Newsflash: 18th EU sanctions package against Russia - strict oil price cap, Nord Stream ban and further measures against the shadow fleet

The 18th package of restrictive measures came into force on July 20, 2025. The focus lies on the energy, transport and financial sectors. 55 additional listings (14 individuals, 41 organizations) bring the total number of sanctioned persons to over 2,500.

The most important new measures at a glance

• Oil price cap: The ceiling for Russian crude oil transported by sea will be lowered from USD 60 to USD 47.6 per barrel from September 3, 2025. At the same time, an "automatic and dynamic procedure" will be introduced to regularly adjust the cap to the average market price in future.

• For Nord Stream and Nord Stream 2, the new Art. 5af of Regulation 833/2014 imposes a comprehensive ban on transactions and financing relating to the completion, operation, maintenance and use of both pipelines. Exceptions and approval options apply in the event of emergencies and disasters in order to avert acute damage to health, safety or the environment, provided they are "strictly necessary". Authorizations must be submitted to the Commission for approval by the competent authorities.
• Import ban on refined products: Crude oil, diesel and other refined products may no longer be imported into the EU even if they were produced in third countries from Russian crude oil. Only deliveries from Canada, Norway, Switzerland, the United Kingdom and the USA are exempt. The EU is thus closing a frequently used circumvention route.

• "shadow fleet": A further 105 tankers are listed; meaning that a total of 444 ships now no longer have access to ports and locks of the the Member States and can no longer use a wide range of services related to maritime transport.
• RDIF blockade: All transactions with the Russian Direct Investment Fund ("RDIF"), its subsidiaries and target companies as well as supporting financial service providers are prohibited. A wind-down requiring approval is only possible until December 31, 2026.
• Bank and software bans: The former SWIFT messaging ban becomes a complete transaction ban for 23 institutions. 22 further banks are added.
• Catch-all regulation against circumvention & extended dual-use list: A catch-all clause will apply to Annex VII goods (electronics, CNC machines, etc.) in future. Under this clause, authorities can impose a licensing requirement if they identify a risk of sanctions circumvention. At the same time, 26 additional organizations - eleven of them in third countries (including China and Turkey) - will be included in Annex IV, meaning that stricter export restrictions will apply to them.
• Belarus measures: Eight more companies in the Belarusian defense sector are listed; trade and financial bans are now fully aligned with the Russian regime.

What companies should do now

Companies should now take the following steps in the short term:

• Adapt price, freight and insurance clauses to the new oil price cap. Otherwise, there is a risk of reversals or recalculations for spot or forward transactions that have already been confirmed.
• Review shipping, logistics and insurance contracts with regard to the 444 tanker list and newly listed operators, traders and flag registers.
• Check supply and distribution channels for dual-use, high-tech and Annex VII goods. If there is a potential risk of sanctions circumvention and companies are informed by the competent authority, they must obtain prior approval.
• Analyze contracts and adapt them if necessary: incorporate "no-Russia" and withdrawal clauses into existing contracts in a legally secure manner and consider them when concluding new contracts. Agree assurances of no onward delivery to avoid involvement in sanctions evasion.
• Update sanctions screening: Customer relationships with sanctioned persons must be prevented by an effective KYC system.
• All internal measures to ensure compliance with sanctions and for risk assessment must be carefully documented.

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