EU-Russia Sanctions: The 19th Sanctions Package

On 24 October 2025, the 19th sanctions package against Russia came into force. The EU is thus setting new standards - particularly in energy trade, financial transactions, and the fight against circumvention structures.

With a complete ban on LNG imports from 2027 and the listing of a total of 557 shadow fleet ships, the sanctions are being elevated to a new level. This presents significant compliance challenges for EU companies - but also strategic opportunities for realigning their business models.

The key measures of the 19th sanctions package:

1. Energy sector: Complete decoupling from Russian LNG

LNG import ban with staggered implementation

The EU introduces a complete ban on the import of Russian liquefied natural gas (LNG):

• From 1 January 2027: Ban on long-term contracts

• Within 6 months of coming into force: Ban on short-term contracts

Companies with existing LNG supply contracts must now develop alternative procurement strategies and diversify their energy supply.

Transaction ban for Rosneft and Gazprom Neft

The existing transaction ban for the energy giants Rosneft and Gazprom Neft has been significantly tightened:

• Lifting of the previous exception for oil and gas imports to the EU.

• Exceptions now only apply for:

  • Oil imports from third countries (e.g., Kazakhstan).

  • Transportation of oil in compliance with the oil price cap.

Sanctions against Chinese energy actors

For the first time, targeted sanctions are imposed on Chinese companies:

• Two refineries and an oil trader as significant buyers of Russian crude oil.

• Signal to third countries: The EU is consistently expanding the range of sanctions.

LPG variant banned

A specific variant of liquefied gas (LPG) is subject to an import ban to prevent circumvention of existing LPG restrictions.

2. Shadow fleet: Further blow against circumvention structures

New total of 557 listed ships

With the inclusion of a further 117 ships, the total number of listed shadow fleet ships rises to 557:

• Port access bans throughout the EU.

• Comprehensive service bans.

• Pressure on flag states for reflagging.

Sanctions along the entire value chain

The EU is targeting supporters of the shadow fleet:

• LITASCO Middle East DMCC (UAE) – a Dubai-based trading subsidiary of the Russian oil company Lukoil.

• Shipping registries providing false flags.

• Two oil trading companies in Hong Kong and the UAE.

3. Financial sector: Cryptocurrencies in focus

First cryptocurrency sanctions

The 19th sanctions package includes the first measures to combat sanctions circumvention in the digital financial sector:

• Ban on the ruble-pegged stablecoin "A7A5".

• Sanctioning the "A7A5" issuer and associated trading platforms.

• Listing of a cryptocurrency exchange in Paraguay.

Expanded banking sanctions

• Transaction ban for five more Russian banks and for five banks from Central Asian countries.

• Four new financial institutions in Belarus and Kazakhstan listed due to usage of the Russian financial transaction system SPFS.

Bans on payment traffic

• Comprehensive ban on the Russian payment card system Mir.

• Ban on the System for Quick Payments (SBP).

• Prohibition of crypto services to develop Russian financial infrastructure.

4. Trade restrictions: New export bans and restrictions

The sanctions package significantly expands export restrictions:

• New export restrictions for additional dual-use goods and advanced technologies (e.g., electronic components and sensors, optical components, measuring and testing devices for mechanical properties like tantalum, chromium oxides, boron, molybdenum alloys).

• New export bans for industrial goods (e.g., salts, ores, rubber products, building materials like bricks, tiles, ceramic goods).

5. Listing of further circumvention actors

45 additional organizations have been listed that support the military-industrial complex or are involved in circumventing sanctions:

• 28 companies in Russia,

• 17 in third countries (12 in China/Hong Kong, 3 in India, 2 in Thailand).

6. Other measures

Special Economic Zones (SEZ) in focus

The EU prohibits the conclusion of new contracts with entities in certain Russian Special Economic Zones. For Alabuga and Technopolis Moscow, the ban also applies to existing contracts.

Expanded service bans

• Ban on advanced digital services.

• Restrictions on space-based services and AI services.

• All non-prohibited services for the Russian government will require approval in the future.

What does the 19th sanctions package mean for your company?

The new sanctions require immediate action in several areas:

Immediate actions for affected companies:

1. Strategically plan energy supply:

   • Review LNG supply contracts and develop exit strategies.

   • Observe transition periods: Long-term contracts (>1 year) can still continue until 1 January 2027, short-term contracts until 6 months after the import ban comes into force (until approx. April 2026).

   • Identify alternative procurement sources and start negotiations in a timely manner.

2. Scrutinize supply chains: Identify connections to the shadow fleet and listed actors.

3. Secure financial flows: Review transactions, payment systems, and banking relationships for sanctions compliance.

4. End SEZ engagements, especially contracts with entities in Alabuga and Technopolis Moscow.

Strategic recommendations for sanctions compliance:

Expand Compliance Management System

• Enhanced due diligence for energy and financial transactions.

• Strengthen documentation of all auditing processes.

Intensify sanctions list screening

• Extended scrutiny of Chinese and Central Asian partners.

• Include digital payment service providers.

Optimize contract management

• Review LNG contracts for exit clauses.

• Update, if necessary, force majeure clauses for energy supplies.

Conclusion: Proactive action is required

The 19th sanctions package shows: The EU no longer relies solely on traditional trade restrictions, but also intervenes in digital financial architecture and energy supply. And: Companies must prepare for a permanent tightening of the sanctions landscape - the new normal of EU sanctions.

Companies should no longer view their compliance structures as a reactive tool, but as a strategic competitive advantage. Those investing in robust sanctions compliance now not only minimize risks but also position themselves for the post-sanctions era.

More on EU sanctions compliance can be found in our Insights from 18 June (Russia Sanctions 2025: New Obligations – Best Effort, CHP Goods & No-Russia Clause) and 5 August 2025 (Russia Sanctions 2025: 18th Sanctions Package - July 2025 Update).