EU’s 18th sanctions package against Russia: What it means for trade and customs.

Customs measures in the 18th sanctions package

Lower oil price cap

The EU has reduced the price cap for Russian seaborne crude oil to $47.6 per barrel. All transactions involving Russian oil must now adhere to this lower ceiling. Traders should review contracts and logistics chains to ensure compliance.

Refined oil ban via third countries

Refined petroleum products of Russian origin can no longer be rerouted through intermediary nations, except for a few exempted allies. This measure targets known circumvention routes, increasing the need for careful scrutiny of supply chains.

Expansion of the ‘shadow fleet’

An additional 105 vessels have been added to the EU’s restricted list due to their role in transporting sanctioned goods. These vessels are now barred from EU ports and related services. Businesses engaged in maritime shipping should review charter agreements and vessel tracking protocols.

Full ban on Nord Stream-related activities

The EU has imposed a comprehensive ban on activities related to Nord Stream 1 and 2, including financing, maintenance, consulting and technical support.

More export restrictions

Over 180 new commodity codes (CN codes) have been added to the export control list, expanding restrictions on goods that may support Russia’s industrial or military capacity.

Affected product categories include:

• Industrial metals
• Certain plastics and rubber products
• Electronic components and semiconductors
• Advanced machinery and parts

If you export items in these categories, it is crucial to review your classifications, end-use controls and licensing requirements.

Important update on licensing requirements:
The sanctions package introduces an export license requirement for goods listed in Annex VII when exported to third countries, if there is a credible risk that the items may ultimately be re-exported to Russia. As per Recital 7 and Article 2a, Member States may require prior authorisation where end-use concerns are flagged – especially for dual-use and sensitive technologies.

Expanded financial restrictions

The 18th package places greater emphasis on restricting Russia’s access to international financial systems, going well beyond measures targeting cryptocurrencies. This has a broad impact on payment flows, financial intermediaries, and businesses trading globally.

New restrictions include:

• 22 additional Russian entities added to the EU sanctions list
• Enhanced due diligence and scrutiny on crypto assets and third-country financial institutions suspected of facilitating sanctions evasion

New individual sanctions

A total of 96 additional individuals and entities from Russia, Belarus, and other third countries have been added to the sanctions list. Businesses must ensure they are using up-to-date sanctions screening tools to vet counterparties and ultimate beneficial owners.

Note: The sanctions regulations for Russia and Belarus are closely aligned and typically amended simultaneously. Be sure to monitor both sets of listings when screening.

Trade with high-risk jurisdictions

The EU’s 18th sanctions package underscores the growing concern around sanctions circumvention, especially through intermediary countries.

Countries of highest circumvention risk:

• China, Hong Kong, Turkey – These jurisdictions now account for the largest number of sanctioned businesses and are under intense EU scrutiny. Extra vigilance is required when trading with entities from these regions.

Other high-risk routes and partners:

• Primary targets: Russia, Belarus, Iran, Ukraine
• Transit routes: Armenia, Georgia, Kazakhstan, Kyrgyzstan, Turkmenistan, Uzbekistan
• Other scrutinised jurisdictions: Egypt, India, Mongolia, Pakistan, Serbia, Singapore, Sri Lanka, Syria, Thailand, UAE

A comprehensive risk assessment and robust compliance processes are essential when engaging with any of these countries.

Why this matters: Enforcement is tightening

The EU is shifting towards more aggressive enforcement of sanctions. Customs authorities across the EU are increasing inspections, audits, and penalties.

Even unintentional compliance gaps – such as insufficient due diligence or outdated screening – can lead to:

• Shipment delays
• Financial penalties
• Reputational damage

Staying up to date and maintaining documented compliance processes is no longer optional – it is business-critical.

How Gaston Schul supports your compliance

At Gaston Schul, we combine regulatory expertise with hands-on support to help your business navigate sanctions risk without disruption.

We assist with:

• Interpreting and applying EU sanctions
• Classifying controlled goods and technologies
• Screening partners, goods, and trade routes
• Preparing export documentation and license applications
• Providing tailored training based on your risk exposure

With our support, you can focus on growing your business – while we help ensure you remain compliant and audit-ready.