Third, a ban on the purchase and transportation of Russian oil and petroleum products to third countries was introduced if the contract price exceeds the established price cap. For a long time, this cap was set at $60 per barrel of crude oil. However, in 2025, the EU introduced a floating cap mechanism, which changes depending on the oil price. It is currently $47. Notably, Russia prohibits participation in transactions that require compliance with the price cap.
Fourth, there are attempts to restrict Russian energy transport. Russian entities are prohibited from buying tankers. A campaign is underway to target the so-called “shadow fleet” – tankers that, according to EU authorities, are used to transport Russian oil. A list of such vessels is maintained. Currently, there are over 500 of them, and it is expanding with each new sanctions package. It is forbidden to purchase or sell these vessels within EU jurisdiction, and Europeans are prohibited from operating or manning such vessels, from insuring and servicing them, and from trans-shipping cargo from such vessels on the high seas. Vessels that trans-ship oil at sea or conceal its transportation are also prohibited from accessing EU ports. In addition, a ban on the transportation of natural gas through the Nord Stream 1 and Nord Stream 2 pipelines is in effect.
Fifth, blocking financial sanctions are imposed on both Russian entities involved in the energy sector and their partners in third countries. In the latter case, this also includes secondary financial sanctions. A specific feature of the nineteenth and eighteenth packages is the escalation of secondary sanctions related to Russia.
The concept of secondary sanctions is not defined in EU legislation. It is used more as a political concept. However, in a narrow sense, it can be understood as the use of blocking financial sanctions and other restrictive measures against those in third countries who cooperate with Russian partners. The EU law does contain grounds that can be used to impose secondary sanctions. These include the provisions of Article 3 of Regulation (EC) 269/2014, which defines the grounds for imposing blocking financial sanctions. These include the circumvention of EU sanctions, undermining Ukraine’s sovereignty, connections with Russian government structures, etc. The Regulation does not specify the nationality of these individuals. This means that they could also be individuals from third countries, meaning these restrictions could be used as secondary sanctions. Furthermore, Regulation (EC) 833/2014 also contains a number of secondary sanctions mechanisms. The basis for their application may include, for example, the use of the Russian financial messaging system (applied to banks), the filing of claims in Russian arbitration courts by individuals under sanctions against EU individuals, etc. In practice, financial sanctions mechanisms are primarily relevant for the energy sector.
Before the launch of the SMO, the EU criticised secondary sanctions. However, after February 2022, it began to increasingly use them against individuals in third countries with ties to Russia. As with the US, the EU’s primary target for a long time was suppliers of export-controlled goods and industrial products to Russia that circumvented EU export controls. However, since July 2025, a trend has emerged of escalating secondary sanctions against Russia’s partners in the energy sector.
For example, the eighteenth package of sanctions included legal entities in third countries that, according to EU authorities, are involved in the transportation of Russian oil. These include Bellatrix Energy and Zhu Jiang (China), the Intershipping Services (India and the UAE), Twister Shipmanagement (UAE), Admiral Group (UAE), Milavous Group (UAE), 2 Rivers PTE (UAE, including its Singapore branch), Monolink, Tarabya, Aqua Ship Management (Azerbaijan), as well as Redbird Corporate Services and Sapang Shipping (Mauritius). This trend continued in the nineteenth package. MSTA International Maritime Registers and Regulatory (Belize), International Maritime Ship Registry (UK), and Aruba Maritime Administration and Offshore Company Registry (US) were blocked. Such blockages are unlikely to cause significant problems for Russia. In third-country jurisdictions, new companies will likely take the place of the blocked companies.
The Valdai Discussion Club was established in 2004. It is named after Lake Valdai, which is located close to Veliky Novgorod, where the Club’s first meeting took place.
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