EU and UK Sanctions Developments: Key Updates for Businesses
Recent Geopolitical Shifts and Their Legal Implications
The European Union (EU) and the United Kingdom (UK) continue to evolve their sanctions regimes in response to geopolitical developments. February 2025 saw significant updates targeting Russia, Belarus, and Syria, with far-reaching implications for businesses operating within and beyond these jurisdictions.
EU’s 16th Sanctions Package Against Russia
On 24 February 2025, the EU adopted its latest sanctions package against Russia, targeting key sectors such as trade, energy, transport, financial services, and media. These measures seek to disrupt Russia’s economic capacity and military supply chains while preventing circumvention via third countries.
Key Features of the New EU Sanctions:
Anti-circumvention measures: Extends compliance requirements to ensure that EU entities do not indirectly undermine sanctions through non-EU subsidiaries.
Expanded asset freezes: 83 new listings, including individuals and entities linked to Russia’s shadow fleet and military-industrial complex.
Trade restrictions: Bans on Russian primary aluminium imports and refined limitations on dual-use technology exports.
Energy sanctions: Prohibits the storage of Russian crude oil in EU ports and expands restrictions on Russian LNG projects.
Financial sector controls: Further transaction bans on banks facilitating sanction evasion.
Transport and infrastructure: Prohibits Russian ownership above 25% in EU road transport and restricts EU operators from providing construction services in Russia.
Disinformation measures: Bans eight additional media outlets disseminating pro-Russian narratives within the EU.
UK’s Largest Sanctions Package Since 2022
In a parallel move, the UK government imposed 107 new sanctions, reinforcing its commitment to disrupting Russia’s war economy.
Key UK Measures:
Targeting supply chains: Sanctions on machine tool, electronics, and dual-use goods suppliers in Central Asia, Turkey, India, and China.
International enforcement: Sanctions on North Korean officials supplying troops to Russia.
Financial restrictions: Sanctioning of the first third-country financial institution, Kyrgyzstan’s Keremet Bank.
Oil-related measures: Sanctions on 40+ vessels operating as part of Russia’s shadow fleet.
These updates align the UK’s strategy with the EU, focusing on cutting off Russia’s access to critical military components and financial networks.
Easing of Sanctions on Syria
Amidst tightening measures on Russia, the EU and UK have taken steps to ease sanctions on Syria following the fall of the al-Assad regime. This shift underscores the fluid nature of sanctions regimes, responding to geopolitical transitions.
Key Changes:
Lifting restrictions on the transport and energy sectors, facilitating economic recovery.
Financial sector relief: Removal of five entities from asset freeze lists and exemptions for EU-Syrian banking transactions.
Humanitarian provisions: Indefinite exemptions for humanitarian aid and personal-use luxury goods.
Continued vigilance: Retention of sanctions on individuals linked to the former regime and restrictions on arms, dual-use goods, and chemical weapons.
The UK has signalled a similar approach, with planned adaptations to support humanitarian efforts while maintaining sanctions on high-risk entities.
Compliance and Risk Considerations for Businesses
With sanctions enforcement becoming more complex and extraterritorial in reach, businesses must:
Conduct enhanced due diligence on third-party suppliers and financial partners.
Stay informed about sector-specific restrictions affecting trade, finance, and technology.
Implement robust compliance frameworks to mitigate risks of unintentional sanctions breaches.
As the geopolitical landscape continues to evolve, proactive legal strategies will be crucial in navigating these regulatory changes and maintaining compliance.
📩 Contact me today For tailored advice on sanctions compliance and risk management
David Orchard | Lawyer
+44 743 789 4552
