The EU’s 19th sanction package on Russia
The Council of the European Union (the “EU”) adopted on 23 October 2025 its 19th package of sanctions against Russia.
Please find our previous blog posts on the sanctions here, here, here, here and here.
Russia’s energy sector – A new ban on import of LNG and further sanctions against the shadow fleet
The EU introduces a new ban on imports of Russian liquefied natural gas (LNG), starting January 2027 for long-term contracts, and within six months for short-term contracts. A full transaction ban will be imposed on the major state-owned fossil fuel companies Rosneft and Gazprom.
Furthermore, the EU is taking measures against important third country operators enabling Russia’s revenue streams, including Chinese entities – two refineries and an oil trader – that are significant buyers of Russian crude oil.
The EU has also added 117 additional vessels that are part of the Russian “shadow fleet” which attempts to sell Russian oil while avoiding sanctions, transport military equipment, or sell stolen Ukrainian grain. The total number of vessels listed as part of the shadow fleet is now 557. The package also imposes additional sanctions across the shadow fleet value chain, including Litasco Middle East DMCC, Lukoil’s prominent shadow fleet enabler based in the United Arab Emirates.
Russia’s banking sector – Additional sanctioned bans and new ban on cryptocurrencies
Five Russian banks and five third-country banks in Central Asia that support Russia’s war have been added to the transaction ban. New bans also target Russia’s payment card and fast payment systems (Mir and SBP). The measures also list four new Belarusian and Kazakh financial institutions that use the Russian payment system (SPFS).
The package also targets cryptocurrencies and services, banning the rouble-backed stablecoin A7A5 and a Paraguayan exchange. For the first time, the measures include a ban on the use of the sanctioned cryptocurrency. The measures aim to close loopholes and prevent circumvention of sanctions. Additionally, EU operators are banned from providing crypto services that enable Russia to develop its own financial infrastructure and potentially circumvent sanctions.
Trade measures – New individual sanctions, export restrictions and export bans
The package sanctions individual businesspersons and companies forming part of the Russian military-industrial complex, as well as operators from the UAE and China supplying military and dual-use goods to Russia. New export restrictions are introduced on additional dual-use items and technologies, including metals for weapon system construction and products used in propellant preparation. The package bans exports of items such as salts and ores, construction materials, and rubber articles. The banned items correspond to an estimated value of EUR 155 million of EU exports at 2024 prices.
Specific restrictions on economics with entities active in nine Russian special economic zones have also been introduced. EU businesses are banned from entering into new contracts with any entity established in these zones, which are designed to attract foreign investment and to drive economic growth and infrastructure development, and full transaction bans will be placed on two of the zones (Alabuga and Technopolis Moscow).
Anti-circumvention measures
The package adds 45 new entities to the list of those providing direct or indirect support to Russia’s military industrial complex or engaged in sanctions circumvention. These entities will be subject to tighter export restrictions with regard to dual-use goods and items which may contribute to the technological enhancement of Russia’s defence sector. The affected entities are based in Russia, China, India and Thailand.
Other measures
Re-insurance services are prohibited for Russian vessels and aircraft for up to five years after their sale to third countries.
As a measure to deter increasingly hostile intelligence efforts, Russian diplomats must inform EU member states in advance when they intend to travel beyond their country of accreditation.
Eleven additional individuals involved in the abduction, forced assimilation, and indoctrination of Ukrainian children are also sanctioned. A framework has been adopted to streamline similar sanctions in the future.
Concluding remarks
The 19th package continues the broad approach of previous sanctions instalments, further expanding the network of prohibitions. Further sanction packages should be expected as long as Russian hostilities continue.
As the number of regulations and sanctions continue to grow, compliance continues to be of utmost importance for all companies within the EU. As always, Delphi is available for advice and assistance in how to ensure and maintain compliance with the sanctions regime.