The 19th sanctions package against Russia

On October 23, 2025, the European Union (EU) adopted its 19th sanctions package against Russia. The new package targets the energy and financial sectors in particular. At the same time, export and service bans were tightened, and restrictions on individuals were expanded. Annex I to Regulation (EU) No 269/2014 (“Regulation 269/2014”) was expanded to include 64 natural and legal persons, organizations and bodies (“POEs”). The new listings include companies based in China, Hong Kong, the United Kingdom, the United States, the United Arab Emirates, and Kyrgyzstan. A comprehensive supply ban applies to the listed POE.

Energy sector

The central element of the new package is an import ban on Russian liquefied natural gas (LNG) effective from April 25, 2026. For imports based on contracts concluded before June 17, 2025, with a duration of more than one year and which have not been amended since, this prohibition will only apply from January 1, 2027. Furthermore, the transaction ban with listed ports and locks (Article 5ae of Regulation (EU) No 833/2014 (“Regulation 833/2014”) was extended to allow ports and locks outside of Russia to be listed. However, there are currently no entries in Annex XLVII, Part C of Regulation 833/2014, so the ban transaction concerning non-Russian ports and locks remains without practical application for the time being. Additionally, the number of ships in the so-called “shadow fleet" (Annex XLII of Regulation 833/2014) was increased by 117. expanded, so that a total of 557 ships are now listed. Extensive prohibitions apply to these ships pursuant to Article 3s of Regulation (EC) No 833/2014. Financial Sector Sanctions in the financial sector have also been expanded. In particular, prohibitions transactions have been extended through new listings in Annexes XIV, XLV, and XLIV of Regulation (EC) No 833/2014. In addition to the Financial Communications System (SPFS) of the Central Bank of Russia, it is also prohibited from 25 January 2026 to connect to systems of the Central Bank of Russia or to systems with a payment messaging function provided by another legal entity established or registered under Russian law, including the Rapid Payment System (SBP) and Mir the provision of certain services to Russian POE (Power-Oriented Enterprises) has been revised. The 19th sanctions package now explicitly includes, in addition to crypto services, the issuance of payment instruments, the acceptance and settlement of payment transactions, payment initiation, and the issuance of e-money. Furthermore, a new prohibition has been introduced against participating directly or indirectly in transactions related to the crypto assets listed in Annex LIII (Article 5ba of Regulation (EC) No 833/2014). Further changes: Annex IV of Regulation (EC) No 833/2014, which lists POE that are military end-users or belong to Russia's military-industrial complex, has been expanded by 45 entries. Annex VII of Regulation (EC) No 833/2014 has been expanded in Part A by adding several items. In Part B, Table 3 (cameras, sensors, and optical components) has been revised, as has Table [missing information]. 6 (Energy materials and raw materials) and Table 8 (Chemicals, metals, alloys, composites and other advanced materials). Export, transit and ancillary service prohibitions apply to these “Advanced Technology” goods pursuant to Article 2a of Regulation (EC) No 833/2014. Annex XXIII, which lists goods that may not be sold, supplied, transferred or exported, directly or indirectly to POE in Russia or for use in Russia (Article 3k(1) of Regulation (EC) No 833/2014), has also been amended again. In particular, all goods in HS Chapter 25 are now included. Additional goods from HS Chapters 40, 68 and 69 have also been added. The service prohibition pursuant to Article 5n of Regulation (EC) No 833/2014 has been completely revised and expanded. Services are now prohibited. in other areas, namely artificial intelligence, high-performance computing or quantum computing services, as well as services related to tourism activities.

Amendments to the Belarus Embargo Regulation (EC) No 765/2006

In line with the EU's long-standing approach of aligning sanctions against Belarus with those against Russia, the amendments to Regulation 765/2006 under the 19th Sanctions Package essentially correspond to the amendments to Regulation 833/2014.