Adoption of the EU 19th sanctions package against Russia

On 23 October 2025, the European Union adopted its 19th sanctions package against Russia.

The core rationale is two-fold:

• Sustaining Economic Impact by striking at high-value revenue streams like energy,

and

• Combating Circumvention by explicitly targeting third-country enablers and emerging technologies like cryptocurrency.

The new regulations introduce wide-ranging restrictions that demand immediate review of compliance frameworks:

1. Energy and Maritime Sector

The primary focus is on Russian energy exports and closing circumvention routes via the “shadow fleet.”

• LNG Ban: Phased ban on Russian LNG imports: six months for short-term contracts; January 2027 for long-term contracts.
• Major Oil Companies: Full transaction ban on major state-owned oil producers, Rosneft and Gazprom Neft.
• Shadow Fleet Crackdown: 117 additional vessels sanctioned, bringing the total to 557 designated vessels banned from EU ports and services. New bans also cover reinsuring shadow fleet vessels.
• Enablers Targeted: Sanctions hit key maritime players (Litasco Middle East DMCC, port operators, shipbuilders) and Chinese entities (two refineries and an oil trader) buying Russian crude.
• Commodities: New import ban on all acyclic hydrocarbons and sanctions on Russia’s largest gold producer.

2. Financial Measures and Cryptocurrency

Aggressive steps against evasion involve hitting foreign banks and digital assets for the first time.

• Third-Country Banks: Transaction bans imposed on eight banks and oil traders from Tajikistan, Kyrgyzstan, the UAE, and Hong Kong for sanctions circumvention.
• Russian Banks: Five additional Russian banks (Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank) are put under a full transaction ban.
• Payment Systems: EU operators are prohibited from engaging with the Russian National Payment Card System (‘Mir’) or the Fast Payments System (‘SBP’).
• Cryptocurrency Restrictions: Sanctions imposed on the developer, issuer, and platform operator of the rouble-backed stablecoin A7A5, with transactions involving the coin now prohibited across the EU.
• Expanded Services Ban: Prohibition on providing certain crypto-related payment services and software (including for banking, finance, and AI) is expanded.

3. Trade and Anti-Circumvention (Industrial/Military)

The EU targets the foreign supply chains enabling the military-industrial complex.

• Entity Listings (45 Entities): 45 new entities are subject to tighter export restrictions for supporting Russia’s military. 17 of these entities are in third countries, 12 in China (including Hong Kong), three in India, and two in Thailand.
• Export Restrictions Expanded: Existing export bans are widened to include: electronic components, rangefinders, chemicals/metals for propellants, and more stringent restrictions on industrial goods (e.g., salts and ores, construction materials).

4. Special Economic Zones (SEZs) and Services

New measures restrict Russia’s industrial base and access to specialized EU expertise.

• SEZs: Significant restrictions imposed on economic relationships with entities in nine Russian special economic zones.
• Government Services: Prior authorisation is mandatory for all services provided to the Russian government.
• Technology Services: Restriction on the provision of AI services, high-performance computing services, and commercial space-based services to Russian entities, including the Russian government.
• Tourism Services: Prohibition on European operators from providing services directly related to tourism activities in Russia.

5. Human Rights, Diplomacy, and Belarus

• Children/Human Rights: 11 additional individuals sanctioned for involvement in the abduction and forced assimilation of Ukrainian children. A new listing criterion is introduced for crimes against Ukrainian minors.
• Russian Diplomats: New travel notification requirements for diplomats moving across the Schengen area, with EU states permitted to impose an authorisation requirement to counter hostile intelligence activities.
• Belarus Provisions: Five new listings related to the Belarusian military-industrial complex are included, and the package further mirrors Belarus’ trade measures with those imposed on Russia.

Conclusion

Overall, the EU’s message is clear, the sanctions landscape is dynamic and continuously evolving. As the regime grows more complex and far-reaching, the financial and reputational stakes for non-compliance are higher than ever. This makes it essential for organisations to adopt robust, integrated compliance frameworks supported by effective technological tools that provide the oversight needed to ensure full compliance.