EU Adopts 19th Sanctions Package Against Russia
News Flash: EU Adopts 19th Sanctions Package Against Russia
On October 23, 2025, the Council of the European Union approved its 19th package of sanctions against Russia, marking another escalation in the EU’s response to the war in Ukraine[1].
The package targets Russia’s economic lifelines and sanction-evasion networks across energy, finance, technology, and logistics. Key objectives include cutting off revenue fueling Russia’s war effort, closing loopholes exploited to bypass earlier sanctions, and holding perpetrators accountable, all in pursuit of a “just and lasting peace” for Ukraine[2].
In a coordinated response, on October 15, the United Kingdom also announced a tightening of its sanctions package against Russia, notably imposing sanctions on Rosneft and Lukoil for the first time. Other countries may soon follow suit and for example on inquiry last week the SECO confirmed that Switzerland was working on the adoption of the 19th package but declined to provide a timeline.
Below is an overview of the proposed 19th package, its legal and sectoral components, and the implications for businesses.
Objectives and Geopolitical Context
EU’s Strategic Aims: The 19th package is squarely aimed at “any source of income for the Kremlin to continue its aggression”, according to EU officials[3]. High Representative Kaja Kallas underscored that sanctions are visibly undermining Russia’s public finances and must be reinforced “until peace is achieved”[4]. In particular, Brussels seeks to further choke Russia’s fossil fuel revenues, disrupt its military supply chains, and crack down on sanction circumvention in third countries.
Unanimous approval was required, and debate among member states expected, especially on energy measures. Some countries with residual dependence on Russian gas – such as Hungary and Slovakia – had signaled concerns over phasing out LNG and could seek concessions or transitional derogations[5]. Finally the 19th package has been approved after Slovakia lifted its veto.
Energy Sector Measures
Accelerating the Ban on Russian LNG: In a bid to hit Russia’s primary income source, the EU is moving to completely ban imports of Russian liquefied natural gas (LNG) into the EU. The 19th package proposes a full LNG import prohibition effective one year earlier than previously planned[6]. Short-term contracts must end after six months; long-term contracts will be prohibited as of January 1, 2027. This step closes the gap remaining after earlier gas sanctions – while most Russian pipeline gas had already been curtailed, LNG shipments (about 16–19% of Europe’s gas last year) persisted for some member states[7]. The accelerated LNG phase-out will force Russia to find other markets for a “lion’s share” of its LNG produced in the Arctic that had still been reaching Europe[8].
Closing Oil Loopholes – Shadow Fleet and Oil Companies: The EU is also tightening the screws on Russian oil exports. Building on the G7 price cap mechanism, the new package expands the crackdown on the “shadow fleet” – the network of aging tankers and intermediaries concealing Russian oil trades. 117 additional illicit oil vessels are slated to be added to the EU blacklist, bringing the total sanctioned ships to 557[9]. Listed tankers will be barred from EU ports and denied crucial services (insurance, bunkering, classification, etc.), cutting off support for tanker operators that enable sanctioned oil shipments. In tandem, the EU will ban EU insurers and re-insurers from covering these blacklisted vessels. This measure targets marine insurers in the EU and is designed to ground the shadow fleet globally by making it difficult to obtain coverage.
Transactions with Russian oil majors: The last remaining exemptions for Russian oil majors are being removed. The proposal imposes a full transaction ban on Rosneft and Gazprom Neft, Russia’s largest state oil companies[10]. Previously, certain dealings with these entities were tolerated (for instance, to allow oil supplies to third countries), but those carve-outs will end. Once in force, EU persons will be prohibited from any transactions with Rosneft/Gazpromneft, effectively freezing them out of EU-based trade or services.
This aligns with the approach already taken against sanctioned Russian banks, extending the concept of total severance from EU markets to core energy companies.
Third country facilitators: Additionally, third-country oil trade facilitators face new risks. Citing the need to curb circumvention, the Commission aims to sanction oil traders, refiners, and petrochemical companies in third countries that breach the oil embargo or help Russia evade oil restrictions[11]. In practice, the EU is taking measures against major third-country operators that provide revenue streams to Russia. These sanctions particularly affect Chinese entities—two refineries and an oil trader—which are major buyers of Russian crude oil. In addition, the EU is imposing additional sanctions throughout the ghost fleet value chain. The means the inclusion on the sanctions list of Litasco Middle East DMCC, a company based in the United Arab Emirates linked to Lukoil and an essential component of its ghost fleet. Also included are maritime registers of false flags assigned to ships in the ghost fleet, allowing them to continue operating under the false impression that they comply with certification requirements. The measures also target the largest port container operator in the Russian Far East, as well as a leading shipbuilder for the Sovcomflot group.
Aircrafts and vessels
The EU plans to ban re-insurance for used Russian aircraft or vessels by introducing the new Article 5u of Regulation (EU) 833/2014.
The 19th package introduces a prohibition on providing insurance and reinsurance services for aircraft or vessels that were operated by Russian entities or the Russian government, even after their sale or lease to a non-Russian operator. This applies for five years following the transfer of the aircraft, in a view to prevent integration of formerly Russian-operated aircraft into the global fleet with EU-based financial coverage
Financial and Banking Measures
Expanded Banking Bans: The EU is set to broaden its financial sanctions by imposing a full transaction ban and asset freeze on additional Russian banks, including their subsidiaries or operations in third countries[12]. Under earlier packages, major institutions like Sberbank, VTB, and others were cut off from SWIFT or had asset freezes; now the approach is to blacklist more banks entirely (as was done to 23 banks in the 18th round)[13]. By extending to overseas branches or front institutions, this measure closes a loophole where Russian banks could route activities via friendly jurisdictions.
Third-country financial intermediaries: in parallel, the EU continues to leverage the new authority from its last package that allows sanctioning third-country financial actors who “significantly frustrate” EU sanctions[14]. Listed entities face a transaction ban in the EU and asset freeze measures. In the 18th round, for example, two Chinese banks were designated for facilitating transactions for Russia[15]. The 19th package provides more such intermediaries on its list to deter foreign institutions from becoming safe havens for Russian funds. Currently, eight banks and oil traders from Tajikistan, Kyrgyzstan, the UAE, and Hong Kong that are circumventing EU sanctions are subject to a transaction ban. Five additional Russian banks—Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank—are subject to the same measure. Four banks in Belarus and Kazakhstan are also subject to a transaction ban due to their links to Russian financial messaging and payment systems.
Crypto-asst services and payment systems: A headline development in this package is the first-ever EU sanctions on cryptocurrency services. To counter evolving evasion tactics, the EU will prohibit all crypto-asset services involving Russia – effectively a full ban on EU-based crypto platforms serving Russian clients[16]. This goes further than previous restrictions (which capped crypto transfers); now even small crypto transactions or exchanges would be illegal if a Russian individual or entity is involved. The move closes a notable loophole, as crypto had been used to bypass banking sanctions and quietly move funds. EU crypto service providers will need to terminate Russian accounts and implement strict controls to ensure no digital assets can be transferred to or from Russia. In this context, the 19th package therefore imposes sanctions on the founder of A7A5, the Kyrgyz issuer of this currency, and the operator of a platform where large volumes of A7A5 are traded. Transactions using this indexed cyber token have also been banned throughout the EU.
Additionally, the package targets Russia’s domestic financial infrastructure by restricting the MIR payment network and the SBP fast payment system. MIR (Russia’s card payment system) had sought acceptance abroad to sidestep Visa/Mastercard bans; the EU now plans to prohibit any EU dealings that support MIR cards. Likewise, services related to SBP (Russia’s instant payments system) will be curtailed. These steps will further isolate Russia’s financial system by ensuring Russian payment instruments are not connectable to EU networks.
Listings of major economic operators: The Commission also indicated it would add “large economic operators” to the sanctions list – likely referring to significant Russian state-owned enterprises or oligarch-linked companies that generate revenue for the state or support the military[17]. Therefore, 69 new individual entities (natural or legal persons) are listed on the sanction list.
Technology and Export Controls
Widening export bans: The 19th sanctions package adds numerous industrial items (including salts and ores, articles of rubber, tubes, tyres, millstones, construction materials) and high-tech items (including electronic components, rangefinders, additional chemicals used in the preparation of propellants, energetic materials and precursors, additional metals, oxides and alloys) to the export prohibition list, targeting products that Russia could use to sustain its war machine. These items, while not weapons themselves, can be repurposed for military use (for instance, specialty metals and chemicals for weapons manufacturing). The 18th package had already banned 180 additional commodity codes ranging from machine tools to bearings and engines[18]; the 19th round builds on this by further plugging gaps in the export control regime.
Entity listings for export controls: Crucially, 45 new entities (companies, research institutes, etc.) in Russia and third countries (12 in China, including Hong Kong, 3 in India and 2 in Thailand) have been added to the EU’s export blacklist[19]. They are considered as directly supporting Russia’s military and industrial complex by, inter alia, enabling the circumvention of export restrictions on computer numerical control (CNC) machine tools, microelectronics, unmanned aerial vehicles (UAVs) and other advanced technology items, which might generally contribute to the technological enhancement of Russia’s defence sector. Once blacklisted (e.g. via Annex IV of Reg. 833/2014 for military end-users), EU exporters cannot ship any dual-use or high-tech items to those entities without authorization[20].
High-Tech Services and Data Restrictions: For the first time, the EU is also proposing to restrict certain services and intellectual outputs to Russia by making prior authorisation mandatory for all services provided to the Russian government. The 19th package will ban the provision of advanced tech services such as commercial space-based services, AI services, and high-performance computing services to Russian clients, including the Russian government[21]. This novel measure recognizes that not only goods, but also services (e.g. satellite imagery analysis, AI software support, cloud computing power) can significantly enhance Russia’s military or surveillance capabilities. This include ban on new investments in certain Russian special economic zones (SEZs) that are linked to the war effort[22],preventing the injection of EU capital and expertise into strategic industrial Russian sectors.
Transport and Logistics Measures
Maritime Transport – Blacklisting of Shadow Fleet
As noted under energy measures, the EU’s action against the maritime “shadow fleet” is a central feature of the 19th package. By blacklisting an additional 117 vessels (tankers and freighters) suspected of covertly transporting Russian oil or otherwise contributing to sanctions evasion, the EU has expanded the total number of designated vessels to 557. These vessels are now prohibited from receiving any services within EU jurisdiction, including insurance, reinsurance, certification, bunkering, technical support, and port access.
This measure applies not only to Russian shipowners but also to non-Russian operators knowingly assisting in sanctions circumvention. Shipowners, charterers, and maritime service providers worldwide must conduct enhanced due diligence to ensure they are not directly or indirectly dealing with a listed vessel. Owners and operators of sanctioned vessels are subject to asset freezes and travel bans under Council Regulation (EU) No 269/2014. The scale of this maritime sanctions expansion is unprecedented and signals a clear EU intention to structurally disrupt Russia’s oil export logistics.
Aviation and Travel
As noted above, the 19th sanctions package reinforces the EU’s aviation restrictions by extending prohibitions on insurance and reinsurance services for aircraft of Russian origin in certain secondary markets. The measure is designed to prevent Russian-owned or previously Russian-operated commercial aircraft—many of which were unlawfully seized from Western leasing companies in 2022—from being reintegrated into global fleets through resale or transfer to third countries.
This extension complements existing bans that have been in force since 2022, which prohibit:
- The sale, supply, transfer or export of aircraft and aircraft parts to Russia,
- The provision of aircraft leasing services to Russian entities,
- The operation of Russian airlines within EU airspace (which remains strictly prohibited).
The new element is not a blanket ban on reinsurance of any “used Russian aircraft”, but a targeted restriction, applicable where such aircraft are deemed to contribute to sanctions circumvention or to provide economic benefit to Russia.
Logistics and Border Controls
The 19th package strengthens enforcement mechanisms and reinforces existing transport and customs control measures. Authorities are instructed to intensify physical inspections, data monitoring, and cross-border cooperation to detect circumvention.
The "anti-circumvention catch-all" clause —introduced in prior packages and reaffirmed in the 19th— empowers authorities to require export authorisations to third countries where there is a risk of diversion to Russia, even for goods not specifically listed under dual-use controls. This means that:
- Goods in normal commerce can now be subject to licensing requirements purely based on a circumvention risk analysis,
- Exporters, freight forwarders, and logistics providers must expect increased scrutiny and potential delays at customs,
- Authorities in frontline Member States (notably Finland and the Baltic States) have already reported a significant rise in blocked transactions under these enhanced checks.
While no new transit ban for heavy vehicles or machinery was formally added in this package, the enforcement environment has hardened significantly, with the clear intent of closing any remaining logistical loopholes.
Individual and Humanitarian Measures
Sanctions on Deportation of Ukrainian Children: In response to Russia’s human rights violations, the 19th package includes targeted measures against those involved in the abduction and deportation of Ukrainian children. The proposal will list individuals and entities responsible for the abduction, forced adoption, or indoctrination of Ukrainian children[23]. By explicitly addressing this issue, the EU aligns its sanctions with accountability for war crimes and supports international efforts (notably the ICC’s arrest warrant against President Putin for child deportations).
[1] Statement by President von der Leyen on the 19th package of sanctions against Russia, available here.
[2] Ibid.
[3] Russia: Statement by the High Representative/Vice-President Kaja Kallas on the 19th package of sanctions | EEAS, available here.
[4] Ibid.
[5] EU chief seeks sanctions on Russian LNG to pressure Moscow over Ukraine war, Al Jazeera, 19 September 2025, available
here.
[6] Ibid.
[7] New EU sanctions package targets Russian LNG, Artic Today, 22 September 2025, available here.
[8] Ibid.
[9] Statement by President von der Leyen on the 19th package of sanctions against Russia, available here.
[10] Ibid.
[11] Ibid.
[12] Statement by President von der Leyen on the 19th package of sanctions against Russia, available here.
[13] News flash: EU Adopts 18th Sanctions Package, CMS Law, 25 July 2025, available here.
[14] Ibid.
[15] Ibid.
[16] Statement by President von der Leyen on the 19th package of sanctions against Russia, available here.
[17] Russia: Statement by the High Representative/Vice-President Kaja Kallas on the 19th package of sanctions | EEAS, available here.
[18] News flash: EU Adopts 18th Sanctions Package, CMS Law, 25 July 2025, available here.
[19]Statement by President von der Leyen on the 19th package of sanctions against Russia, available here.
[20] News flash: EU Adopts 18th Sanctions Package, CMS Law, 25 July 2025, available here.
[22] Russia: Statement by the High Representative/Vice-President Kaja Kallas on the 19th package of sanctions | EEAS, available here.
[23] Russia: Statement by the High Representative/Vice-President Kaja Kallas on the 19th package of sanctions | EEAS, available here.
