European Union Adopts 19th Sanctions Package

On 23 October 2025, the European Union (“EU”) adopted its 19^th package of sanctions against Russia. The new package is amongst the EU’s most assertive to date, introducing an import ban on liquified natural gas (LNG) and additional measures targeting Russian banks, crypto exchanges, and sanctions circumvention networks.  More is to come: EU officials have already indicated that this will not be the last sanctions package against Russia.

Below we summarize the key measures of this new package:

Trade restrictions

• Import ban on liquified natural gas (LNG) falling under CN 2711.11.00, originating in or exported from Russia into European markets, as well as a prohibition on related technical and financial assistance, as of 25 April 2026. The prohibition will apply as of 1 January 2027 for the execution of supply of LNG under contracts exceeding 1 year concluded before 17 June 2025 and not significantly amended after that date.
• Import ban on all acyclic hydrocarbons (CN 2901 10 00). A wind-down period is provided for the execution until 25 January 2026 of contracts concluded before 24 October 2025. The import ban will not apply until 25 July 2026 to imports of acyclic hydrocarbons from Russia for exclusive use in Hungary, provided they are not resold to buyers outside Hungary.
• New derogation from the import ban on electric filament or discharge lamps falling under CN 8539 49, when they are necessary for the operation, maintenance or repair of ultra-violet (UV) lamps used for the disinfection of drinking water. In addition, the sanctions amend the derogation on the prohibition to purchase, import or transfer of certain items for the operation, maintenance or repair of Budapest metro line 3 cars, to add fire extinguishers and convection heaters falling under CNs 8424 10 00 and 8516 29 50.
• Export ban on items that contribute to the development or production of Russia’s military systems (Annex VII), including electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides and alloys used in the manufacturing of military systems.
• Export ban on goods that might contribute to the enhancement of Russian industrial capacities, such as salts and ores, articles of rubber, tubes, tyres, millstones and construction materials listed in Annex XXIIIG. The provision provides for a wind-down period for the execution until 25 January 2026 of contracts concluded before 24 October 2025. For refractory constructional goods and ceramic wares for lab, chemical or technical use, falling under CNs 6902 and 6909.19, the wind-down period is extended to 25 April 2026.

Shadow fleet

• The designation of 118 additional Russian shadow fleet vessels, including Litasco Middle East DMCC, Lukoil’s prominent shadow fleet enabler based in the UAE.
• The 19^th package introduces a ban on reinsuring Russian vessels listed in Annex XLII and belonging to the shadow fleet.
• Amendment of one of the designation criteria for vessels, to include those involved in irregular and high-risk shipping practices in the transportation of mineral products (in addition to crude oil and petroleum products)
• The transaction ban on any ports and locks has been extended to ports and locks in third countries which are used for the transfer of unmanned aerial vehicles (UAVs), missiles, or related technology and components thereof to Russia and for the circumvention of Oil Price Cap by vessels involved in irregular and high-risk shipping practices and circumvention of other sanctions.

Financial measures

• Transaction ban extended to eight banks and oil tradersfrom Tajikistan, Kyrgyzstan, the UAE and Hong Kong that circumvent EU sanctions. Four banks from Belarus and Kazakhstan are also put under a transaction ban, due to their connections to Russian financial messaging and payment systems.
• Removal of certain energy-related exemptions from the transaction ban against Rosneft and Gazprom Neft.
• Extension on the transaction ban with entities connecting to the system for transfer of financial messages (SPFS) of the Central Bank of Russia or equivalent specialized financial messaging services, as listed in Annex XLIV, to also cover entities connecting any other payment services, such as the Russian National Payment Card System (Mir) and the Fast Payments System (SBP), as of 25 January 2026. The new package provides certain exemptions from the transaction ban related to diplomatic and consular representation, EU nationals and existing contracts and payments. The provision establishes a wind-down period for the execution until 25 April 2026 of contracts concluded before 24 October 2025.
• Amendment to the transaction ban on Russian and third-country banks and crypto-asset service providers listed in Annex XLV, to also include entities that provide payment services to listed entities.
• Prohibition on the provision of crypto-asset and payment services and the issuance of electronic money to Russian nationals and residents, legal persons, entities and bodies established in Russia. The primary responsibility for compliance falls on the account-servicing payment service provider, and restrictions also apply to crypto-asset service providers operating under the transnational regime.
• Ban on transactions involving crypto-assets A7A5 from 25 November 2025, as listed in Annex LIII, which might circumvent restrictive measures against Russia.
• Prohibition to acquire, participate in the ownership or control of any entity registered or doing business or permanently established within the special economic, innovation or preferential zones of Russia, listed in Annex LII, located in Tatarstan, Moscow City and Oblast, Lipetsk, Samara, Kaluga, Saint Petersburg, Ulyanovsk and Vladivostok. The provision also prohibits the creation of joint ventures, branches, or representative offices in those zones, entering into contracts, and arrangements for the supply of goods or services, as well as related intellectual property rights or trade secrets, for use in the listed zones. For zones listed in Part A of Annex LII (i.e., Alabuga and Technopolis Moscow), it will be prohibited to maintain existing participation, joint ventures, any existing contract or arrangement for the supply of goods as of 25 January 2026.

Designations

• 45 additional entities, in third countries, including China, have been added to the list of entities, on which tighter restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defense and security sector are imposed. The entity list includes entities in third countries that have enabled the circumvention of sanctions, including on computer numerical controlled machine tools, on microelectronics, unmanned aerial vehicles, and other dual-use and advanced technology items.
• In the sanctions regime on actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, the Council added the definition of the terms “owning” and “controlling”, in the context of asset freeze measures, to align with other regime. The terms “owing” means being in possession of 50% or more of the proprietary rights, and “controlling” is defined by several criteria listed in the Regulation (e.g., having the right or exercising the power to appoint or remove a majority of the members of the administrative, management or supervisory body). In addition, the Union added a new criterion for designation to include natural or legal persons, entities or bodies responsible for, supporting or implementing actions or policies contributing to the deportation, forced transfer, forced assimilation, including indoctrination, or militarised education of Ukrainian minors.

Restrictions on certain services

• Prohibition on the provision of commercial space-based services, AI, high-performance computing and quantum computing services to the Russian government and companies established in Russia. In addition to restrictions on technical testing and analysis, the measure also covers other engineering-related scientific and technical consulting services, such as geological, geophysical, and other scientific prospecting, as well as subsurface surveying, surface surveying, and map-making services.
• Ban on the provision of services related to tourism activities in Russia.

Divestment

• Extension of the deadlines for certain derogations needed for divesting from Russia by one year, until 31 December 2026.

Other restrictive measures

• Mandatory prior authorisation from the competent authorities for any service provided to the Russian government.
• Mandatory prior notification for Russian diplomats and consular offices travelling in the Schengen area and when travelling to a Member State other than that of their accreditation.
• Prohibition for Russian national or natural persons residing in Russia to own, control or hold any position in a body incorporated in an EU Member State and which is providing crypto-asset wallet, account or custody services.
• Prohibition to reinsure Russian used aircraft or vessels for 5 years following their sale or lease arrangement.
• Extension of the prohibition on public procurement awards to entities owned or controlled by natural persons who are Russian nationals or residents.
• Broader list of partner countries for the importation of petroleum products in Annex LI, which now includes Australia, Japan and New Zealand, in addition to Canada, Norway, the UK, the US and Switzerland.

Belarus

The 19^th sanctions package also includes five new listings related to the Belarussian military-industrial complex and the Lukashenko regime. It also extends some of Russian sanctions to Belarus, including certain export and imports restrictions, the crypto-related payment services and prohibition against software with certain uses in the banking and financial sectors, and services that contribute to enhance Belarus’ technological capacities, such as commercial space-based service, technical testing and analysis, AI and quantum computing.

You will find the 19^th sanctions package here:

• Council Regulation (EU) 2025/2033
• Council Regulation (EU) 2025/2037
• Council Regulation (EU) 2025/2041
• Council Implementing Regulation (EU) 2025/2039

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Please do not hesitate to get in touch with Cassidy Levy Kent’s sanctions team in Brussels, or your usual contact in any of Cassidy Levy Kent’s offices, with any questions.