Sanctions 2025

EU Law and Practice Contributed by: Edward Borovikov, Laurens Engelen, Aurore Ancion and Semen Medvedkov, Dentons

Dentons Dentons Europe LLP Rue de la Regence 58 box 2 1000 Brussels Belgium Tel: +32 2 552 29 00 Fax: +32 2 552 29 10 Email: brussels@dentons.com Web: www.dentons.com

1. Trends and Overview 1.1 Sanctions Market

nies, aimed at preventing the circumvention of existing restrictive rules. Furthermore, the EU has introduced a new framework to address hybrid threats, specifi - cally targeting those responsible for, implementing, supporting or benefiting from Russia’s destabilising actions on a global scale. Moreover, the EU has set up and/or further developed sanctions regimes regarding Belarus, Niger, Haiti, Sudan and Iran. In response to Syria’s political trans - action, the EU lifted all economic restrictive meas - ures thereon in May 2025, with the exception of those based on security grounds. The EU also renewed most of its existing sanctions regimes and made sev - eral designations under the EU Global Human Rights Sanctions Regime. 1.3 Key Industries The sectors most impacted by EU sanctions regula - tions vary depending on the specific sanctions regime. However, some sectors tend to be more frequently tar - geted than others. The following sectors are currently targeted by the EU in its Russia Sanctions Regulation. • Financial sector and services: restrictions on transactions with banks, insurance companies and investment institutions to limit their access to inter - national capital and financial resources. • Energy: restrictions on fossil fuel imports into the EU or limitations on the technology needed for energy production. • Transport: sanctions are targeting airlines, shipping companies and logistics firms, as well as restricting access to the EU market or transit through the EU.

The EU maintains tailored sanctions regimes target - ing over 40 different countries, territories and non- governmental organisations. The past year’s developments in the EU were driven primarily by the ongoing war in Ukraine. This includes stricter restrictions on financial trade, services, energy, technology and other sectors deemed critical to the Russian economy, as well as the further development of sanctions targeting Belarus. Further, geopolitical situations and human rights con - cerns have prompted the EU to also implement addi - tional sanctions regimes or expand the existing ones throughout the world. The EU has devoted considerable attention to sanc - tions enforcement in the global context of COVID-19. As such, it developed specific guidance for sanctions in regard to counter-terrorism, Iran, Nicaragua, Syria and Venezuela in August 2021. On 30 June 2022, the EU issued further guidance on the provision of humanitarian aid in compliance with EU sanctions, which also contains guidance on issues related to COVID-19. 1.2 Key Trends Over the past 12 months, the EU has adopted multiple additional sanctions packages against Russia. These measures include additional export restrictions and the designation of Russian individuals and compa -

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