On 24 February 2025, the European Union adopted the 16th Russia sanctions package.
The new measures amending the framework Council Regulation (EU) 833/2014 are found and included in Council Regulation (EU) 2025/395. They target systemically important sectors of the Russian economy including energy, trade, transport, infrastructure and financial services. The new package also includes restrictions directly impacting the aviation industry, through the amendment to Article 3d, “the flight ban”, and the inclusion of Article 5ae, “a full transaction ban” on ports and airports in and surrounding Russia.
Below you will find a very brief note on the beforementioned articles.
Amendment to Article 3d:
A notable new provision is the new Article 3d(1b) which provides for the possibility to list any third country airlines operating domestic flights within Russia or supplying, selling, transferring or exporting, directly or indirectly, aircraft or other aviation goods and technology to a Russian air carrier or for flights within Russia. If listed in Annex XLVI, these air carriers, as well as any entity owned or controlled by them, will not be allowed to land in, take off from or overfly EU territory.
Are there any exceptions?
The flight ban will not apply:
- In the case of an emergency landing or an emerging overflight; or
- If such landing, take-off or overflight is required for humanitarian purposes.
Inclusion of Article 5ae:
The new package includes a full transaction ban, with immediate effect, on Russian ports and airports, which are believed to have been used to transport combat-related goods and technology, or to circumvent the oil price cap by transporting Russian crude oil via ships in the shadow fleet. The restrictions are broadly drafted and will apply to any transactions with relevant ports and airports (as listed in Annex XLVII), even if there is no direct transaction with the port authorities themselves. That includes access to facilities of the listed ports, locks and airports, and the provision of any services to vessels or aircrafts.
Are there any exceptions?
The exceptions include transactions which are strictly necessary for:
- Humanitarian purposes;
- The operation of flights required for attending meetings with the objective of seeking a solution to Russia’s invasion of Ukraine or of promoting the policy objectives of the restrictive measures;
- An emergency landing, take-off or overflight;
- Travel for official purposes of members of diplomatic or consular missions of Member States or partner countries in Russia or of international organisations enjoying immunities in accordance with international law;
- Travel, for personal reasons, of natural persons to and from Russia or of members of their immediate families travelling with them; and
- The purchase, import or transport of pharmaceutical, medical, agricultural and food products whose import, purchase and transport is allowed under the EU sanctions regime.