EU Adopts 19th Sanctions Package of Sanctions Against Russia

“The 19th package will not be the last” said Kaja Kallas, Vice-President of the European Commission.

The European Union reached a new milestone in its sanctions policy against Russia with the adoption, on 23 October 2025, of its 19th package of restrictive measures. Initially proposed by the European Commission on 19 September 2025, this new package of sanctions increases the pressure on the Russian war economy. It targets directly, even more than previously, the key Russian sectors such as energy, finance and military industrial base sectors and strengths mechanisms to control circumvention.

The adoption of this 19th package comes in a particular diplomatic context, marked by enhanced coordination between the United States and the European Union.

U.S. President Donald Trump, who had previously been reluctant to sanction Russia, simultaneously announced major sanctions against Russian oil giants Rosneft and Lukoil, which together represent more than 3 million barrels exported daily.

Negotiations among Member States were delayed for several weeks due to opposition from Slovakia, whose Prime Minister Robert Fico demanded guarantees on energy prices and automotive industry support. The blockage was finally lifted after assurances were obtained from the European Commission.

Key Measures of the 19th Package (without being exhaustive)

1. Energy Sector

The flagship measure of this package concerns the total ban on importing Russian liquefied natural gas (LNG) as of 1st January 2027 for long-term contracts and as from 25 April 2025 for short-term contracts. This decision is significant since in 2024, Russia still accounted for 19% of the EU’s gas supply, nearly half of which was in the form of LNG.

The EU also eliminates the exemption for Rosneft’s and Gazprom Neft’s oil and gas imports into the EU and targets two Chinese refineries and one Chinese oil trader that are significant buyers of Russian crude oil. Two oil trading companies in Hong Kong and the United Arab Emirates (UAE) are also targeted by the 19th package of sanctions.

The new measures also include bans on energy-related services (such as scientific and technical services).

2. The “Shadow Fleet”

The package targets an additional 117 vessels from Russia’s “shadow fleet” used to circumvent sanctions on hydrocarbon transport. The EU’s sanctions program now targets 557 vessels in total, which are banned from accessing European ports and EU maritime services.

Additional sanctions are notably imposed across the shadow fleet value chain, including on Litasco Middle East DMCC, Lukoil’s prominent shadow fleet enabler, as well as on maritime registries providing false flags to shadow fleet vessels.

Operators from this field of activity should therefore increase their vigilance regarding oil or gas products that could have a Russian origin via third countries, particularly from China.

3. Sectoral and Financial Sanctions

Five new Russian banks are added to the list of sanctioned entities. In addition, EU operators are also banned from carrying out transaction with five banks located in Central Asia that support Russia’s war economy.

Russia’s payment card and fast payment system as well as four new financial institutions in Belarus and Kazakhstan that use the Russian payments system are subject to new bans.

Furthermore, any transaction involving the A7A5 cryptocurrency is now prohibited and EU operators are banned from providing crypto services and certain fintech services that would help Russia to develop its own financial infrastructure.

4. Trade measures

This 19th package of sanction added new export restrictions on dual-use items and advanced technologies that were not yet under sanctions and new export bans on items which correspond to a value of EUR 155 million of EU exports on the basis of 2024 prices.

In addition, 69 new individuals (are now subject to individual sanctions / asset freezes), including operators from UAE and China.

Furthermore, the package proposes a prohibition on entering into new contracts with any entity established within certain Russia’s Special Economic Zones (SEZs).

5. Fighting Circumvention

This 19th package of sanctions adds 45 entities, among those 17 are located in third-country, to the list of entities engaged in sanctions circumvention. Among the third-country entities, 12 are located in China including Hong-Kong, 3 in India and 2 in Thailand.

The 19th sanctions package illustrates the EU’s determination to maintain growing economic pressure on Russia and on third-parties that help Russia circumvent the sanctions, while seeking to reduce its own energy dependence. Coordination with the United States on this matter also marks a turning point in Western strategy.

This article is for informational purposes only. For any specific questions regarding your company’s compliance with European sanctions, we invite you to consult the official texts published in the Official Journal of the European Union and to contact our firm for legal advice tailored to your situation.

Stephanie De Giovanni is an accomplished international and litigation attorney with over 20 years of experience practicing commercial law and complex commercial litigation. Ms. De Giovanni has a background in international distribution law and spent her early career focused on commercial agency and the setting-up of distribution networks. For the duration of her legal career, she has dealt with termination issues and the disputes arising therefrom. Read more here.

Elia El Kouh is an Associate in Rimon’s Paris office. Ms. El Kouh focuses on international law, commercial law, litigation, and compliance. She has prior experience in law firms in Paris and Morroco advising clients on matters relating to commercial law, criminal business law, economic law, contract law, litigation, and arbitration.  Ms. El Kouh also has experience serving as in-house counsel for the legal department of an automotive manufacturer, where she advised on issues relating to contract law, competition law, distribution, and consumer law. Read more here.