Sanctions Tracker: EU's 19th Sanctions Package Targets LNG, Crypto And Circumvention

On 23 October 2025, the Council of the European Union adopted its 19th sanctions package, comprising 69 new listings and multiple economic restrictions in response to Russia's escalating aggression against Ukraine. The comprehensive package aims at battling circumvention of the sanctions and addresses critical sectors supporting Russia's aggression: energy, finance, military-industrial complex, and diplomatic activities.

The 19th package consists of Council Regulation (EU) 2025/2033 amending Regulation (EU) 833/2014, and Council Regulation (EU) 2025/2037 and Council Implementing Regulation (EU) 2025/2035 which amend Regulation (EU) 269/2014. The amending regulations came into force on 23 October 2025 following their publication in the Official Journal.

1. Key Takeaways

• On 23 October 2025, the EU adopted its 19th sanctions package targeting Russia's energy, finance, military, and related sectors.
• New bans include Russian liquefied natural gas (LNG) imports and extended restrictions on Russian oil producers.
• Additional sanctions are imposed on third-party entities (from China, UAE, Tajikistan, Kyrgyzstan, and others) facilitating the circumvention of sanctions.
• The package targets Russian diplomats' movements within the Schengen Area to curb intelligence threats.
• New restrictions affect dual-use goods, technology exports, and various services to Russian and Belarusian entities.

2. Key features OF THE 19^th SANCTIONS PACKAGE

a. Energy Sector Measures

The 19^th package contains several measures targeting Russia's energy sector. More specifically, with the insertion of Article 3ra in Regulation 833/2014, the new package now includes provisions on the total ban of imports of Russian liquefied natural gas (LNG) by January 2027 for long-term contracts and within six months for short-term contracts. This prohibition follows the European Commission's proposal in June to gradually phase out the importation of Russian gas, including LNG, into the Union market by the end of 2027.

Existing transaction bans on Russian state oil producers Rosneft and Gazprom Neft are being tightened by limiting the applicable exemptions. New listings of Russian and third-country entities active in the energy sector have been added, including Chinese entities (two refineries and an oil trader), significant buyers of Russian crude oil, who face new sanctions to block revenue flows and avoid circumvention.

In the context of anti-circumvention measures, the package also targets the "shadow fleet" enabling Russia to bypass sanctions, including tanker operators, maritime registries issuing false flags, port operators, and shipbuilders. Following the adoption, the port access ban is extended to an additional 117 vessels, covering now 557 vessels, restricting transport of Russian oil, military equipment, and stolen Ukrainian grain. With the amendment of Article 3s of Regulation 833/2014, a ban on reinsurance for shadow fleet vessels is introduced, further limiting their operations.

b. Financial and Crypto-Related Sanctions

The new package also aims to capture financial and crypto-related activities involved in the financing of Russia's aggressions. In particular, the package targets the Russian-backed A7A5 stablecoin with a full prohibition to engage, directly or indirectly, in any transaction involving the crypto-asset, effective from 25 November 2025, as outlined in the newly inserted Article 5ba of Regulation 833/2014. Moreover, Article 5ad of Regulation 833/2014 imposes a ban on transactions with Russian institutions and entities active in the provision of crypto-assets services, included in Annex XLV. At the same time, the amended Article 5b of Regulation 833/2014 bans the provision of financial services to Russian entities, involving crypto-currency and electronic money, to combat sanctions circumvention via these instruments.

To further address circumvention of measures, eight banks and traders from countries including Tajikistan, Kyrgyzstan, UAE, and Hong Kong have been banned. At the same time, the amended Article 5ac of Regulation 833/2014 now prohibits EU operators from dealing with Russia's National Payment Card System ('Mir') and the Fast Payments System ('SBP'), in addition to the previously banned System for Transfer of Financial Messages (SPFS), and five Russian banks and four from Belarus and Kazakhstan face transaction bans due to their links with Russian payment systems.

Finally, with the insertion of Article 5ah of Regulation 833/2014, the new package prohibits any new participation and the maintaining of existing participation in, the creation of joint ventures with, and the provision of financing to, any enterprise established in or operating through certain special economic, innovation or preferential zones, as well as prohibiting entering into new contracts with such enterprises. These special economic, innovation and preferential zones are a core element of the economic development strategy of the Russian Federation. They are designed to attract direct investment and promote industrial, technological and innovative capacity by providing preferential tax, customs and regulatory regimes in regard to industrial and technological business activities.

c. Other restrictions

Under the new Articles 5v and 5w of the package, Russian diplomats traveling within the Schengen Area beyond their accredited country must now notify member states in advance. Member states may impose authorization requirements for Russian diplomats entering their territories.

The newly introduced amendments also target individuals and entities of the Russian military-industrial complex, including those in third countries supplying military or dual-use goods. The EU imposes tighter export restrictions on 45 entities aiding circumvention of export restrictions on high-tech equipment like Computer Numerical Control (CNC) machine tools, microelectronics, and unmanned aerial vehicles (UAVs), while the export ban has now been expanded and covers additional chemicals, metals, electronic components, construction materials, and acyclic hydrocarbons due to the importance of such materials in generating significant revenues for Russia.

Pursuant to the amended Article 5n, the restrictions on the provision of services have also been extended to require prior authorization for all services provided to the Russian government and to include AI, high-performance computing, commercial space services, and tourism-related services to Russia and Russian entities, as well as services regarding software critical to banking, AI, and quantum computing sectors.

d. Additional targeted individuals and entities

The 19th sanctions package added a further 69 individual listings that the EU sees as having aided Russia's war against Ukraine to Annex I of Regulation 269/2014. Individuals and entities listed in Annex I are subject to an asset freeze, and it is illegal to make funds or other economic resources available to them, whether directly or indirectly. In addition, natural persons are subject to a travel ban, which prevents them from entering or transiting through EU territories.

It is worth noting that the 19th sanctions package amends Council Regulation (EU) 269/2014 to incorporate for the first time binding criteria for assessing whether an entity is owned or controlled by a designated individual or entity.

3. Conclusion

The EU's 19th sanctions package aims at intensifying the pressure on Russia's war capacities, disrupting key revenue streams, and curtailing support from foreign actors. If you require legal advice on sanctions compliance or related matters, please contact our firm for expert guidance.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.