EU Trends and Developments Contributed by: Valerijus Ostrovskis, Coline Cauvin, Yapa Thepkanjana and Delphine Buyle, ACQUIS
Anti - circumvention and third - country targeting Each 2025 package expanded the list of third-country entities (predominantly those located in China, Hong Kong, Türkiye, the UAE and Central Asia) subject to stricter export controls or transaction bans. The 17th package extended restrictions to non-EU finan - cial institutions and crypto-asset service providers deemed to be facilitating Russian sanctions circum - vention. The 19th package imposed transaction bans on five third-country banks in Central Asia and tar - geted a cryptocurrency exchange in Paraguay. The readiness to designate entities in jurisdictions not tra - ditionally targeted by EU restrictive measures signals a fundamental shift in the geographic reach of the EU sanctions regime. Key trends from the 2025 EU sanctions packages against Russia include the following. • Energy restrictions have become self-executing. The dynamic price cap mechanism and the LNG ban together represent a systematic effort to close Russian energy revenue routes without requiring novel political consensus to effect each tightening. • The shadow fleet campaign has matured from vessel listings to infrastructure and full operational ecosystem targeting. Designating maritime registry operators and port administrators reflects a more sophisticated attack on the shadow fleet’s enabling ecosystem. • Third-country circumvention is now a primary enforcement priority. The consistent expansion of circumvention lists signals a strategic decision to impose costs on enablers of evasion in third coun - The most consequential development in EU Iran sanctions policy during 2025 was the triggering of the snapback mechanism under the 2015 JCPOA. On 29 September 2025, the EU reimposed compre - hensive sanctions that it had lifted under the 2015 nuclear deal, including the freezing of the Iranian Cen - tral Bank’s assets, a ban on the importation of Iranian oil, and a ban on the exportation of technologies or materials that could be used for uranium enrichment. Designations covered institutions of structural signifi - tries, not just primary Russian actors. Iran: the snapback and reimposition of comprehensive sanctions
The Evolving Sanctions Landscape in the EU Russia: the 16th to 19th packages Four major packages adopted between February and October 2025 represent a significant expansion of the EU sanctions regime against Russia across three structural axes: energy, the shadow fleet and anti- circumvention. Energy as the vital battleground The 18th package delivered one of the most techni - cally significant energy measures to date, reducing the oil price cap for crude oil from USD60 to USD47.6 and introducing an automatic and dynamic review mecha - nism to ensure that the cap remains 15% below the average market price for Urals crude in the preceding six-month period. This removes the need for ad hoc political negotiations to tighten the cap, constraining Russian revenues automatically as market prices shift. The 19th package delivered the most consequential energy measure yet: a ban on imports of Russian liq - uefied natural gas (LNG) as of 1 January 2027 for long- term contracts, and within six months of entry into force for short-term contracts, representing the first time the EU imposed a full LNG import ban. Accompa - nying this measure was a full transaction ban on Ros - neft and Gazprom Neft, eliminating previous import exemptions. The EU is systematically closing every remaining commercially meaningful route for Russian energy exports in order to constrain Russian energy revenues. The shadow fleet campaign By the 17th package, the EU had doubled the total number of listed vessels to 342, and the 18th pack - age brought that figure to 444, including the first ever designation of a captain of a shadow fleet vessel and an operator of an international flag registry. The 19th package added a further 117 vessels, raising the total to 557. More significant than the raw num - bers has been the evolution of the tools themselves: port access bans on implicated third-country ports, expanded service prohibitions, and sanctions extend - ed to the registries providing false flags. The EU is now attacking the operational ecosystem of the fleet rather than merely the individual vessels to amplify the impacts of sanctions.
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