EU Adopts 19th Sanctions Package Against Russia

On 23 October 2025, the EU adopted a further sanctions package, its "19^th Round", against Russia in connection with its ongoing war in Ukraine. We summarise the key measures below.

Energy

• LNG Import Ban: The EU will prohibit the purchase, import, or transfer, directly or indirectly, of Russian liquified natural gas (LNG) from 25 April 2026, except for any contracts entered into before 17 June 2025 and lasting more than a year. For these historic contracts, the prohibition comes into effect on 1 January 2027 (provided the contract is not amended post-June 17, subject to certain limited exemptions).

• Vessel Sanctions: An additional 117 vessels have been added to the list of vessels subject to an EU port access ban and other services restrictions.

Asset-Freezing Sanctions

• Ownership and Control Test: The EU has codified in legislation the terms "owning" and "controlling" for the purposes of determining whether a non-designated entity is subject to EU asset freezing sanctions under Regulation (EU) No 269/2014. These terms were previously specified in guidance, but the EU has pulled them formally into the regulation to drive consistency in interpretation against the Union. In particular, "owning" means being in possession of 50 % or more of the proprietary rights of a legal person, entity or body, or having a majority interest therein. "Controlling" includes, but is not limited to, a range of factors, all of which were previously included in the guidance (e.g., having the right to appoint or remove a majority of board members or having the right to exercise a dominant influence).

• Expanded Criteria: The EU expanded its asset freezing designation criteria to include persons that are responsible for, supporting or implementing actions or policies contributing to the deportation, forced transfer, forced assimilation, including indoctrination, or militarised education of Ukrainian minors.

• New designations: The EU designated an additional 22 persons and 42 entities as asset-freeze targets, including Litasco Middle East DMCC. Despite an earlier action by the UK and U.S. sanctions issued on the 22nd, the EU did not designate either the Lukoil or Rosneft parent companies (it did, however, expand the scope of the "transaction" ban applicable to the latter).

Military and industrial capabilities

• Additional Goods Subject to Export and Import Restrictions: New items have been subject to export restrictions on Russia and Belarus, including electronic components, rangefinders, and additional chemicals, metals, oxides and alloys, salts and ores, and articles made of rubber, tubes, tyres, millstones and construction materials. Import-related prohibitions have been extended to cover all acyclic hydrocarbons.

• Investment Prohibition: The package introduces a prohibition on acquiring any new or extending any existing participation in ownership or control, creating any new JV, branch, or representative office, entering into any new contract or arrangement for the supply of goods or services, or of related intellectual property rights or trade secrets to, from or for use in listed Russian special economic, innovation or preferential zones. Financing of companies located in these zones is also prohibited. As of 25 January 2026, it will be prohibited to maintain the same in the zones. The restriction provides for certain exemptions and derogations, e.g., for the purchase, import or transport of natural gas, titanium, aluminium, copper, nickel, palladium or iron ore to the EU or for humanitarian purposes.

• Export Restricted Entities: An additional 45 entities are subject to a restriction on selling or exporting dual-use goods or other advanced goods and technologies, i.e., EU persons cannot export or sell such items to them. This list includes entities in Russia and third countries (China, Hong Kong, India, and Thailand).

Financial services

• Transaction Ban: The following banks and oil traders have been added to an EU transaction ban:
  • CJSC Alfa-Bank (Belarus), OJSC Sber Bank (Belarus), VTB Bank (Belarus) and VTB Bank (Kazakhstan) (effective 2 December 2025)
  • Payeer, CJSB JSCB Tolubay, OJSC Eurasian Savings Bank, CJSC Dushanbe City Bank, CJSC Spitamen Bank (Tajikistan), OJSC Commerce Bank of Tajikistan (effective 25 November 2025)
  • Blackford Corporation Limited and Fuel and Oil Dynamics FZE (effective 12 November 2025).

• Russian Payment Systems: It will be prohibited, from 25 January 2026, to connect to any systems of the Central Bank of Russia or to systems provided by any other legal person, entity or body incorporated or constituted under the law of Russia that include a financial messaging functionality, including the Fast Payment System (SBP) and the Russian National Payment Card System (Mir).

• Crypto: Existing crypto prohibitions have been expanded to prohibit directly or indirectly providing the following to Russian entities or residents: crypto-asset services; issuing of payment instruments, acquiring of payment transactions, or payment initiation services; and issuing of electronic money. EU persons are also prohibited from engaging in transactions involving A7A5 (a stablecoin created with Russian state support) as of 25 November 2025.

Other services

• Additional Services: The EU has restricted the provision of the following additional services to the Russian government or Russian entities: (i) commercial space-based services consisting of Earth observation or satellite navigation, (ii) artificial intelligence services consisting of access to models or platforms for their training, fine-tuning and inference, and (iii) high-performance computing, including access to graphic processing unit-accelerated computing, or quantum computing services. These restrictions are effective as from 25 November 2025.

• Tourism: In addition, services directly related to tourism activities in Russia are prohibited (subject to a wind-down derogation until 1 January 2026 for contracts concluded before 24 October 2025).

• Government Services: Advance authorisation is now required before any non-sanctioned services are provided to the Russian government.

• Reinsurance: It will be prohibited to provide reinsurance for any aircraft or vessels operated by the Russian Government or Russian entities for a period of five years following the sale or lease arrangement of those aircraft or vessels.

Diplomats

Russian diplomatic or consular personnel, including administrative and technical staff, and their family members, will be obliged to provide a 24-hour prior notification of their arrival in or transit through the EU. An EU Member State may impose an authorisation requirement on the travel to or transit through its territory. The measures are applicable as from 25 January 2026.

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.