The 19th sanctions package against Russia

The additions consist of Regulation (EU) 2025/2033 amending Regulation (EU) No. 833/2014. Regulation (EU) 2025/2037 and Implementing Regulation 2025/2035 amending and implementing Regulation (EU) No. 269/2014, respectively. Regulation (EU) 2025/2041 amending Regulation (EC) No 765/2006, and Implementing Regulation (EU) 2025/2039 implementing Article 8a(1) of that Regulation (Belarus).

Below, we provide a brief overview of the most important additions and amendments and the resulting implications for European companies. 

I. Background

Most recently, EU member states agreed on the 18th sanctions package, imposing comprehensive financial and economic sanctions on Russia and Belarus.

The focus was primarily on further measures against Russia's “Shadow Fleet,” the introduction of a dynamic oil price cap, and an import ban on refined petroleum products.

The transaction bans on Russian banks were also extended, as was the list of goods that contribute to Russia's military and technological strength or to the development of its defense and security sector.
The current sanctions package adds further restrictions, thereby significantly expanding the existing sanctions.

II. The 19th sanctions package

On October 23, 2025, the EU member states adopted Regulation (EU) 2025/2033 amending Regulation (EU) No. 833/2014, Regulation (EU) 2025/2037 amending Regulation (EU) No. 833/2014, and Implementing Regulation 2025/2035 implementing Regulation (EU) No. 269/2014, Regulation (EU) 2025/2041 amending Regulation (EC) No. 765/2006, and Implementing Regulation (EU) 2025/2039 implementing Regulation (EC) No. 765/2006, further individual and economic sanctions.

The package of measures focuses on the following points:

• Additional dual-use goods will be subject to export bans. These include electronic components, rangefinders, additional chemicals for the production of fuels, and additional metals, oxides, and alloys for military systems. Salts and ores, articles made of rubber, tubes, tyres, millstones and construction materials will be subject to strict export restrictions.
• A full ban on purchasing, importing, or transferring any acyclic hydrocarbons into the Union if they originate in Russia or are exported from Russia will also be imposed.
•  Forty-five new organizations that support the Russian military-industrial complex have been identified. These organizations will be subject to stricter export restrictions on dual-use goods and products that could generally contribute to the technological strengthening of the Russian defense sector. 17 of these organizations are located in third countries outside Russia (twelve in China, including Hong Kong, three in India, and two in Thailand).
• In addition, an import ban on Russian Liquefied Natural Gas (LNG) into the EU will be imposed from January 2027 for long-term contracts. For short-term contracts, it will apply within six months of the sanctions coming into force.
• Furthermore, the existing transaction ban on two of Russia's major state-owned oil producers (Rosneft and Gazprom Neft) will be tightened. The exemption that had previously existed for imports from these two companies into the EU will be abolished.
• A further 117 ships belonging to the Russian Shadow Fleet will be subject to sanctions. In addition, these ships will be banned from entering European ports. The provision of various services to these ships will also be prohibited. The aim is to cover the entire value chain of the Russian shadow fleet. This means that 557 ships are now subject to sanctions by name.
• As Russia increasingly uses cryptocurrencies to circumvent sanctions, these are now the focus of sanctions for the first time. The use of the stablecoin “A75A5,” which is pegged to the ruble, will be banned throughout the EU, and sanctions will be imposed on the developers, the Kyrgyz issuers, and the platform operators.
• Five other banks (Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank and Alfa-Bank) in Russia and 12 banks and oil traders from Tajikistan, Kyrgyzstan, the United Arab Emirates, Hong Kong, Belarus and Kazakhstan will be subject to a transaction ban.
• Furthermore, prior authorization will be required for all services to be provided to the Russian government.
• With regard to the financial sanctions imposed, it should be noted that not only a further 69 individuals were listed and thus individually sanctioned, but also that a dogmatic amendment was made to Sanctions Regulation (EU) No 269/2014: On the one hand, the terms “owning” and “controlling” were legally defined, and on the other hand, the sanction criterion “natural or legal persons, entities or bodies associated with them” was deleted from Article 2. Although neither of these changes will fundamentally alter the enforcement of sanctions or compliance requirements in the member states, they represent an important step toward greater legal clarity and are therefore very welcome from the application perspective.

III. Outlook and conclusion

The sanctions in the 19th package represent another decisive step in Europe's response to Russia's ongoing war against Ukraine. With these measures, the EU is attempting to further increase economic and political pressure on Russia in order to continue raising the costs of continuing the war. In addition, the issue of sanctions evasion is also being consistently addressed.

The comprehensive package of measures once again poses a challenge for export control and sanctions compliance for European companies. They are obliged to adapt to the latest changes immediately and integrate them into their existing internal compliance programs. In view of the severe penalties for violations of sanctions regulations, a preventive legal review of established processes from time to time is strongly recommended. 

Council Regulation (EU) 2025/2033 of 23 October 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Implementing Regulation (EU) 2025/2035 of 23 October 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Regulation (EU) 2025/2037 of 23 October 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Implementing Regulation (EU) 2025/2039 of 23 October 2025 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

Council Regulation (EU) 2025/2041 of 23 October 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine