EU adopts its 19th sanctions package against Russia

On 23 October 2025, the European Council formally adopted the EU’s 19th sanctions package against Russia. The 19th sanctions package was first proposed by European Commission President Ursula Von der Leyen in a statement dated 19 September 2025. 

Following that statement, there were reports that some Member States might veto a decision to adopt the package. However, the concerns of those Member States would appear to have been addressed in time for the package to be adopted unanimously at the European Council meeting in Brussels on 23 October.

The key prohibitions forming part of this latest round of sanctions are set out below.

Russian LNG/Shadow fleet

There is a ban on the import of Russian LNG into European markets within six months for short-term contracts, and from 1 January 2027 for long-term contracts. 

To strengthen enforcement of this prohibition, the EU has sanctioned 117 additional vessels from the shadow fleet. In total, 557 vessels are now listed under EU sanctions. The EU has also imposed additional sanctions along the shadow fleet value chain. Litasco Middle East DMCC has been sanctioned on the basis that this company is said to enable Litasco’s shadow fleet vessels. There is also a ban on reinsuring shadow fleet vessels.

Also sanctioned are a number of maritime registries said to provide false flags to shadow fleets, as well as the largest port container operator in the Russian Far East and a leading ship builder for Sovcomflot.

Major energy trading companies, Rosneft and Gazprom Neft, are now subject to a full transaction ban. Other companies that are deemed to fuel the war in Ukraine by purchasing Russian oil in breach of sanctions have been made subject to asset freezes. They include two Chinese refineries and a Chinese oil trader, as well as a Tatarstani conglomerate active in the Russian oil sector. Oil traders from Tajikistan, Kyrgyzstan, the UAE and Hong Kong that circumvent EU sanctions are subject to a transaction ban. 

Financial prohibitions

A number of banks from Tajikistan, Kyrgyzstan, the UAE and Hong Kong that are said to circumvent 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 also subject to a transaction ban, as are four banks from Belarus and Kazakhstan, due to their connections to Russian financial messaging and payment systems.

For the first time also, there are restrictive measures on crypto platforms and the prohibition of transactions in crypto currencies. The stablecoin A7A5 that has been created with Russian state support has been identified as a prominent tool for financing illicit activities in breach of sanctions. Therefore, sanctions have been introduced on the developer of A7A5, the Kyrgyz issuer of that coin and the operator of a platform where significant volumes of A7A5 is traded. Transactions involving A7A5 have been prohibited across the EU. 

Also sanctioned are foreign banks connected to Russian alternative payment service systems. EU operators are now prohibited from engaging with the Russian National Payment Card System (MIR) or the Fast Payments System (SBP).

The latest sanctions also restrict transactions with entities active in nine Russian special economic zones.

Export restrictions

There are new direct export restrictions for items and technologies used on the battlefield.  The package lists 45 companies in Russia and third countries. These are companies said to have been providing direct or indirect support to the Russian military industrial complex. 

These entities are now subject to tighter export restrictions with regard to dual-use goods, as well as items which might generally contribute to the technological enhancement of Russia’s defence sector. Seventeen of these entities are located in third countries (twelve in China, including Hong Kong, three in India and two in Thailand).

The package also expands the existing export ban to include electronic components, rangefinders, additional chemicals used in preparing propellants and additional metals, oxides and alloys used in the manufacturing of military systems.

Salts and ores, articles made of rubber, tubes, tyres, millstones and construction materials will also be subject to more stringent export restrictions. There is now also a prohibition on purchasing, importing or transferring all acyclic hydrocarbons.

The EU has also sanctioned Russia’s largest gold producer.

Service restrictions

Prior authorisation is now mandatory for all services provided to the Russian Government. There is also a restriction on the provision of AI services, high-performance computing services and commercial space-based services to Russian entities, including the Russian Government.

Belarus

Finally, as part of the package, the EU has imposed further restrictions on Belarus.

Related measures

Reparations

Discussions continue on the proposed use of the Euros 175 billion worth of frozen Russian assets towards securing sustainable funding for Ukraine, with the aim of releasing those funds by mid-2026.

Shadow fleet

Concerns have been expressed that the shadow fleet vessels do not only allow circumvention of sanctions but also present a major maritime risk. It is estimated that hundreds of oil tankers are operating under opaque ownership and without adequate insurance or credible certification. Many of these oil tankers are old and poorly maintained and pose significant risk of casualties and environmental disasters.

It is reported that discussions are ongoing on a declaration that would give Member States authority to board shadow fleet vessels and to allow bilateral agreements with flag states that would permit EU Member States to board and inspect vessels. 

The question remains, however, what action would be legally permitted after boarding and inspection of a shadow fleet vessel. Under the United Nations Convention on the Law of the Sea (UNCLOS), signatory states have freedom of navigation and the right of innocent passage.

Comment

In line with the EU’s latest initiative, on 15 October 2025, the UK sanctioned Rosneft and Lukoil, four Chinese oil terminals and an Indian refinery, as well as 44 additional tankers forming part of the shadow fleet. Gazprom Neft was sanctioned by the UK in January 2025.

Additionally, on 22 October 2025, the US sanctioned Rosneft and Lukoil and various subsidiaries associated with these two refineries, subject to various General Licences.

There is already talk of a 20th EU sanctions package. It remains to be seen what further sanctions measures the international community will impose on Russia.