Search
On 23 October 2025, the 19th EU sanctions package was adopted, imposing several restrictions on Russia and Belarus. The measures are set out in several regulations and decisions accessible in the Official Journal here. The main restrictions are set out in Council Regulation (EU) 833/2014, as amended by Regulation (EU) 2025/2033, which is accessible here.
Below, we have summarised the most significant new restrictions.
New export restrictions have been imposed covering various goods with military or industrial appliations, including certain electronic equipment, chemicals, metals, minerals, rubber products, tubes and tyres, millstones and construction materials.
A total of 45 entities has been listed in Annex IV to Regulation 833/2014 for directly supporting Russia’s military and industrial complex by enabling the circumvention of export restrictions on advanced technology items such as computer numerical control machine tools, microelectronics, and unmanned aerial vehicles. Consequently, they are subject to tighter export restrictions, including the prohibition to sell, supply, transfer or export dual-use items and technology, as well as items that might contribute to the technological enhancement of Russia’s defence sector.
An import ban on Russian liquefied natural gas (LNG) has been introduced meaning that it is prohibited to purchase, import, or transfer LNG that originates in Russia or is exported from Russia. For short-term contracts, the prohibitions are applicable from 25 April 2026, whereas for long-term contracts (i.e. contracts with a duration exceeding one year) concluded before 17 June 2025, the prohibition will apply from 1 January 2027.
The existing transaction ban on the two major Russian state-owned oil producers, Rosneft and Gazprom Neft, is also tightened. Previous exemptions regarding transactions strictly necessary for the purchase, import or transport of natural gas, titanium, aluminium, copper nickel, palladium, iron ore, and oil, including refined petroleum products from or through Russia, no longer apply to Rosneft or Gazprom Neft. However, for transactions with Rosneft, a narrow exemption applies regarding transit of oil or refined petroleum products that originate in a third country that are only being loaded in, departing from or transiting through Russia, provided that both the origin and the owner of the goods are non-Russian.
The 19th sanctions package impose further restrictions targeting the Russian shadow fleet.
A ban on reinsurance of vessels belonging to the shadow fleet is introduced to further constrain its ability to operate. Moreover, for five years after any sale or lease of a vessel that was operated by the Russian government or a legal person, entity, or body established in Russia, it is prohibited to sell, provide, underwrite or otherwise enter into any insurance-related contracts or arrangements that transfer the insurance risk associated with that vessel.
The port access ban and the ban on the provision of a broad range of services related to maritime transport are expanded to include an additional 117 vessels. The total number of designated vessels is now 557.
Several maritime registries have been listed on the basis that they have provided the Russian shadow fleet with false flags. In addition, large and significant entities are listed such as Far Eastern Shipping Company, which is the largest port container port operator in the Russian Far East and the leading Russian shipbuilding company, Zvezda. Litasco Middle East DMCC, a UAE based company with affiliations to Lukoil, has also been listed.
New measures targeting the Russian financial system include a transaction ban on 13 banks and oil traders from Russia, Belarus, Kazakhstan, Tajikistan, Kyrgyzstan, the United Arab Emirates, and Hong Kong. Further, as of 25 January 2026, EU operators are prohibited from connecting to any systems of the Central Bank of Russia and from engaging with the Russian National Payment Card System (“Mir”) and the Fast Payments System (“SBP”).
The EU is also introducing new financial restrictions targeting crypto-assets. It is prohibited to directly or indirectly engage in any transaction with a legal person, entity or body established outside the EU that is a credit or financial institution, or an entity that provides crypto-asset or payment services, where those services are provided to listed individuals or entities, or otherwise support Russia’s war efforts. Further, it is prohibited to provide crypto-asset services to Russian nationals or individuals residing in Russia.
Following the new sanctions package, it is now required to obtain a prior authorisation to provide any kind of services to the Russian government.
For non-governmental Russian persons or entities, the existing service restrictions have been expanded and now also include AI services, high-performance computing, and commercial space-based services.
A legal definition of the notion of “owning” and “controlling” a sanctioned person has been added to Regulation 269/2014 (asset freezes). While the EU Commission has previously provided guidance on the interpretation of the concepts, the definitions are now set out explicitly in the regulation.
The term “owning” is defined as a legal person, entity, or body being in possession of 50% or more of the proprietary rights of a legal person, entity, or body, or having major interest therein. When defining the term “controlling”, a non-exhaustive list of measures that establish control over a company is set out, such as having the right to appoint a majority of the members of management, controlling a majority of voting rights, or otherwise having the right (legally or de facto) to exercise a dominant influence over the company. However, the list is not exhaustive, and control of an entity may therefore be established by other means. These definitions correspond to the previous guidance notes from the EU Commission.
Further listings have been added to Annex I of Regulation 269/2014 imposing asset freezes on individuals and entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, including individuals and entities falling under the new listing criterion relating to those individuals and entities responsible for the forced transfer, forced assimilation, and militarised education of Ukrainian minors.
Certain of the abovementioned measures towards Russia have been mirrored in the updated Belarus sanctions regulation (Regulation 765/2006). This includes the enhanced services restrictions and the new export restrictions.
The list of individuals and legal persons, entities and bodies subject to asset freeze is expanded to include two individuals and three legal entities. These persons and entities are connected to the Belarusian military and industrial complex and the Lukashenka regime.
Gorrissen Federspiel closely follows the developments of export controls and sanctions, and we can assist with interpretation of and compliance with applicable sanctions as well as the implementation of measures to ensure that sanctions are observed. If you have any questions, please feel free to contact a member of our Compliance & Sustainability team.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel’s newsletters of 23 July 2025, 21 May 2025, 25 February 2025, 19 December 2024, 25 June 2024, 27 February 2024, 19 December 2023, 26 June 2023, 27 February 2023, 19 December 2022, 7 October 2022, 8 June 2022, 11 April 2022, 16 March 2022, 10 March 2022, 2 March 2022, 28 February 2022, and 24 February 2022.