EU publishes 19th sanctions package against Russia and Belarus

The measures include a ban on Russian Liquified Natural Gas (LNG) imports, sanctions on over 100 additional vessels and enhanced transaction bans on key oil and gas companies. In addition, the 19^th package bolsters restrictions against crypto service providers, Russian payment systems and banks identified as having been involved in sanctions evasion. The EU has also introduced enhanced export restrictions in relation to 45 companies supporting Russia’s military-industrial complex, as well as a variety of critical industry goods.

As set out in an announcement by the European Commission President, Ursula von der Leyen, the 19th package of sanctions is a response to intensified Russian military aggression and violation of EU airspace. The package expands many of the measures introduced by the EU’s 18^th package of sanctions on 18 July 2025 (see our briefing here), and follows shortly after the introduction of the UK’s latest sanctions package (see our briefing here) as well as new US measures which formally designated Russia’s two largest oil companies, Rosneft and Lukoil (please see our briefing here).

Summary of key new EU sanctions measures

1. Trade and supply chain measures

The 19^th sanctions package introduces additional trade- and supply chain-related restrictions to further disrupt Russia’s military-industrial complex. In particular:

• a further 45 entities have been made subject to tighter export controls, 17 of which are based in third countries (including mainland China, Hong Kong, India and Thailand);

• the existing export ban on goods and technology which might contribute to Russia’s military and technological enhancement has been expanded to include a variety of new items, including electronic components, rangefinders, certain chemicals used in the preparation of propellants and certain metals, oxides and alloys used in the manufacturing of military systems;

• a new prohibition has been introduced which covers the purchase, import or transfer (directly or indirectly) of all acyclic hydrocarbons;

• a key Russian gold producer has been formally designated;

• a new measure has been introduced requiring prior authorisation for all services provided to the Government of Russia; and

• new restrictions on the provision of services to the Government of Russia or to legal persons, entities or bodies established in Russia have been introduced to cover:

• certain artificial intelligence services (including access to models or to platforms for their training, fine-tuning and inference);
• certain commercial space-based services (including Earth observation or satellite navigation); and
• high performance computing (including access to graphic processing unit-accelerated computing, or quantum computing services).

In addition, a transaction ban has been imposed to target ports and locks in third countries that have been identified as having been used: (i) for the transfer to Russia of unmanned arial vehicles (UAVs), missiles or related technology, or components thereof; or (ii) for the circumvention of the Oil Price Cap; or (iii) for the circumvention of other EU restrictive measures.

2. Energy measures

The 19^th sanctions package also builds on recent measures targeting Russia’s energy industry, in particular the oil and gas sector and the operations of Russia’s ‘shadow fleet’. New measures include:

• a new prohibition on the purchase, import or transfer (directly or indirectly) of LNG if it originates in Russia or is exported from Russia (with the ban taking effect from 1 January 2027 for contracts concluded before 17 June 2025 and exceeding one year (subject to certain exceptions), or from 25 April 2026 for shorter-term contracts);

• a strengthening of the transaction ban on Rosneft and Gazprom Neft, by excluding these entities from certain exemptions previously available under the applicable transaction ban provisions;

• further oil sector designations, including a conglomerate based in the Russian Republic of Tatarstan, as well as third country designations including two Chinese refineries and a Chinese oil trader;

• further measures designed to target the operations of Russia’s ‘shadow fleet’, including:

• the designation of a UAE-incorporated oil trader;
• the designation of various maritime registries providing false flags to shadow fleet vessels;
• the designation of a Russian port container operator and a Russian shipbuilder;
• new prohibitions on port access for a further 117 vessels, as well as a ban on the provision of various services to those vessels; and
• a new prohibition on providing reinsurance to vessels in the shadow fleet.

3. Financial measures

The 19^th package also seeks to further close financial loopholes which have been used to evade sanctions. In particular, it introduces:

• new measures targeting crypto service providers, including the designation of the developer of the A7A5 cryptocurrency, the designation of the operator of a trading platform for A7A%, and a prohibition on the use of A7A5 throughout the EU;

• further transaction bans, including on: (i) 5 Russian banks; (ii) 4 banks in Belarus/Kazakhstan; and (iii) 8 banks and oil traders from third countries including Tajikistan, Kyrgyzstan, the UAE and Hong Kong;

• new prohibitions on engaging with the Russian National Payment Card System (Mir) and the Fast Payments System (SBP); and

• a variety of new measures aimed at preventing economic activities with nine Russian special economic zones.

Commentary

The timing of the EU’s 19^th package of yesterday, last week’s UK measures, and this week’s US sanctions is not a coincidence – it arguably represents a rare coordination effort between the three jurisdictions, intended to put extra pressure on Russia, not just to bring Putin to the negation table, but also to force third country actors to abide by Western sanctions policy objectives via the threat of secondary sanctions.

The 19^th package demonstrates a continuation of the EU’s recent policy shift towards targeting high-risk areas for sanctions circumvention, notably by capturing more persons and activities that would normally be outside of the EU’s jurisdiction, and by attempting to close financial loopholes through the use of transaction bans and new restrictions on payment systems.

Also of note is the continued focus, alongside recent designations by the UK and the US, on the energy sector (a strategically important industry for Russia in terms of revenue generation), as well as the expanded restrictions on the provision of services (particularly in relation to “advanced technologies” such as artificial intelligence and high performance computing sectors, which are increasingly subject to enhanced trade controls and other national security and protectionist measures).

As with the regime updates in July, the key takeaway is that the expanding boundaries of the EU sanctions regime create a more complex regulatory system and heightened compliance obligations for businesses operating internationally. The European Commission has been pushing Member States to aggressively enforce sanctions violations across the EU, and we have seen hundreds of sanctions investigations by EU competent authorities since Russia’s invasion of Ukraine in February 2022. It therefore is increasingly important (particularly given the additional flurry of sanctions updates from the US and UK) to remain on top of these developments and to implement robust internal policies and procedures in order to ensure compliance.