On Thursday, 23 October 2025, the EU’s foreign and defence ministers approved what is now its 19th sanctions package in response to Russia’s war of aggression against Ukraine. The package includes a ban on imports of Russian liquefied natural gas and further sanctions against its shadow fleet. The EU has also imposed additional sanctions on Belarus to restrict its ongoing support for Russia’s war against Ukraine.
The EU’s latest measures build on its 18th sanctions package, adopted in July, which already targeted Russia’s shadow fleet, financial institutions and persons connected to Russia’s military-industrial complex (our report: Foreign Trade Law Update: 18th Package of EU Sanctions against Russia | Gleiss Lutz). The current steps focus on further tightening and extending these existing restrictions. The EU justifies the new package by citing Russia’s escalating attacks against Ukraine, deliberately targeting civilian infrastructure (such as energy, water and healthcare facilities), and the growing threat to the EU’s security, as underlined by Russia’s recent violations of Polish and Romanian airspace. The 19th sanctions package entered into force on 24 October 2025.
EU sanctions against Russia
The 19th sanctions package mainly incorporates the following acts:
- Amending Regulation (EU) 2025/2033 tightens the largely trade-related sanctions set out in Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.
- Amending Regulation (EU) 2025/2037 largely clarifies and harmonises terminology set out in Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
- Implementing Regulation (EU) 2025/2035 amends Annex I to Regulation (EU) 269/2014, which lists the natural and legal persons subject to financial sanctions.
- Implementing Regulation (EU) 2025/2039 amends Annex I to Regulation (EU) 765/2006 on restrictive measures in view of the situation in Belarus and involvement of Belarus in the Russian aggression against Ukraine, which lists the natural and legal persons subject to financial sanctions.
Particularly noteworthy changes from these legal acts include:
Introduction of a ban on imports of liquefied natural gas (LNG)
In order to reduce Russian gas and oil revenues, the sanctions package contains a ban on importing liquefied natural gas (LNG) from Russia. The new Article 3ra Regulation (EU) 833/2014 prohibits, as of 25 April 2026, the purchase, import or transfer, directly or indirectly, of liquified natural gas if it originates in Russia or is exported from Russia. Contracts with a term of more than one year that were concluded before 17 June 2025 and have not been amended since are exempt from the prohibition until 1 January 2027.
The LNG sector had previously been exempt from EU sanctions. This import ban on liquefied natural gas marks a major step for the EU towards reducing its dependence on Russian energy. The import ban will take effect a year sooner than envisioned in the European Commission’s original draft, posing a significant challenge that will require considerable effort from EU Member States that continue to import large quantities of gas from Russia (in particular Hungary and Slovakia).
Tougher sanctions against Russia’s shadow fleet
The Russian shadow fleet consists of up to hundreds of (often aging and poorly maintained) vessels used by Russia to circumvent the oil price cap set by the EU and export crude oil to destinations such as India. The size of the shadow fleet is now estimated at up to 1,400 ships. To prevent this, Article 3s(1) Regulation (EU) 833/2014 prohibits these vessels from entering EU ports and imposes a comprehensive ban on the provision of services to the vessels listed in Annex XLII to the Regulation that belong to the shadow fleet.
The 19th sanctions package adds an additional 117 vessels suspected of being involved in the circumvention of sanctions to the list in Annex XLII to Regulation (EU) 833/2014. This brings the total number of sanctioned vessels to over 550.
The EU is also expanding the sanctions list in Annex I to Regulation (EU) 269/2014 adding further individuals and entities that have supported the Russian shadow fleet in the past and enabled the circumvention of sanctions. For example, Litasco Middle East DMCC, a United Arab Emirates-based important partner and supporter of the shadow fleet of Russian oil company Lukoil, has now been added to the list. Other listings include maritime registries providing false flags to shadow fleet vessels, as well as one of the largest port container operators in Russia and a leading Russian shipbuilder. One of the effects of listing is that no funds or other economic resources from the EU may be made available to these individuals or entities.
Expansion of sanctions in the financial sector
The 19th sanctions package expands existing financial-sector restrictions to block previously exploited loopholes. Recent activity confirms Russia’s increasing use of cryptocurrency to evade sanctions. The 19th sanctions package now prohibits transactions involving the crypto-assets listed in Annex LIII to Regulation (EU) 833/2014 (Article 5ba). Sanctions will also be imposed on developers and issuers of cryptocurrency and on cryptocurrency platform operators.
The 19th sanctions package also introduces transaction bans on banks and oil traders from third countries (Tajikistan, Kyrgyzstan, the United Arab Emirates and Hong Kong) involved in circumventing EU sanctions. In future, transaction bans will also apply to five other Russian banks (Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank and Alfa-Bank) and to four banks from Belarus and Kazakhstan that have links to Russian financial messaging and payment systems.
Additionally, cooperation with the Russian National Payment Card System (“Mir”) or the Faster Payments System (“SBP”) will be prohibited in future pursuant to Article 5ac Regulation (EU) 833/2014.
Restrictions on economic relationships with entities in Russian special economic zones
The introduction of Article 5ah Regulation (EU) 833/2014 imposes significant restrictions on maintaining economic relationships with entities active in nine Russian special economic zones. These zones are central to Russia’s industrial and technological capacity, hosting enterprises engaged in the production or development of goods contributing to the Russian war effort. For example, it will be prohibited to acquire new participations in entities or to conclude new contracts for the supply of goods.
Further action against Russia’s military-industrial complex
The EU has also expanded the measures against entities operating in Russia’s military-industrial sector. Annex IV to Regulation (EU) 833/2014 now includes a total of 45 new entities that directly support the Russian military-industrial complex, for example by enabling the circumvention of export restrictions on CNC machine tools, microelectronics, unmanned aerial vehicles (UAVs) and other advanced technology items. While the majority of these are headquartered in Russia, twelve are based in China, including Hong Kong, three in India and two in Thailand. Under Article 2b Regulation (EU) 833/2014, these entities are subject to an export ban on dual-use goods and on items that might generally contribute to the technological enhancement of Russia’s defence sector.
The sanctions list in Annex I to Regulation (EU) 269/2014 has also been expanded to include further businesspersons and entities forming part of Russia’s military-industrial complex, as well as operators from the United Arab Emirates and China that produce military and dual-use goods for or supply these to Russia.
Expansion of goods-related import and export restrictions
The 19th sanctions package once again extends the range of goods falling under import and export restrictions. The export bans now also cover electronic components, rangefinders, additional chemicals used in the preparation of propellants, and additional metals, oxides and alloys used in the manufacturing of military systems. Stricter export restrictions apply with immediate effect to salts and ores, articles of rubber, tubes, tyres, millstones and construction materials.
The purchase, import or transfer of acyclic hydrocarbons – previously a significant source of revenue for Russia – is now also prohibited.
Extension of restrictions and bans on services
The package also extends the restrictions on services under Article 5n Regulation (EU) 833/2014, prohibiting the provision of AI, high-performance computing and commercial space-based services to the Russian government or to legal persons, entities or bodies established in Russia.
Providing services directly related to tourism activities in Russia is also banned from now on.
Travel restrictions for Russian diplomats
Russian diplomats will be obliged to inform the relevant EU Member State before travelling to Schengen-area countries other than their country of accreditation (Article 5v Regulation (EU) 833/2014). This is aimed at ensuring that Member States are aware of such movements, against the backdrop of increasingly hostile intelligence activities supporting Russia’s aggression against Ukraine. EU Member States may also impose an authorisation requirement on Russian diplomats who are travelling to the Member State in question based on a visa or residence permit issued by another Member State (Article 5w Regulation (EU) 833/2014).
EU sanctions against Belarus
The new package includes additional sanctions against Belarus, aimed in particular at further aligning the Belarus trade measures with the ones imposed on Russia. It also contains five new listings related to the Belarusian military-industrial complex and the Lukashenka regime.
US sanctions
The United States also announced further sanctions against Russia on 23 October 2025. After much hesitation, punitive measures are to be imposed on Russian oil companies after all – especially Rosneft and Lukoil, with which any economic interaction is to be prohibited. In the US, this is considered one of the most significant steps against the Russian energy sector taken by the US since Russia invaded Ukraine.
Outlook
The EU is stepping up its economic and political pressure on Russia yet again, aiming to further restrict Russia’s economic capacity to act and persuade it to enter into negotiations about ending the war against Ukraine. While the measures build on existing sanctions instruments, the package represents another step in the EU’s consistently pursued strategy to cut Russia off from key international markets and technologies in the long term. The import ban on liquefied natural gas introduced by the 19th sanctions package could make a significant contribution to this, in particular – but could also pose considerable challenges for EU Member States that will have to switch to (and finance) alternative energy sources. Ultimately, the success of the measures depends largely on whether the Member States manage to enforce them consistently.
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