Nikita Veremeev
22.07.2025 | 6 min read
Updated: 22.07.2025
In 2025, the number of legal entities whose assets were frozen due to EU sanctions lists increased by 38% compared to the previous year. More than 22 banks have been completely cut off from international settlements, and the dynamic oil pricing mechanism has become mandatory for all traders working with exports to Europe. For companies from Europe, Asia, and the CIS, this is not just statistics, but a daily reality where every decision is associated with the risk of account blockage, supply chain disruption, or even criminal liability for circumventing sanctions.
EU sanctions are becoming increasingly complex: the 18th package of restrictions leaves no room for error, and the new requirements for compliance procedures and legal support for transactions demand not only a deep understanding of international sanctions law but also flexibility in corporate structuring. How to set up business processes to avoid ending up on the blacklist? Which counterparty monitoring and verification tools really work? How to minimize corporate risks and protect assets under sanctions pressure?
I am convinced: understanding the new rules is not just a matter of survival, but a strategic advantage. In this article, I share the experience of COREDO so that you can not only adapt but also use sanctions compliance as a growth tool. Read to the end: you will receive not only a current analysis of the 18th EU sanctions package but also practical recommendations to help your business maintain resilience and competitiveness.
Brief Overview of the 18th European Union Sanctions Package
Main Goals and Principles of the New Restrictions
The 18th EU sanctions package: it’s not just another expansion of restrictive measures against Russia. Its key aim is to strengthen control over the circumvention of sanctions, increase transparency of international settlements, and minimize risks to the European financial system. The focus is on individual EU sanctions against individuals and legal entities, strengthening sanctions monitoring, and the introduction of new sanction risk management mechanisms.
COREDO’s practice confirms: the new restrictions require businesses not only to formally comply with EU sanctions lists but also to implement comprehensive due diligence procedures, regularly update KYC processes, and automate sanctions monitoring. In conditions where secondary sanctions pose a real threat to companies from the CIS and Asia, sanctions risk management becomes a top priority.
Who Are Affected by the New Sanctions: Sectors and Jurisdictions
The 18th EU sanctions package significantly expanded the geographical and sectoral coverage of the restrictions:
- Banking Sector: a ban on operations with 22 banks, including SWIFT blockage and account freezes, effectively excludes them from the international financial system.
- Energy and Oil Trading: new sanctions against the oil sector, export restrictions on oil, automatic price cap adjustments, and the introduction of a dynamic pricing mechanism.
- Shipping and Logistics: EU blacklist of ships, sanctions against captains and shadow fleet management companies, restrictions for international flag registries.
- Crypto Sector: sanctions against the crypto sector, tightening of cryptocurrency regulation in the EU, new AML and KYC requirements for fintech companies.
- Individual Sanctions: the list of individuals and companies involved in circumventing sanctions has been expanded, including against the Russian Direct Investment Fund and Indian refineries working with Russian oil.
A solution developed at COREDO for clients showed: effective corporate structuring in the EU and jurisdiction diversification are key to reducing operational and sanctions risks.
Key Innovations of the 18th EU Sanctions Package
Ban on Operations with Russian Banks and Financial Institutions
Sanctions against banks are one of the most sensitive elements of the new package. The ban on operations with 22 banks, SWIFT blockage, and account freezes mean that any company conducting settlements through these institutions risks facing a complete block on international payments. The COREDO team has implemented projects to relocate settlement centers to alternative EU and Asian jurisdictions, allowing clients to maintain access to cross-border payments and minimize the risk of account blockage.
Special attention is paid to sanctions due diligence: regular checks of banking partners against EU sanctions lists and the implementation of automated platforms for real-time monitoring of changes.
Restrictions for the Energy Sector and Oil Trading
For the energy sector, the 18th EU sanctions package is a challenge: new export restrictions on oil, sanctions against traders and shadow fleet management companies have been introduced. The dynamic oil pricing mechanism and automatic price cap adjustments compel reviewing all contracts and implementing automated financial monitoring systems.
COREDO’s experience showed: updating contract terms, integrating sanctions monitoring into ERP systems, and conducting regular sanctions audits of supply chains allows reducing the risk of secondary sanctions and ensuring transparency for European regulators.
Sanctions against Shipping and Logistics
The EU blacklist of ships, sanctions against captains, and restrictions for international flag registries severely complicate supply chain management under sanctions. For companies working with exports and imports, this means the necessity to review logistical routes, implement monitoring tools for shipping companies, and conduct sanctions due diligence for each supply chain link.
COREDO’s practice confirms: only a comprehensive sanctions audit of logistics and the use of alternative routes allow avoiding supply disruptions and maintaining business resilience.
New Restrictions for the Crypto Sector
Sanctions against the crypto sector and tighter cryptocurrency regulation in the EU are another strategic challenge for fintech and trading. New KYC/AML requirements, sanctions restrictions on cryptocurrencies, and mandatory transaction monitoring using compliance platforms have been introduced. For COREDO clients, implementing automated solutions for sanction monitoring of crypto counterparties has become standard, allowing for reduced risk of account blockage and secondary sanctions.
Practical Consequences for Business: Risks and Challenges
How the 18th EU Sanctions Package Affects Business in Europe, Asia, and the CIS
The introduction of new EU sanctions in 2025 transforms not only the structure of international settlements but also the export and import strategy for companies from Europe, Asia, and the CIS. The cost and availability of international settlements are decreasing, and sanctions barriers for M&A deals and corporate restructuring become a serious obstacle to business scaling.
COREDO’s experience showed: for companies from the CIS and Asia, the key is not only to comply with formal requirements but also to implement regular corporate sanctions reporting, which reduces the risk of account blockage and increases trust from European banks.
Risks of Secondary Sanctions and Liability for Circumvention
Secondary sanctions pose a real threat to international holdings and subsidiaries working with Russian assets or contractors. Violating the sanctions regime results not only in asset blockage for legal entities but also in criminal liability for bypassing sanctions.
The COREDO team recommends implementing sanctions risk management at the holding structure level: conducting regular sanctions audits, monitoring changes in international sanctions regimes, and documenting all compliance procedures to demonstrate good faith to EU regulators.
Impact on Investment Climate and Corporate Deals
Sanction barriers for investments, stricter corporate governance, and new sanction reporting requirements significantly affect the ability to scale business in Europe. For foreign investors, this means the necessity for in-depth due diligence, implementing sanctions monitoring systems, and regular corporate risk assessment.
COREDO’s solutions in corporate structuring in the EU and supporting M&A deals allow clients to minimize risks associated with sanctions pressure and maintain flexibility when entering new markets.
Compliance, AML, and due diligence under New EU Sanctions
New Compliance and AML Requirements for European and International Companies
The 18th EU sanctions package tightened compliance procedures, AML, and due diligence requirements for all financial market participants. Now not only standard KYC is mandatory, but also regular checks against EU sanctions lists, automating sanctions monitoring, and the expanded role of the compliance officer.
COREDO’s team implements comprehensive compliance platforms for clients, integrated with international sanctions registries, allowing timely risk identification and prevention of violations. Special attention is paid to training employees on new financial monitoring standards and documenting all procedures for EU regulators.
Counterparty Checks and Working with Sanctions Lists
Checking counterparties for sanctions affiliation becomes an obligatory part of due diligence. In 2025, working with EU sanctions lists requires not only manual verification but also the implementation of automated monitoring tools capable of identifying new risks in real-time.
COREDO’s solutions allow integrating such tools into business processes, reducing the likelihood of errors and speeding up decision-making processes. For companies conducting cross-border operations, this is critically important for maintaining resilience and transparency.
Preparing for Sanctions Audit and Internal Monitoring
Sanctions audit becomes an integral part of corporate governance. Preparing for an audit requires not only up-to-date corporate sanctions reporting but also organizing internal sanctions monitoring that records all actions for sanctions compliance control.
COREDO’s practice showed: regular internal checks, automation of reporting, and training employees allow successfully passing audits by European regulators and minimizing the risk of fines and account blockage.
Practical Steps for Minimizing Risks and Adapting Business
Recommendations for Protecting Assets and Preventing Freezes
Freezing assets of legal entities and accounts is one of the most serious risks of the new sanctions regime. To prevent them, COREDO recommends:
- Regularly update the list of banking partners, excluding sanctioned institutions from settlement chains.
- Implement systems for automated transaction and sanctions list monitoring.
- Prepare Legal Opinions for each transaction confirming compliance with the sanctions regime.
Strategies for Adapting Corporate Structure and Business Processes
Restructuring corporate structure under new sanctions requires a comprehensive approach:
- Restructuring business considering export and corporate licensing requirements under sanctions.
- Optimizing cross-border capital movement considering restrictions on international settlements.
- Implementing alternative logistics routes and diversifying supply chains.
COREDO’s experience shows: timely adaptation of business processes allows not only reducing risks but also maintaining competitiveness in European and Asian markets.
Best Practices in Legal Support and Compliance
Effective legal support for transactions under sanctions pressure is based on:
- Conducting sanctions expertise for each transaction.
- Implementing corporate compliance and AML standards.
- Using legal consultations on EU sanctions for timely response to legislative changes.
The COREDO team supports clients at all stages – from deal structuring to preparing corporate sanctions reports.
Key Takeaways and Actionable Advice for Business
| Change in the 18th Package | Risks for Business | Recommendations |
|---|---|---|
| Ban on operations with 22 banks | Account blockage, settlement restriction | Verify banking partners, use alternative settlement schemes |
| Dynamic oil pricing mechanism | Increased volatility, new reporting requirements | Update contracts, implement automated price monitoring |
| Shipping restrictions | Supply chain disruptions | Review logistics, use alternative routes |
| Sanctions against the crypto sector | Risks for fintech and trading | Strengthen KYC/AML, implement sanction monitoring of crypto counterparties |
Brief Checklist for Executives and Compliance Officers
- Update the list of banking and logistic partners.
- Implement automated platforms for sanctions monitoring.
- Conduct an internal sanctions audit and train employees on new requirements.
- Ensure transparency and documentation of all compliance procedures.
- Prepare corporate sanctions reporting for EU regulators.
Useful Tools and Platforms for Sanctions Monitoring
- International EU sanctions lists registries.
- Compliance platforms with automatic sanctions list updates.
- ERP systems with integrated sanctions monitoring.
For an individual strategy to adapt to new EU sanctions, contact COREDO experts. We are ready to offer solutions that will ensure the sustainability and growth of your business under sanctions pressure.