Insights

On 24th February 2025, the European Union (“EU”) introduced its 16th package of restrictive measures and sanctions against Russia (the “16th Package”) through Council Regulation 2025/395 amending Regulation (EU) No. 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (“Regulation 2025/395”). The 16th Package forms part of the EU’s ongoing commitment to supporting Ukraine and aims to further weaken the Russian economy, close loopholes in previous sanctions and curb circumvention tactics. This latest round of measures has profound implications for the international maritime industry, particularly in terms of vessel sanctions, port restrictions and compliance burdens.

Transport Malta has published its Merchant Shipping Notice 191 informing shipowners, operators and practitioners alike of the principal measures introduced by the 16th Package. This notice essentially focuses on the further prohibitions introduced, namely: restrictions on ports to circumvent the oil price cap and extended transaction bans to credit and financial institutions.

A central focus of the 16th Package is the expansion of the list of vessels subject to the EU’s restrictions whereby 74 new vessels have been added, consisting primarily of oil tankers, bringing the overall total to 153 sanctioned vessels. These ships are part of what is commonly referred to as Russia’s “shadow fleet” which has been instrumental in transporting oil and military equipment whilst evading sanctions including the oil price cap. This measure is part of the EU’s broader strategy to combat sanctions circumvention, as listed under Annex XLII of Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (“Regulation (EU) 833/2014”).

Two new criteria have also been introduced for the designation of individuals and entities to the sanctions list, these being:

those that own, control, manage or operate vessels in Russia’s shadow fleet; and
those supporting or benefitting from Russia’s military and industrial complex.

The EU’s port access ban for vessels forming part of the shadow fleet as introduced by previously issued sanctions packages, is now extended to the abovementioned 74 new vessels, which are prohibited from entering EU ports except in emergency situations such as safety hazards, environmental protection concerns and humanitarian purposes. Furthermore, operators within the EU are prohibited from providing maritime services, including bunkering, insurance and ship-to-ship transfers to these sanctioned vessels. This move significantly complicates the logistics of oil transportation and increases the operational risks for companies involved in these activities as detailed under Article 3s of Regulation (EU) 833/2014.

In addition to targeting individual vessels, the EU has also imposed further prohibitions on direct and indirect transactions within five ports and six airports, all of which are located in Russia. These ports and airports are critical for transferring military equipment and circumventing oil sanctions. A few of the key Russian ports affected by the prohibition of these transactions include Ust-Luga and Novorossiysk which are frequently used for the loading of oil as listed under Annex XLVII of Regulation (EU) 833/2014. This measure is specifically intended to disrupt Russia’s maritime logistics and energy exports through traditional shipping routes.

Furthermore, the newly introduced Article 5ae of Regulation 2025/395 provides the general rule that any transaction involving ports listed under Annex XLVII is prohibited subject to certain exceptions. Article 5ae(5) obliges vessel operators to report any transaction concluded pursuant to said exceptions to the competent authority of their country of registration within two weeks of the transaction being concluded. For Maltese operators, such a notification is to be made to the Sanctions Monitoring Board (“SMB”).
As of the writing of this article, no guidance note has been issued by the SMB with respect to the interpretation of Article 5ae. This reporting obligation is another instance whereby a notification is to be made to the SMB, similar to that provided under Article 3q(4) of Regulation 833/2014 which concerns vessel sale and purchase transactions.

Moreover, through the addition of Article 3nb of Regulation 833/2014, the EU has introduced a temporary storage ban for Russian crude oil or petroleum products in EU ports, even if compliant with the oil price cap. This measure further tightens the enforcement of the oil price cap and complicates the logistics of oil storage and transport and strengthens the EU’s broader strategy to limit Russia’s revenue from oil exports. By means of the introduction of this ban, a key loophole which has been previously used for the transshipment or storage of Russian oil destined for third countries has been addressed and extinguished.

Trade and export controls have also been fortified by means of a further ban on Russian aluminium which is one of the main products that is exported out of Russia via maritime transport. This ban has been introduced after a one-year transition period, with a quota of 275,000 tons which is to be used over a 12-month period, and also equates to 80% of the EU’s imports in 2024. The end result of this ban will be that by the end of 2026, no Russian aluminium can be imported into the EU. This crackdown on aluminium has been implemented gradually whereby the EU’s dependence on Russian aluminium has decreased from 16% in 2020 to 6% in 2024.

The 16th Package marks an escalation in the EU’s efforts to restrict Russia’s maritime and energy sectors by targeting the shadow fleet, isolating critical infrastructure, expanding trade bans and enforcing stricter compliance. For the maritime industry, this means navigating heightened operational risks, adopting more rigorous compliance protocols and rerouting supply chains to avoid penalties and reputational damage. As the sanctions landscape continues to evolve, companies must remain vigilant and adapt to ensure compliance with EU regulations.

These measures, taken together, significantly tighten the restrictions on Russia’s maritime sector, aiming to disrupt logistics, limit revenue from energy and commodity exports and prevent sanctions evasion through maritime channels.