Overview
On October 23, 2025, the Council of the European Union (EU) adopted its 19th sanctions package against Russia. The new comprehensive set of restrictive measures targets Russia’s key sectors as well as entities in Belarus, China, India and other countries allegedly assisting Russia’s military efforts. The sanctions aim at further constraining Russia’s access to critical resources, technologies and financial channels, limiting its sources of revenue.
The EU actions followed recent sanctions from the US and UK against major Russian oil companies and tankers. The coordinated action is particularly relevant, given that this is the first time the US has targeted Russia with sanctions since President Trump returned to the White House in January.
The EU’s latest package of restrictive measures is set out in eight legal instruments:
- Council Decision (CFSP) 2025/2032;
- Council Decision (CFSP) 2025/2036;
- Council Decision (CFSP) 2025/2040;
- Council Regulation (EU) 2025/2037;
- Council Regulation (EU) 2025/2033;
- Council Implementing Decision (CFSP) 2025/2038;
- Council Implementing Regulation (EU) 2025/2035;
- Council Implementing Regulation (EU) 2025/2039.
The 19th sanctions package primarily targets Russia’s energy, trade, finance, and military sectors.
The package contains 64 listings of individuals and entities involved in key sectors of the Russian economy, including Russia’s largest gold producer, PJSC Polyus, Evraz plc, state-owned automaker JSC AvtoVAZ, and companies in the energy, shipping and military sectors. The package contains new provisions restricting the movement of Russian diplomats and consular staff within the EU through a prior notification mechanism. The package also introduces new restrictions on services. Additionally, the package further aligns restrictive measures applied to Belarus under Decision 2012/642/CFSP with the newly adopted measures against Russia.
Restrictive measures on the energy sector
The 19th sanctions package introduces stringent restrictions on the energy sector. A full prohibition on the purchase, import or transfer of liquefied natural gas (LNG) originating or exported from Russia will take effect April 25, 2026. For long-term contracts[1] that are concluded before June 17, 2025, and not amended thereafter, the prohibition will take effect January 1, 2027.
It is also prohibited to provide technical assistance, brokering services, financing or financial assistance or any other services related to the import of Russian LNG.
Additional key changes include:
- The designation of 117 additional shadow fleet vessels, bringing the total number of designated vessels to 557.
- The introduction of a new designation criterion for shadow fleet vessels targeting tankers carrying mineral products.[2]
- A full transaction ban on major companies Rosneft and Gazprom Neft: The new measures eliminate the exemption for Rosneft's and Gazprom Neft's oil and gas imports into the EU.[3] The import of oil from third countries, such as Kazakhstan, and the transport of oil compliant with the Oil Price Cap to third countries, are exempted.
- An extended list of partner countries not required to provide evidence of the country of origin of crude oil used for the refining of the product: The list now includes Australia, Japan and New Zealand.[4]
- A ban on reinsuring vessels belonging to the shadow fleet, further constraining their ability to operate.[5]
- The designation of entities involved in the energy and shipping sectors, including Litasco Middle East DMCC, Lukoil’s UAE unit; maritime registries providing false flags to shadow fleet vessels; the largest port container operator, Russian Far East; shipping companies transporting oil cargos including Volgotanker; a conglomerate active in the oil sector, LLC Yadran-Group; and the leading shipbuilder of Sovcomflot, Zvezda.[6]
- The designation of third-country operators—including two refineries and an oil trader from China—considered to be significant buyers of Russian crude oil.[7]
Trade restrictions
The trade sector faces the following restrictions under the new sanctions package:
- A prohibition on the export of goods which might contribute to the enhancement of Russian industrial capacities, such as salts and ores, articles of rubber, tubes, tires, millstones and construction materials.[8]
- A ban on the purchase, import or transfer of all acyclic hydrocarbons.[9]
- A prohibition on the sale, supply, transfer, export or provision to the Government of Russia or legal persons/entities established in Russia of software used for:[10]
- the management of enterprises; or
- industrial design and manufacture; or
- certain uses in the banking and financial sector.
- The list of items subject to export restrictions has been expanded to include those that contribute to Russia’s military and technological capabilities, particularly in the development of its defense and security sector. This includes:
- components and materials used in the production of military systems, such as electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides, and alloys used in military manufacturing.[11]
Further key changes include:
- The designation of 45 Russian and third-country entities—12 in China, including Hong Kong, three in India and two in Thailand—due to their contribution to Russia’s military and technological enhancement or to the development of Russia’s defense and security sector.[12]
- Introduction of a new targeted derogation from the prohibition on the purchase, import or transfer of certain items which are necessary for the operation, maintenance or repair of ultra-violet (UV) lamps used for the disinfection of drinking water.[13]
- Extension of the port infrastructure ban by prohibiting any transaction with specifically-listed third- country ports and locks.[14]
Lastly, Council Regulation 2025/833 includes several derogations that allow national competent authorities to authorize the purchase, import, transfer of certain goods,[15] such as glass fibres, electrical transformers, apparatus for broadcasting and television, electric filament or discharge lamps, and the provision of related technical assistance or financial assistance.
Restrictions on access to finance and financial services
To limit Russia’s financial capabilities and restrict access to financial technologies that could facilitate sanctions evasion, the 19th sanctions package introduces the following measures:
- A prohibition on providing crypto-asset services, certain payment services, or issuing electronic money to Russian nationals, individuals residing in Russia, and legal persons or entities established in Russia.[16]
- A ban on engaging in any transaction involving the stablecoin A7A5,[17] together with the designation of the Kyrgyz issuer of that coin, Old Vector LLC, and a related major trading platform, Grinex.[18]
- An expanded transaction ban on third-country banks, financial institutions and crypto-asset service providers (CASPs) to include:[19]
- Entities that provide payment services, or crypto-asset and payment services to designated entities, otherwise significantly frustrate the purpose of sanctions.
- Certain equivalent entities, if they operate as a ‘mirror’ or ‘successor’ to the above financial entities. Certain exemptions apply to the transaction ban.
- New listings of entities that significantly frustrate sanctions including a crypto-platform, banks, financial institutions from third countries (i.e. Kyrgyzstan and Tajikistan).[20]
- A comprehensive ban on any new or continued participation in the creation of joint ventures with; the provision of financing to, or entry into contracts with companies established in or operating through certain special economic, innovation, or preferential zones.[21]
- A full transaction ban is imposed on five further Russian banks and entities owned by them.[22]
- As from January 25, 2026, a prohibition for EU operators to connect to the Russian National Payment Card System (MIR) or the Fast Payments System (SBP).[23]
Restrictive measures on services
Specific services are also impacted with new restrictions, including:
- A ban on the provision of services directly related to tourism activities in Russia.
- A prohibition on the provision of the following services to the Government of Russia or to legal persons or entities established in Russia:
- Commercial space-based services (i.e. Earth observation or satellite navigation);
- Artificial intelligence services (i.e. access to models or platforms for training, fine-tuning, and inference); and
- High-performance computing services (i.e. GPU-accelerated computing and quantum computing).[24]
- Any services to the Government of Russia that are not mentioned under the service restrictions are now subject to an authorization requirement.
- A prohibition to reinsure vessels and aircraft of the Russian government or Russian persons for up to five years after their sale to third countries.[25]
Restrictive measures related to the military sector
The EU has designated businesspersons and entities that form part of the Russian military-industrial complex,[26] as well as operators based in the UAE and China involved in the production or supply of military and dual-use goods to Russia. As an example, the EU has imposed asset freeze sanctions on ODK-Ufa Engine-Building Production Association, the largest turbine manufacturer. In addition, the 19th sanctions package includes five new listings linked to the Belarusian military-industrial complex and the Lukashenka regime.
The latest listings also include a Lieutenant General in the Korean People’s Army of the Democratic People’s Republic of Korea (DPRK), deployed to Russia in support of its invasion of Ukraine, and a Russian individual responsible for the inhumane and degrading treatment of prisoners of war.
Additional restrictive measures
The 19th sanctions package introduces additional novel measures, including:
- Restrictions on the movement of Russian diplomats, consular officers and related staff. These individuals, along with their family members, are now subject to a prior notification mechanism when travelling within the EU. Member States may also impose an authorization requirement on Russian diplomats for traveling to their territories, based on visas or residence permits issued by another State.
- A new designation criterion for those who contribute to the deportation, forced transfer, forced assimilation, indoctrination, or military education of Ukrainian children.[27] The measure was accompanied with the designation of 11 individuals involved in abduction.[28]
- Targeted measures, including restrictions on certain services, prohibitions on crypto-related payment services, and trade measures imposed on Russia, are now extended to Belarus.[29]
Impact on business
EU operators need to understand the impact of the new restrictions in their transactions as well as the applicable exemptions and derogations. Some provisions include a deferred effective date, while others provide an exemption for the execution of on-going contracts for a certain period (e.g. April 2026).
EU operators should plan to reinforce their due diligence enhancing screening of counterparties, service providers, as well as their ultimate beneficial owners and directors. The 19th sanctions package introduces into Council Regulation (EU) 269/2014 the factors for determining ownership and control of an entity by another sanctioned person. Until the 19th sanctions package, these factors were under the EU Council’s Best Practices for the effective implementation of restrictive measures and constituted soft law. The factors now become binding.
The continued targeting of entities established in third countries with both trade restrictions and asset freezes calls for increased caution from EU operators transacting with entities from countries having economic ties with Russia (e.g. UAE, China, and India, among others). EU operators can see their operations disrupted if they transact with entities considered to be supporting Russia’s war efforts. Therefore, they should be reviewing their supply chains and customer base to understand their risk of designations of counterparties not established in Russia.
Finally, the EU advises to take any possible steps to wind down businesses and transactions in Russia and to not start new businesses there.[30] To facilitate the divestments, the EU has extended wind down periods until 31 December 2026 under certain derogations. The derogations are subject to an authorization requirement from EU authorities. Thus, it is important for EU operators to prepare and timely submit the authorization requests to benefit from the extended divestment period, avoid undue delays in the restructuring of their operations and ensure that no assets are stranded in Russia after the termination of the derogation period.
[1] Those with a duration of more than one year.
[2] Article 3s of Regulation (EU) 833/2014.
[3] Article 5aa of Regulation (EU) 833/2014.
[4] Annex LI to Regulation (EU) 833/2014.
[5] Article 3s of Regulation (EU) 833/2014.
[6] Annex I to Regulation (EU) 269/2014.
[7] Id.
[8] Annex XXIII to Regulation (EU) 833/2014.
[9] Annex XXI to Regulation (EU) 833/2014.
[10] Annex XXXIX to Regulation (EU) 833/2014.
[11] Annex VII to Regulation (EU) 833/2014.
[12] Annex IV to Regulation (EU) 833/2014.
[13] Listed in Annex XXI to Regulation (EU) No 833/2014.
[14] Part C of Annex XLVII to Regulation (EU) 833/2014. Currently, there are no ports and locks included within the listing.
[15] Those falling under CN codes 7007, 7019, 8424 10 00, 8479, 8481, 8483, 8487, 8504, 8517, 8531, 8536, 8537, 8538, 8539, 8539 49, 8543 and 8603, as listed in Annex XXI to Regulation (EU) 833/2014.
[16] Article 5b of Regulation (EU) 833/2014.
[17] Article 5ba of Regulation (EU) 833/2014.
[18] Annex I to Regulation (EU) 269/2014.
[19] Certain exemptions to the transaction ban are also introduced in the amendments of Article 5ad of Regulation 833/2014.
[20] Part A of Annex XLV to Regulation (EU) 833/2014.
[21] Article 5ah of Regulation (EU) 833/2014
[22] Annex XIV to Regulation (EU) 833/2014.
[23] Article 5ac of Regulation (EU) 833/2014.
[24] Article 5n of Regulation (EU) 833/2014.
[25] Article 5u of Regulation (EU) 833/2014.
[26] Annex I to Regulation (EU) 269/2014.
[27] Council Regulation (EU) 2025/2037 of 23 October 2025 amending Article 3(1) of Regulation (EU) 269/2014.
[28] Annex I to Regulation (EU) 269/2014.
[29] Council Regulation (EU) 2025/2041 of 23 October 2025 amending Regulation (EC) 765/2006.
[30] Recital 27, Council Regulation (EU) 2025/2033 of 23 October 2025 amending Regulation (EU) No 833/2014.
