Overview of the EU's 19th sanction package

What you need to know

• Th EU intensified restrictions on Russia’s energy and financial sectors. The sanctions package tightens pressure on Russia’s core revenue streams with liquefied natural gas (LNG) and liquefied petroleum gas (LPG) import bans.
• The package includes sanctions measures against third-country financial institutions and corporations, determined to be frustrating the objectives of EU sanctions. 
• Exemptions and derogations for winding down Russia operations have been extended until 31 December 2026, reflecting regulatory flexibility for orderly exits.
• Intending to reduce ambiguity in interpretation of asset freezing sanctions, the EU has codified the definitions of "ownership"and "control".

On 23 October 2025 the EU adopted its long-awaited 19th package of sanctions against Russia. The new package introduces both sectoral and individual restrictive measures, primarily aimed at Russia’s energy and financial sectors. It combines stricter trade controls, additional service restrictions, transaction bans, and reinforced financial sanctions, while further expanding the use of list-based designations across all sectors. Certain measures are also reflected in the sanctions regime against Belarus. 

Trade restrictions 

Import bans

The package introduces a ban on imports of Russian LNG into the EU (as well as on the provision of related technical or financial assistance) as of 25 April 2026. A limited wind-down exemption applies until 1 January 2027 for certain long-term LNG supply contracts concluded before 17 June 2025, provided they have not been materially amended (with narrowly defined amendments permitted).

In addition, the EU introduced an import ban on a variant of LPG.

Export restrictions 

Export bans have been expanded to include additional items such as salts and ores, articles of rubber, tubes, tyres, millstones and construction materials. New restrictions have also been implemented on additional dual-use items and advanced technologies, including additional metals, oxides and alloys used in the manufacturing of military systems and electronic components, rangefinders and additional chemicals used in the preparation of propellants.

New listing of persons/ entities subject to enhanced export controls 

The EU has added a further 45 entities to the list of entities subject to stricter export controls relating to listed dual-use and advanced technology items. This includes 28 entities established in Russia and 17 entities in third countries (12 in China, including Hong Kong, 3 in India and 2 in Thailand).

Service bans

The package significantly expands restrictions on provision of certain financial services to Russian nationals and residents, and Russian entities. EU persons are now prohibited from providing the following services to such persons: all crypto-asset services (previously, the restriction only covered crypto-asset wallet, account and custody services), issuing of payment instruments, acquiring of payment transactions, or payment initiation services, and electronic money issuance. The existing restriction on accepting deposits from such persons has not been amended.

The EU expanded bans on provision of certain services to the Russian Government and Russian entities. With immediate effect, prohibited services now also include integrated engineering, urban planning, and related consulting services. From 25 November 2025, EU persons will also be prohibited from providing certain commercial space-based services, artificial intelligence services, and high-performance or quantum computing services. 

In addition, the new package requires EU persons to seek a prior authorisation from their competent authority prior to providing (directly or indirectly) any services to the Russian Government. 

The new measures also prohibit EU persons from providing re-insurance services to a vessel or aircraft that was operated (directly or indirectly) by the Russian Government or a Russian entity during a period of five years following the sale or lease of such vessel or aircraft to a third party. 

Finally, the package restricts the provision of services directly related to tourism activities in Russia, including agency and tour operations, travel planning and ticketing, tourist guiding, and related advertising.

Transaction bans in the energy and finance sectors

The package expands, or makes additional listings under existing, transaction ban frameworks targeting the energy and financial sectors.

Energy

Rosneft and Gazprom were already targets of a transaction ban, subject to certain limited exemptions. The new measures eliminate the prior exemption for Rosneft's and Gazprom Neft's oil and gas imports into the EU. 

This package also contains an extension of the port infrastructure ban, which will enable the EU to impose transaction bans on ports in third countries that the EU deems instrumental to Russia.

Finance

The EU implemented a transaction ban, effective 2 December 2025, on five additional Russian banks (Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa Bank). 

The EU has also introduced a transaction ban, effective 12 November 2025, on five banks from Tajikistan and Kyrgyzstan and, effective 25 November 2025, on one cryptocurrency exchange established in Paraguay for they role in frustrating the existing EU sanctions. Furthermore, the EU has targeted with transaction bans, effective 12 November 2025, two oil trading companies in Hong Kong and the United Arab Emirates (UAE).

The new package also imposes a prohibition on engaging in any transactions involving the crypto-asset A7A5, a rouble-backed stablecoin. 

Subject to certain exemptions, the EU is also prohibiting EU persons from connecting to the Russian National Payment Card System (Mir) or the Russian Fast Payment System (SBP). The package also lists four new financial institutions in Belarus and Kazakhstan for their connection to these payment systems.

Asset freezing sanctions

The EU has codified the criteria for “ownership” and “control” used in assessing whether a non-designated entity is subject to the asset-freezing measures. “Owning” is defined as holding 50% or more of proprietary rights or a majority interest, while “controlling” includes, among other things, the right to appoint or remove a board majority or to exercise dominant influence over the non-designated entity. These concepts were previously found in Council and European Commission guidance.

Besides these substantive amendments, the package contains 69 additional listings, which are also subject to travel bans. The listings notably target key actors in the crypto-asset sector linked to A7A5 and across the shadow fleet value chain, including Litasco Middle East DMCC – Lukoil’s major shadow fleet facilitator in the UAE – as well as the largest port container operator in Russia’s Far East and a leading shipbuilder for Sovcomflot.

Anti-circumvention measures

Russia's "shadow fleet"

The EU added 117 shadow fleet vessels to its list of Russian "shadow fleet", bringing the total number to 557 vessels that are unable to access EU ports and subject to a ban on the provision of a broad range of services related to maritime transport. The package also introduces a ban on insuring and reinsuring the designated vessels.
The package also broadens the designation criteria to vessels carrying Russian mineral products or engaging in irregular or high-risk practices.

Other measures 

Exemptions and derogations for exits and divestments from Russia 

Exemptions and derogations facilitating EU persons' exits and divestments from Russia have been extended until 31 December 2026. These apply to certain transaction bans on certain state-owned enterprises, no-claims clauses, trade restrictions, and professional services prohibitions. The recitals highlight the risk of stranded EU assets due to Russian countermeasures and urge companies to accelerate wind-downs and avoid new investments in Russia.

Russian special economic zones 

As of 24 October 2025, subject to certain exemptions, EU persons are prohibited from acquiring interests in, establishing joint ventures or offices with, or concluding new supply or IP contracts involving entities established in 11 designated Russian special economic zones (Designated SEZ). 

From 25 January 2026, subject to certain exemptions, EU persons will also be prohibited from maintaining such arrangements with entities established in two of the Designated SEZ, Alabuga and Technopolis Moscow. This, according to the European Commission, "essentially forc[es] divestment".

With respect to each measure, the prohibition also extends to any entities based outside the relevant Designated SEZ which is owned or controlled by an entity established in the Designated SEZ entity. These bans on investment are also accompanied by associated restrictions on provision of financing and investment services.

What's next?

Preparations for the 20th sanctions package are already in motion, with speculation that Russian oil could be the focus. At the same time, the debate on deploying Russia’s frozen assets within the EU remains politically and legally fraught: no solid legal basis has yet emerged, and Belgium continues to press for robust safeguards before any such step could move forward.