Publication of the new sanctions package against certain areas of Ukraine, Crimea, and Sevastopol

Alongside the adoption of the so-called “sixteenth sanctions package” implemented by the European Union against Russia, the Official Journal of the European Union published a new package of sanctions targeting the non-government-controlled areas of Ukraine.

On February 24, 2025, alongside the adoption of the so-called “sixteenth sanctions package” implemented by the European Union against Russia, the Official Journal of the European Union published a new package of sanctions targeting certain areas of Ukraine. Specifically, these include the non-government-controlled areas of Ukraine —namely, Donetsk, Kherson, Luhansk, and Zaporizhzhia (referred to as “specified territories“) as well as the regions of Crimea and Sevastopol.

The newly adopted restrictive measures are outlined in the following regulations:

• Council Regulation (EU) 2025/398 of 24 February 2025 amending Regulation (EU) 2022/263 concerning restrictive measures in response to the illegal recognition, occupation, or annexation by the Russian Federation of certain non-government-controlled areas of Ukraine
• Council Regulation (EU) 2025/401 of 24 February 2025 amending Regulation (EU) No. 692/2014 concerning restrictive measures in response to the illegal annexation of Crimea and Sevastopol.

These regulations are complementary and introduce the same new restrictions for non-government-controlled areas, Crimea, and Sevastopol, aligning them with the EU’s sanctions regime against Russia and Belarus.

Below is a detailed overview of the main sanctions introduced by the aforementioned regulations.

Restrictions on the Transfer of Banknotes

The regulations introduce a new ban on selling, transferring, or exporting banknotes denominated in any official currency of an EU Member State to the specified territories, Crimea, and Sevastopol. This ban, already in place for Russia and Belarus under Regulations (EU) 833/2014 and 765/2006, respectively, includes certain exceptions, such as personal use by individuals, official purposes of international organizations, or activities promoting democracy, human rights, and the rule of law.

Restrictions on Goods and Technology (exports)

Goods and technologies suitable for use in the key sectors of (i) transport, (ii) telecommunications, (iii) energy, (iv) exploration, prospecting and production of oil, gas and mineral resources

In order to restrict the movement to the specified territories, Crimea and Sevastopol, of goods and technologies that are already subject to restrictions on movement to Russia, certain new goods that may be intended for use in the key sectors of the economy of the specified areas of Ukraine, for which the sale, supply, transfer and export to the specified destinations is now prohibited, have been introduced in Annex II to Regulations (EU) 2022/263 and (EU) 692/2014.