“It is becoming increasingly difficult for Putin to finance his war. Every euro we deny Russia is one it cannot spend on war. The 19th package will not be the last.” - Kaja Kallas, High Representative for Foreign Affairs and Security Policy and chair of the Foreign Affairs Council 

As part of this package, the Council also imposed further sanctions on Belarus to restrict its support for the Russian war effort, which are not covered in this insight.

This insight discusses the sanctions adopted against Russia. The sanctions against Russia were adopted through 2 Common Foreign and Security Policy (“CFSP”) Decisions, 2 Council Regulations, and 1 Council Implementing Regulation. 

Key Takeaways:

• Russian Energy Sector: 
  
  • The 19^th sanctions package introduces a new ban on imports of Russian liquefied natural gas (“LNG”) into the European Union (“EU”) and tightens the existing transaction ban on Rosneft and Gazprom Neft.
  • It includes new listings of third-country entities active in the Russian oil sector, in particular Chinese operators identified as significant buyers of Russian crude oil (two refineries and an oil trader).
  • New measures target the shadow fleet, such as new listings and extension of the ban on vessels contributing to Russia’s energy revenues to additional 117 vessels. 
• Trade
  
  • 45 new entities (17 of which are located in countries other than Russia) are subject to enhanced export-related restrictions with regard to dual-use and advanced technology items.
  • The EU expands the existing export bans to cover additional items (e.g., electronic components, rangefinders, metals, salts and ores, articles made of rubber, tubes, tyres, construction materials);
  • The package extends the import ban to all acyclic hydrocarbons.
• Financial Sector: 
  
  • 17 additional non-EU banks and oil traders are subject to transaction bans.
  • The package also prohibits the use of two additional payment systems (the Russian National Payment Card System (“Mir”) or the Fast Payments System (“SBP”));
  • It also targets crypto related activities, in particular the stablecoin A7A5 used for sanctions circumvention.
  • Significant restrictions are imposed on activities with entities active in 11 Russian special economic zones.
• Services: 
  
  • The services ban is expanded to cover additional services, such artificial intelligence (“AI”), high-performance computing and commercial space-based services;
  • A prior authorisation is now required for all services provided to the Russian government;
  • The package also introduces a new prohibition to provide services related to tourism activities in Russia.

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Individual Restrictive Measures

New designations – The Council added 22 individuals and 42 entities to its restricted parties list through Council Regulation 2025/2035. 

• These newly listed persons notably include: 
  
  • Two Chinese refineries (Liaoyang Petrochemical Company and Shandong Yulong Petrochemical Co., Ltd.) and one oil trader (Chinaoil (Hong Kong) Corporation Limited) that are significant buyers of Russian crude oil;
  • A Dubai-based subsidiary of Lukoil (Litasco Middle East DMCC) that have enabled the procurement of shadow fleet vessels;
  • Three maritime registries providing false flags to shadow fleet vessels;
  • A Russian developer of the stablecoin A7A5, a Kyrgyz issuer and crypto-currency platform where this coin is traded; 
  • Several businesspersons and entities forming part of the Russian military-industrial complex, and operators from the United Arab Emirates and China producing or supplying sensitive goods to Russia;
  • Russian largest gold producer (PJSC “Polyus”). 
• In total, as of 23 October 2025, 1,980 individuals and 683 entities were designated under Regulation 269/2014. The newly listed individuals and entities are subject to asset freeze. The individuals are additionally subject to a travel ban. 

Inclusion of the definition of “ownership” and “control” – To harmonize the terminology across EU legal acts and ensure a consistent application of Regulation 269/2014, the Council included in this Regulation definitions of “owning” and “controlling” an entity. These definitions essentially reproduce those provided in the EU Best Practices last updated on 3 July 2024. 

Removal of “associated” persons from the asset freeze provision – The asset freeze provision no longer states that the obligation to freeze funds and economic resources of listed persons and the prohibition on making funds and economic resources available to such persons also apply to individuals and entities associated with listed persons. 

New designation criteria – The Council can now designate individuals and entities responsible for, supporting or implementing actions or policies contributing to the deportation, forced transfer, forced assimilation or militarised education of Ukrainian minors. 

Extension of the insurance-related derogation – The existing derogations allowing payments due by AlfaStrakhovanie Group constituting an indemnity or benefit provided further to the materialisation of a risk was extended to two insurance companies (Gas Industry Insurance Company SOGAZ and Insurance Joint Stock Company ‘VSK’). 

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Sectoral Sanctions

Energy Sector

• New import ban on Russian LNG – The EU introduces a ban on purchase, import or transfer of LNG falling under CN code 2711 11 00, and on the provision of related services, if it originates in or is exported from Russia.
  
  • Contract-dependant date of entry into force: This import ban starts on: 
    
    • 1 January 2027 for contracts for the supply of LNG (excluding a natural gas derivative) the duration of which exceeds one year, concluded before 17 June 2025 and not amended thereafter (except for some specific amendments); and 
    • 25 April 2026 for other contracts. 
  • The Council underlined that this import ban shall be complied with regardless of any provision pursuant to other EU legislation with overlapping scope.   

• Vessels contributing to Russia’s energy revenues (Annex XLII) –
  
  • New vessels listed – Additional 117 vessels are subject to a port access ban and a ban on the provision of a range of services, bringing the total number of the vessels subject to these bans to 557 (4 vessels have been delisted). 
  • New listing criteria – The Council can now list vessels transporting Russian mineral products (in addition to crude oil and petroleum products) using irregular and high-shipping practices.
  • Expansion of the ban to cover reinsurance services – It is now also prohibited to provide reinsurance services to the vessels listed in Annex XLII. 

• Expansion of the list of partner countries for importation of petroleum products (Annex LI) – The list of partner countries was expanded to include Australia, Japan and New Zealand.

Export/Import-Related Restrictions

• Export ban on dual-use (Annex I to Regulation 2021/821) and advanced technology items (Annex VII or Regulation 833/2014) 
  
  • New advanced technology items listed (Annex VII) – The prohibition on the export of advanced goods and technology has been further strengthened to cover energetic, rangefinders, additional chemicals used in the preparation of propellants, additional metals, oxides and alloys used in the manufacturing of military systems. See the complete list below. 
  • New entities subject to enhanced restrictions in relation to dual-use and advanced technology items (Annex IV) – The Council added 45 new entities to Annex IV of Regulation 833/2014. Among the newly listed entities, 12 are registered in China (including Hong Kong), 3 in India and 2 in Thailand. These third countries operators are considered to indirectly contribute to Russia’s military and technological enhancement through the circumvention of export restrictions, including on computer numerical controlled machine tools, on microelectronics, and UAV.

• Export ban on industrial goods (Annex XXIII) – 
  
  • New listed items – Additional items (e.g., salts and ores, articles of rubber, tubes, tyres, millstones and construction materials) are now subject to export-related restrictions. 
    
    • Wind-down exemptions:
      
      • For the goods falling under CN codes 6902 and 6909 19 allowing the execution until 25 April 2026 of contracts concluded before 24 October 2025;
      • For the goods listed in new Annex XXIIIG allowing the performance until 25 January 2026 of contracts signed before 24 October 2025. 
  • Extension of the derogation for personal household use – The national competence authorities (“NCAs”) can now also authorise the export of goods falling under CN code 8423 10 and the provision of related technical or financial assistance necessary for personal household use of individuals in Russia.

• Export ban on luxury goods (Annex XVIII) – For housekeeping purposes, some items have been removed from Annex XVIII, but are still listed in Annex XXIII so they remain subject to an export ban. 

• Import ban on goods generating significant revenues for Russia (Annex XXI) –
  
  • New listed items – All acyclic hydrocarbons falling under CN code 2901 originating in or exported from Russia are now subject to import ban. ‍
  • New exemptions for acyclic hydrocarbons falling under CN code 2901 10 00 – 
    
    • Wind-down exemption allowing the execution until 25 January 2026 of contracts signed before 24 October 2025.
    • Temporary exemption allowing the import to Hungary of these goods between 26 January and 25 July 2026 provided that they are intended for exclusive use in Hungary.‍
  • Extension of the Budapest metro derogation to additional items – The derogation allowing the NCAs to authorize the import of goods necessary for the operation, maintenance or repair of Budapest metro line 3 cars was extended to cover two additional items falling under CN codes 8424 10 00 and 8516 29 50.‍
  • New derogation related to UV lamps – The NCAs can allow authorise the import of goods falling under CN code 8539 49 or the provision of related technical or financial assistance necessary for the operation, maintenance or repair of UV lamps used for the disinfection of drinking water.

Transaction Ban Targeting Rosneft and Gazprom Neft (Annex XIX)

The Council strengthened the restrictions targeting the two Russian energy majors, Rosneft and Gazprom Neft, by excluding them from some existing exemptions.    

• Exclusion of Rosneft and Gazprom Neft from the scope of certain exemptions – 
  
  • Rosneft – Two exemptions allowing transactions strictly necessary for the import or transport of (i) natural gas, titanium, aluminium, copper, nickel, palladium and iron ore from or through Russia into the EU, the European Economic Area, Switzerland, or the Western Balkans, and (ii) oil from or through Russia, are not applicable to Rosneft, except for transit of oil or refined petroleum products originating in a third country that are only being loaded in, departing from or transiting through Russia, provided that both the origin and the owner of those goods are non-Russian.   
  • Gazprom Neft – The two abovementioned exemptions as well as the one allowing certain transactions related to energy projects outside Russia are not applicable to Gazprom Neft.

• New exemptions for Rosneft and Gazprom Neft – However, the Council introduced a new exemption allowing transactions  with Rosneft and Gazprom Neft which are necessary for the trading, brokering, transport, of Russian crude oil (falling under CN code 2709 00) and petroleum products (falling under CN code 2710), and for the provision of related services, provided compliance with the oil price cap and without prejudice to the prohibition in Article 3m of Regulation 833/2014.

Financial Sector

• New restrictions targeting 11 Russian special economic zones (Annex LII) – The Council underlined that these zones, which are designed to attract direct investment and promote industrial, technological and innovative capacity, are contributing to the Russian war effort and are central to Russia’s economic reorientation towards Asia, as well as to the circumvention of EU sanctions. 
  
  • Prohibition to enter into or maintain agreements with entities active in these zones – It is now prohibited to enter into the following agreements or maintain them (as of 25 January 2026):
    
    • Acquire or extend any participation in ownership or control of entities registered or operating in these zones;
    • Create any new JVs, branch or representative officers in these zones or with entities located or operating in these zones; 
    • Enter into any new contract for the supply of goods or services, or of related intellectual property to, from or for use in these zones or with entities registered or operating in these zones;
    • Entities outside these zones that are owned or controlled by the entities mentioned above.
  • Prohibition on investment – It is also prohibited to provide financing to such entities and investment services related to prohibited activities mentioned above. 
    
    • Wind-down exemption – These restrictions do not apply to the execution until 25 January 2026 of contracts concluded before 24 October 2025.
    • Exemptions – There are several exemptions notably related to health emergencies, import of natural gas, titanium, aluminum, oil or transfer of seaborn crude oil and petroleum products.   
    • Derogations – The NCAs can authorize otherwise prohibited activities, notably those is strictly necessary for (i) humanitarian purposes, (ii) research, development and manufacturing of pharmaceutical, medical or agricultural products, (iii) ensuring access to proceedings in a Member State, (iv) divestment and withdrawal from Russia, etc.   

• Extension of the crypto-asset services ban – In addition to the prohibition to provide crypto-asset services to Russian nationals and residents, it is now prohibited to provide:
  
  • Issuing of payment instruments, acquiring of payment transactions, or payment initiation services; and
  • Issuing of electronic money services. 
    
    • The Council underlines that these restrictions should not be understood as imposing obligations on payment initiation service providers to determine the nationality, residence or place of establishment of payment service users on a transaction-by-transaction basis, nor on acquirers of payment transactions to conduct sanctions screening of individual payment card transactions. Primary responsibility for sanctions compliance in relation rests with the account-servicing payment service provider.‍
  • New exemption – It is now allowed to provide personalised security credentials necessary to access an account with a credit institution or an electronic money institution established in a Member State or a partner country (as listed in Annex VIII). 
  • Derogation – The NCAs can authorize provision of otherwise prohibited services if they are for the exclusive use of Russian entities that are owned by, or solely or jointly controlled by an entity which is incorporated or constituted under the law of a Member State or a partner country (as listed in Annex VIII). 

• New transaction ban targeting certain crypto-assets (Annex LIII) – It is now prohibited to engage in any transaction involving the crypto-assets listed in Annex LIII, which only include A7A5 (with entry into force on 25 November 2025). 

• Restrictions on entities using Russian payment services – 
  
  • Extension of the transaction ban to cover additional entities using Russian payment services (Annex XLIV) – The transaction ban was expanded to cover any non-Russian entity listed in Annex XLIV that use any systems of the Central Bank of Russia (“CBR”) and any other systems that include a financial messaging functionality, including SBP and Mir.
    
    • 4 additional Belarus and Kazakh banks (CJSC Alfa-Bank (Belarus), OJSC Sber Bank (Belarus), VTB Bank (Belarus), and VTB Bank (Kazakhstan)) will be subject to the transaction ban as of 2 December 2025. 
    • New wind-down exemptions – This transaction ban does not apply (i) to the execution of contracts signed before 24 October 2025 until 25 April 2026, and (ii) to the reception of payments due by listed banks by 24 October 2025 pursuant to contracts performed before 25 April 2026.
  • Extension of the ban on the use of Russian payment services – As of 25 January 2026, it is prohibited to connect to any systems of the CBR or to systems provided by any Russian entity that include a financial messaging functionality, including SBP and Mir. This restriction was previously limited to the System for Transfer of Financial Messages of the CBR. 
    
    • New exemptions – This ban does not apply to transactions (i) necessary for diplomatic and consular representations, (ii) made by EU citizens residing in third countries, or (iii) necessary for Member States’ historical responsibility programmes or for the support of Member States’ ethnic minorities in Russia.

• Transaction ban on Russian banks (Annex XIV) –  
  
  • New listings – 5 new banks were included in Annex XIV (‘NPO “Istina” (JSC), LLC “Zemsky Bank”, Commercial Bank Absolut Bank (PAO), PJSC “MTS Bank”, JSC “ALFA-BANK”) and are subject to a transaction ban as of 12 November 2025. 
  • New exemptions – The Council introduced several exemptions allowing transactions with listed banks, notably when they are necessary for export or transport of pharmaceutical, medical or agricultural products, for humanitarian purposes, for the reception of certain payments due by the entities listed in Part A of Annex XIX, etc. 
• Transaction ban on the entities providing crypto-asset and payment services (Annex XLV) –  
  
  • New listing – 6 banks (Payyer, CJSB JSCB Tolubay, OJSC Eurasian Savings Bank, CJSC Dushanbe City Bank, CJSC Spitamen Bank (Tajikistan) and OJSC Commerce Bank of Tajikistan) were included in Part A of Annex XLV and oil traders (‘Blackford Corporation Limited and Fuel and Oil Dynamics FZE) in Part C of Annex XLV. These entities will be subject to a transaction ban as of 12 November 2025, except for Payeer for which it will apply as of 25 November 2025.
  • Extension of the listing criteria to target “payment services” providers – In addition to crypto assets services providers, the EU can now subject “payment services” providers to this transaction ban.   
  • Extension of the transaction ban to “mirror or successor” entities – The transaction ban now also applies to any non-listed crypto-asset or payment services provider that operates as a mirror or successor entity (defined in Regulation 833/2014) of an entity listed in Annex XLV. 
  • New wind-down exemptions for the entities newly listed in Part A of Annex XLV – The transaction ban does not apply to transactions with these entities, if they are necessary: 
    
    • For the execution, until 25 April 2026, of contracts concluded before 24 October 2025; and
    • For the reception of payments due by these entities pursuant to contracts performed before 24 October 2025. 

Restricted Services 

Article 5n of Regulation 833/2014 has been fully revamped and new services have been added to the list by the Council. 

• Extension of the services ban to cover additional services – 
  
  • It is now also prohibited to provide integrated engineering, urban planning, engineering-related scientific and technical consulting to the Government of Russia or to entities established in Russia;
  • As of 25 November 2025, it will be also prohibited to provide the following services to the Government of Russia or to entities established in Russia: 
    
    • Commercial space-based services consisting of Earth observation or satellite navigation;
    • AI services consisting of access to models or to platforms for their training, fine-tuning and inference;
    • High-performance computing, including access to graphic processing unit -accelerated computing, or quantum computing services.
  • Exemptions and derogations – There are several exemptions and derogations for the provision of these new restricted services which are in presented in the table below.

• New authorization requirement for the provision of any service to the Government of Russia – The provision of any service to the Government of Russia is now subject to a prior authorization from the NCAs. 
• New prohibition to provide services related to tourism in Russia – It is now prohibited to provide services directly related to tourism activities in Russia.
• Wind-down exemption – The provision of services to the Government of Russia and services related to tourism is allowed for the execution until 1 January 2026 of contracts concluded before 24 October 2025.

Transport Sector 

• New prohibition to enter into arrangement regarding vessels or aircraft operated by the Government of Russia or Russian entities – It is now prohibited, during the five years following the sale or any form of lease arrangement of vessels or aircraft that were operated by the Government of Russia or by any entity established in Russia, to enter into any contract or arrangement which results in the transfer of risks from, or the ceding of exposure to risks associated with, insurance coverage for such vessels or aircraft.

• Extension of the transaction ban targeting ports and locks (Annex XLVII) – The transaction ban has been extended to ports and locks in third countries other than Russia listed in new Part C of Annex XLVII (currently empty) that are notably used to transfer UAVs, missiles or related technology or components thereof to Russia, or for the circumvention of other EU restrictive measures, including the oil price cap.

Wind-Down and Divestment in Russia

• General extension of the wind-down period to divest from Russia – Recognising that multiple new laws and regulations adopted by Russia are preventing some EU operators from exiting the country, the Council extended the deadline for some divestment derogations (under Articles 5aa.3(d), 5aa.3a, 11.4, 12b.1, 12b.1a, 12b.2, 12b.2a) to 31 December 2026.

• Extension of the derogation for divestment from a JV operating a gas pipeline between Russia and third countries to additional items – The derogation allowing the NCAs to authorize the export or transfer of items listed in Annex II of Regulation 833/2104 (energy related) necessary for the divestment from such JV has been extended to items listed in Annexes VII (advanced technology items) and XXIII (industrial goods).   

Public Concession Contracts

• Extension of the prohibition to provide public concession contracts – It is now also prohibited to award or continue the execution of any public or concession contract to or with any entity owned for more than 50% by a Russian national or resident. 

Annexes

Exemptions and Derogations Allowing the Provision of Newly Restrictions Services under Article 5n of Regulation 833/2014

New Advanced Technology Items (Annex VII)

New Industrial Goods (Annex XXIII)

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