In May 2025, the EU adopted its 17th sanctions package in response to Russia’s continued aggression against Ukraine. The latest measures significantly intensify restrictions across sectors critical to Russia’s military and economic infrastructure, namely energy, shipping, trade, defence and finance. Key actions include:
Restrictions on Russia’s shadow fleet;
Expansion of import bans on fundamental industrial materials;
Tightening of export controls on dual-use technologies and drone components; and
Imposition of sanctions targeting cyber actors and disinformation networks.
In terms of Malta’s National Interest (Enabling Powers) Act (Cap. 365 of the Laws of Malta) (the “NIA”), both AML/CFT subject and non-subject persons are required to comply with applicable sanctions. Moreover, subject persons must maintain internal controls, conduct regular screening, and report any identified designated assets in line with Article 17(6) of the NIA. Non-subject persons are equally obliged under Article 3(5) of the NIA to take reasonable measures - particularly in high-risk contexts - with automated screening tools strongly recommended in such scenarios to mitigate the risk of potential breaches and penalties.
What does this mean for you?
The ever-evolving sanctions compliance landscape poses cross-sectoral challenges, thereby intensifying legal, reputational, and operational risks. Anyone exposed to sanctioned parties and high-risk jurisdictions and products/services must reassess their sanctions compliance frameworks to ensure that they are well-prepared to face such challenges and their implications head-on.
Moving beyond compliance checklists, subject and non-subject persons particularly exposed to sanctions circumvention risks, must strengthen their governance frameworks and operational resilience to manage reputational protection.
In today’s regulatory and geo-political landscape, a specifically tailored sanctions compliance framework is essential. Designed to help organisations effectively manage sanctions-related risks, this set-up supports strategic decision-making by enabling businesses to:
By offering a practical and adaptable solution, the framework equips organisations to navigate sanctions obligations confidently while maintaining compliance and supporting long-term, sustainable global operations.
How can we help?
Our Financial Crime Compliance team offers targeted support to help businesses manage sanctions risk effectively. We may assist you in the following:
Carrying out health checks and gap analyses on your sanctions compliance framework and benchmarking against industry best practices;
Adopting and implementing an effective sanctions risk assessment tool to identify your operation’s exposure across relevant sectors;
Developing tailored sanctions policies and procedures or review the same to ensure alignment of internal processes with regulatory standards;
Delivering targeted training to enhance your team’s sanctions compliance capabilities.
This integrated approach supports organisations’ sanctions compliance efforts, strengthens resilience, and maintains flexibility amid such a rapidly evolving global regulatory environment.
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