knowledge 30 October 2025 |

Sanctions Update: The European Union’s 19th Sanctions Package Against Russia

The 19th Package builds on previous EU sanctions packages (see our briefing on the eighteenth sanctions package here), and reinforces the EU’s determination to close existing loopholes and strengthen enforcement against circumvention. The package represents one of the most comprehensive and far-reaching to date, and according to Kaja Kallas, High Representative for Foreign Affairs and Security Policy and chair of the Foreign Affairs Council, “the 19th package will not be the last”.

Key measures in the 19th Package

Energy measures

The energy sector remains central to the EU’s sanctions regime. The 19th Package introduces a full prohibition on the import of Russian liquefied natural gas (LNG) into the EU. This ban will take effect from 1 January 2027 in respect of long-term contracts and within six months for short-term arrangements. The 19th Package also removes exemptions previously available to Russian state-owned oil companies, including Rosneft and Gazprom Neft, thereby ending their ability to supply oil or petroleum products into the EU market.

In parallel, the EU has imposed additional restrictions on non-EU entities that facilitate the flow of Russian energy revenues. Sanctions have been extended to two Chinese refineries and a Chinese oil trader, as well as to oil trading companies in Hong Kong and the United Arab Emirates (the “UAE”) that have assisted in the resale or transportation of Russian crude.

The so-called “shadow fleet” used to disguise the origin of Russian oil exports has also come under renewed scrutiny. A further 117 vessels have been designated, bringing the total number of listed ships to 557. Those vessels are subject to port-access prohibitions and a broad ban on related maritime services. The EU has also introduced a ban on the re-insurance of vessels and aircraft of the Russian government or Russian persons for up to five years after their sale to third countries.

On 29 October, the EU’s FAQs on oil import sanctions were updated to say that as of January 2026, petroleum products falling under HS 2710 (Petroleum oils and oils obtained from bituminous minerals, other than crude) obtained in a third country from Russian crude oil are subject to the import ban.  

Together, these measures are designed to cut off a major source of revenue for the Russian state while disrupting global networks that support illicit trade in Russian energy.  

Financial and cryptocurrency restrictions

The 19th Package introduces wide-ranging measures affecting the Russian financial system. Five additional Russian banks, including Alfa-Bank and MTS Bank, have been added to the EU’s transaction ban list. The prohibitions also extend to eight financial institutions and oil traders located in Tajikistan, Kyrgyzstan, the UAE, and Hong Kong, all of which were found by the Council to have facilitated the circumvention of EU sanctions. In addition, four banks in Belarus and Kazakhstan have been designated because of their use of Russian payment infrastructures.

The EU has banned any dealings by EU entities with Russia’s “Mir” and “SBP” payment systems. The Council has also targeted crypto-assets as a vehicle of circumvention. Sanctions have been imposed on the developer, issuer and main trading platform associated with the rouble-backed stablecoin “A7A5”, and transactions involving that coin are now prohibited across the EU. These steps mark a significant evolution in the EU’s sanctions architecture, extending it firmly into the digital-finance domain.

Trade and export controls

The trade measures accompanying the 19th Package aim to further weaken Russia’s military-industrial base. 45 entities have been added to the list of those directly supporting the Russian defence sector, including 28 in Russia itself and 17 located in third countries, such as China, India and Thailand. Export restrictions now cover an expanded range of dual-use and advanced-technology items, and additional export bans apply to products such as salts, ores, rubber articles and construction materials.

The Council has introduced a ban on the purchase, import or transfer of acyclic hydrocarbons, which constitute a significant revenue stream for the Russian petrochemical sector.  The EU has also sanctioned Russia’s largest gold producer, PJSC Polyus. Collectively, these measures are designed to erode Russia’s industrial capacity and constrain its access to critical materials.

Diplomats and individual listings

The EU has introduced new obligations for Russian diplomats travelling within the Schengen Area. Russian diplomats must now provide advance notice for travelling in the area, and Member States may require specific authorisation for such travel.

The Council has imposed 69 new individual listings under the 19th Package, covering oligarchs, Russian energy companies and other entities supporting the war. 11 additional individuals involved in the abduction and indoctrination of Ukrainian children have been sanctioned, and a new listing criterion has been adopted to facilitate future action in this area.

Services and special economic zones

The 19th Package further limits the range of services that may lawfully be provided to Russian counterparties. New restrictions apply to the provision of artificial-intelligence, high-performance computing and commercial space-based services to Russian entities, including the Russian government.

Significant restrictions are also imposed on economic relationships with entities active in nine Russian special economic zones (“SEZs”). SEZs are designated zones considered instrumental in sustaining Russia’s war economy. EU businesses are now prohibited from contracting with companies in the SEZs and from investing in the SEZs. In addition, two of these SEZs – Alabuga and Technopolis Moscow – will be subject to a ban that applies also to existing contracts.

 Furthermore, a new requirement has been introduced so that any non-prohibited services provided to the Russian government be subject to prior authorisation, ensuring greater oversight and accountability.  

Comment

The 19th Package underscores the EU’s continuing resolve to maintain and deepen economic pressure on Russia. The package demonstrates that the EU’s focus has shifted from reactive crisis management to long-term economic containment. The twentieth sanctions package is already being discussed and therefore, sanctions compliance will remain an enduring feature of the European regulatory environment, and businesses should plan for sustained and evolving restrictions rather than short-term adjustments.

Businesses operating within the EU, and particularly those with international supply chains, must ensure that their sanctions-compliance frameworks are robust, regularly updated and capable of addressing new forms of risk such as crypto-assets and third-country facilitation.

Links to new restrictive measures announced on 23 October 2025:

• The new measures introduced by the 19th Package are available on the Official Journal of the European Union (see here) and include:
  • Council Regulation (EU) 2025/2033 of 23 October 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (see here);
  • Council Regulation (EU) 2025/2037 of 23 October 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (see here); and
  • Council Regulation (EU) 2025/2041 of 23 October 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (see here).
• The Council of the European Union press release on 23 October 2025 (see here)
• European Commission press release on 23 October 2025 (see here)

Also contributed by Kelsey Ahern