude oil that has been refined or processed into a petroleum product in a non-EU country such as India or China. From 21 January 2026, importers are generally expected to provide “evidence of the country of origin of the crude oil used for the refining of the product in a third country”. Article 3ma provides an exception if the product is imported from a “partner country” in Annex LI (presently, Canada, Norway, the UK, the US, and Switzerland).
In addition, Article 3ma provides that competent EU Member State authorities may proceed on the basis that “petroleum products imported from third countries which were net exporters of crude oil in the previous calendar year” were “obtained from domestic crude oil and not from crude oil originating in Russia”, unless they have reasonable grounds to believe otherwise.
In an OPC-related measure, Article 3n and Annex XXVIII have been updated, such that the OPC for maritime-borne Russian crude oil (CN code 2709 00) shall be reduced from US$60 per barrel to US$47.60 per barrel from 3 September 2025. Article 3n also directs the European Commission to monitor the average price of Russian crude oil, with a view to regularly re-setting the OPC at 15% below the average price of Russian crude oil. The EU expects the next such update to occur on 15 January 2026, “and every six months thereafter”.
Aside from oil-related measures, the EU implemented the following:
In addition, the EU updated its Belarus-targeted sanctions, as contained in Regulation 765. The EU did so via Council Implementing Regulation (EU) 2025/1469, which placed new asset freezes on a range of largely military-linked Belarusian entities. The EU also used Council Regulation (EU) 2025/1472 to align the Belarus sanctions with recent Russia sanctions. This included a change in the wording of Article 1zb, which alters several de-SWIFTings into wider-scale transaction bans and affects the banks listed in Annex XV (currently, Belagroprombank, Bank Dabrabyt, the Development Bank of the Republic of Belarus, and Belinvestbank).
In parallel to these EU developments, the UK has also heightened its sanctions against Russia in 2025. Notably, on 10 January 2025, the UK placed full-scale asset freeze sanctions on two major Russian oil companies, including Surgutneftgas.
On 22 April 2025, the UK released The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025. These updated the UK’s primary Russian-focused sanctions instrument — The Russia (Sanctions) (EU Exit) Regulations 2019 (the UK Russia Regulations). In this update, the UK followed the EU in prohibiting the export to Russia, or to “persons connected with Russia”, certain types of “sectoral software” (namely, certain types of “business enterprise” software, “industrial design” software, and “oil and gas related” software). The relevant prohibitions are now contained in Chapter 4N of the UK Russia Regulations, while the types of affected software and technologies are listed in Schedule 3IA.
The UK initially provided for a wind-down exception, scheduled to expire on 22 July 2025. On 21 July 2025, however, the UK released a “General Trade Licence”, which permits — until 20 October 2025 and subject to the licence user registering within 20 calendar days — the continued provision of “sectoral software” affected by Chapter 4N to “multinational clients headquartered outside of Russia” but which have “global subsidiaries and affiliates, including in Russia”. An important condition is that the software and any related “ancillary services” are not for “predominant use” by a subsidiary established in Russia.
Also, in coordination with the EU, the UK announced on 18 July 2025 that it would reduce the OPC for seaborne Russian crude oil from US$60 to US$46.60, in effect from 23:01 (BST) on 2 September 2025.
Latham & Watkins actively tracks sanctions developments across regions and is well positioned to advise on the legal and practical impacts of these measures.