EU Adopts 19th Package Against Russia and Parallel Sanctions On Belarus

Following proposals made by the European Commission (“Commission”) on September 19, 2025, the European Union (“EU”)’s 19^th package of sanctions targeting Russia, including parallel measures aligning sanctions on Belarus, has been adopted on October 23, 2025. This package targets primarily the energy, financial and military industrial sectors, while addressing circumvention concerns through a mix of list-based sanctions, enhanced trade controls (including on liquefied natural gas (“LNG”)), services restrictions and reinforced financial sanctions. While significant, High Representative Kallas nonetheless already announced that the package adopted today “will not be the last one.”

New asset freeze measures were imposed through Decision 2025/2036 and Regulation 2025/2035 under the main asset freeze regime targeting Russia (Decision 2014/145 and Regulation 269/2014) and through Decision 2025/2038 and Regulation 2025/2039 under the Belarus sanctions regime (Decision 2012/642 and Regulation 765/2006). In addition, Decision 2025/2036 and Regulation 2025/2037 amended the asset freeze measures framework under the main asset freeze regime targeting Russia. These provisions entered into force on October 23, 2025.

Amendments to sectoral sanctions targeting Russia (Decision 2015/512 and Regulation 833/2014) and Belarus (Decision 2012/642 and Regulation 765/2006) were made through, respectively, Decision 2025/2032 and Regulation 2025/2033 and Decision 2025/2040 and Regulation 2025/2041, which entered into force on October 24, 2025.

1. Asset Freeze Measures

New designation (Russia & Belarus):

The EU imposed travel ban and/or asset freeze measures against 24 individuals and 45 legal persons, entities or bodies ("entities"). Designations target primarily the energy and shadow fleet value chains, military-industrial companies and their suppliers, cryptocurrencies actors, major actors in the gold mining, steel and logistics sectors, as well as actors involved in circumvention or accused of abducting and indoctrinating Ukrainian children. Reflecting the EU’s sharper posture on extraterritoriality, 12 companies located in China, Hong Kong, Kyrgyzstan, the United Arab Emirates, the United Kingdom and the United States have been designated.

Amendments to the asset freeze framework under Regulation 269/2014 (Russia only):

The framework has been refined by:

• Adding legal definitions of “ownership” and “control”, aligned with inter alia those set forth in Regulation 2580/2001 and the Council of the European Union’s Best Practices.
• Adjusting the scope language of asset freeze measures, removing references to persons “associated with” listed individuals and entities.
• Introducing a new listing criterion, focused on the deportation, forced transfer, forced assimilation or militarized education of Ukrainian minors.
• Extending a derogation for certain insurance payments to two additional listed Russian insurers.

2. Other List-Based Sanctions

The 19^th package makes extensive use of the different list-based sanctions frameworks under the Russia regime, reflecting the EU’s willingness to further use these tools as a way to pressure Russia and third-country operators supporting Russia by cutting access to the EU market.

New list-based designations:

• EU’s “Entity List”: 45 entities added to the list of parties subject to enhanced export control restrictions (Article 2b and Annex IV of Regulation 833/2014), including 17 in China, Hong Kong, India and Thailand.
• Designated vessels:117 vessels designated as subject to an EU port ban and ban on a broad range of activities and services (Article 3s and Annex XLII of Regulation 833/2014). Four vessels were also de-listed.
• Transaction bans: Five Russian banks (effective November 12, 2025), four banks in Belarus and Kazakhstan (effective December 2, 2025), five banks in Kyrgyzstan and Tajikistan (effective November 12, 2025), one cryptocurrency exchange (effective November 25, 2025) and two Hong Kong and UAE oil traders (effective November 12, 2025) are now subject to transaction bans based on different frameworks.

Measures can extend to affiliates of designated parties and are subject to limited exemptions and/or derogations, including to wind-down existing operations.

Reinforcing existing list-based sanctions frameworks:

• Tightening the transaction ban against Rosneft and Gazprom Neft (Article 5aa and Annex XIX of Regulation 833/2014), by withdrawing exemptions covering transactions (i) necessary for oil and gas transactions involving Russia, or (ii) related to certain Gazprom Neft-minority owned energy projects abroad. At the same time, limited new exemptions permit transactions related to oil and petroleum products from third countries or consistent with the oil price cap.
• Targeting all Russian financial messaging systems including not only SPFS, but also SBP and Mir (Article 5ac and Annex XLIV of Regulation 833/2014), by (i) prohibiting EU entities operating outside Russia from connecting to such system as of January 25, 2026, and (ii) providing for the possibility to impose transaction bans against non-Russian parties using such systems. Tailored and limited exemptions were introduced.
• Extending the possibilities to impose transaction bans against parties frustrating EU sanctions (Article 5ad and Annex XLV of Regulation 833/2014), by (i) extending the list of potential targets to non-EU payment service providers; (ii) focusing on the provision of crypto-assets services to listed parties; and (iii) providing for the application of transaction bans to non-listed parties providing crypto-asset or payment services that operate as a mirror or successor entity of an entity listed in Annex XLV.
• Introducing a possibility to ban transactions with non-Russian ports and locks (Article 5ae and Annex XLVII of Regulation 833/2014), to the extent they are used to support Russia’s war, the Russian oil industry, or to circumvent or frustrate EU sanctions, though no port or lock outside Russia has been designated so far.
• Clarifying and extending the scope of the designated vessels framework (Article 3s and Annex XLII of Regulation 833/2014), by (i) covering expressly both insurance and reinsurance, while preserving pay-outs to third-party claimants for pre-designation events, and (ii) expanding designation criteria to cover vessels transporting mineral products from Russia and engaging in irregular/high-risk practices.

At the same time, limited new exemptions have been introduced as regards the transaction ban targeting certain Russian and Belarusian banks (Article 5h and Annex XIV of Regulation 833/2014 & Article 1zb and Annex XV).

3. New Restrictions Targeting Designated Russian Special Economic Zones (New Article 5ah and Annex LII Of Regulation 833/201)

A new regime targets activities associated with 11 designated Russian special economic zones (“Designated SEZ”):

• Effective October 24, 2025, EU operators are prohibited from (i) making new acquisition in entities located or operating in Designated SEZ (“Designated SEZ Entities”); (ii) creating new joint ventures, branches or representatives offices in Designated SEZ or with Designated SEZ Entities; and (iii) entering into new contracts or arrangements for the supply of goods, services or related IP rights/trade secrets to, from or for use in Designated SEZ or with Designated SEZ Entities.
• As of January 25, 2026, maintaining the existing above participations, joint ventures, branches, representatives offices, contracts or arrangements will be prohibited in connection with two Designated SEZ.
• Financing and related investment services tied to restricted activities are also prohibited.
• The above restrictions apply also to entities outside Designated SEZ that are owned or controlled by a Designated SEZ Entity.

Limited exemptions and derogations have also been introduced, including a wind-down exemption for existing contracts.

4. Export-Related Restrictions

Lists of controlled items under the Russia and Belarus regimes have been extended to cover additional items, namely:

• Advanced technology items (Articles 2a and 2b and Annex VII of Regulation 833/2014 & Article 1f and Annex Va of Regulation 765/2006): including (i) electronic components; (ii) rangefinders; (iii) additional chemicals used in the preparation of propellants; (iv) energetic materials and precursors; and (v) additional metals, oxides and alloys.
• Industrial items (Article 3k and Annex XXIII of Regulation 833/2014 & Article 1bb and Annex XVIII of Regulation 765/2006): including (i) salts and ores; (ii) articles of rubber; (iii) tubes; (iv) tyres; (v) millstones; and (vi) construction materials.

Wind-down exemptions have been introduced for newly listed items.

Separately, the list of controlled luxury items under the Russian regime (Article 3h and Annex XVIII of Regulation 833/2014) has been adjusted to limit duplicate controls, by removing items that were covered by other annexes, notably Annex XXIII.

Furthermore, the Belarus regime has been aligned with the Russia regime to impose export-related restrictions on software with certain uses in the banking and financial sector, which are limited to the Republic of Belarus, its government, its public bodies, corporations or agencies and individuals or entities acting on their behalf or at their direction (Article 1jc and Annex XXVI of Regulation 765/2006).

5. Import-Related Restrictions

New import-related restrictions on Russian LNG (new Article 3ra of Regulation 833/2014): Prohibitions to (i) purchase, import or transfer LNG under CN code 2711 11 00 originating in or exported from Russia and (ii) provide related ancillary services (technical assistance, brokering services, financing or financial assistance or other services) will apply as of April 25, 2026. A limited wind-down exemption allows the execution, until January 1, 2027, of certain pre-June 17, 2025 long-term LNG supply contracts, provided they have not been materially amended (with some limited amendments considered permissible).

These prohibitions apply regardless of any other EU legislation with overlapping scope, implicitly referencing the parallel proposal to phase out Russian LNG under the REPowerEU Plan.

Extension of lists of import-controlled items (Article 3i and Annex XXI of Regulation 833/2014 & Article 1ra and Annex XXVII of Regulation 765/2006): Import-related restrictions on Russia and Belarus have been extended to cover saturated acyclic hydrocarbons falling under CN code 2901, subject to (i) a wind-down exemption and (ii) a Hungary-specific exemption, prohibiting goods from being re-sold outside Hungary.

Separately, under the Russian regime, new derogations have been introduced in connection with Annex XXI items for (i) Budapest Metro Line 3 components and (ii) certain UV disinfection lamps where non-Russian alternatives are unavailable.

Extended list of partner countries for importation of petroleum products, for which imports of petroleum products do not require proof of origin of the crude oil used for refining (Article 3ma and Annex LI of Regulation 833/2014): This list of partner countries has been extended to Australia, Japan and New Zealand (in addition to Canada, Norway, the United Kingdom, the United States, and Switzerland).

6. Services Restrictions (Article 5n of Regulation 833/2014 & Article 1jc of Regulation 833/2014)

Extension of the list of restricted professional services: the provision of the following services to (i) the Government of Russia or entities established in Russia, and (ii) the Republic of Belarus, its government, its public bodies, corporations or agencies is now prohibited:

• Integrated engineering, urban planning, engineering related scientific and technical consulting services.
• As of November 25, 2025: (i) commercial space-based services; (ii) artificial intelligence services; and (iii) high-performance/quantum computing services.

Amendments to the scope of ancillary services related to restricted professional services and software: The new wording no longer requires ancillary services to be related to the provision of such services and software for restrictions to apply. The mere provision of ancillary services related to such services and software is subject to restrictions.

New restrictions on tourism services: Services directly related to tourism activities in Russia are now prohibited (subject to a wind-down exemption).

New catch-all controls on other services provided to the Government of Russia or the Republic of Belarus, its government, its public bodies, corporations or agencies: The provision of any service that is not specifically prohibited now requires a prior authorization from national competent authorities (subject to a wind-down exemption).

7. Financial Restrictions

New restrictions on crypto-asset services, the provision of payment services and the issuing of electronic money (Article 5b of Regulation 833/2014 & Article 1u of Regulation 765/2006): Restrictions on the provision of crypto-assets wallet, account or custody services to Russian/Belarusian nationals or residents and entities established in Russia/Belarus have been extended to cover a broader array of financial services: (i) crypto-asset services; (ii) issuing of payment instruments, acquiring of payment transactions, or payment initiation services; and (iii) issuing of electronic money.

Recitals clarify that the ban does not extend to the execution of payment transactions per se and does not impose transaction-by-transaction nationality/residency checks on payment initiation providers or acquirers. Primary responsibility for compliance lies with the account-servicing payment service provider.

Limited exemptions and derogations are foreseen, including for Russian subsidiaries of EU or partner country parents.

New prohibition on transactions involving certain crypto-assets (new Article 5ba and Annex LIII of Regulation 833/2014): A new prohibition bans any transaction involving Annex LIII crypto-assets, currently listing the A7A5 stablecoin, effective November 25, 2025.

New prohibition on reinsuring Russian used aircraft or vessels for five years after their sale or lease (new Article 5u of Regulation 833/2014): The package imposes a five-year bar on reinsuring vessels or aircraft that were operated by the Russian Government or Russian-established entities after their sale or lease.

8. Facilitating Exits from Russia

To facilitate orderly exits from Russia, several exemptions and derogations have been extended until December 31, 2026 (instead of December 31, 2025), including in connection with (i) transaction bans targeting certain State-owned enterprises; (ii) no claims clauses; (iii) export- and import-related restrictions; and (iv) professional services restrictions.

Recitals emphasize the risk of stranded EU assets due to Russian countermeasures and strongly encourage winding down business in Russia and refraining from new ventures.

9. Travel Controls on Russian Diplomatic Missions or Consular Post Members

Effective 25 January 2026, Russian diplomatic or consular staff, and non-minor family members of their household, must provide 24-hour prior notification before traveling to or transiting through an EU Member State other than the one that issued their residence permit or visa. Under certain conditions, Member States may require prior authorization for such travel or transit.