EU 19th adopts Sanctions Package against Russia – What It Means for Your Business

On October 23, the EU adopted its 19th package of sanctions against Russia.

Since the full-scale invasion of Ukraine in February 2022, the EU has repeatedly expanded its sanctions regime against Russia, aiming to weaken the economic base of its war-economy and curtail Russia’s access to technologies, financial systems and global markets.

The 19th package comes at a time when the EU is seeking to increase pressure on Russia by targeting key revenue streams (in particular energy) and to close emerging circumvention channels via third countries. This package once again signals a shift towards a more extraterritorial reach: it addresses not only Russian entities, but also foreign actors (third country entities) that facilitate Russia’s war effort, their logistics and technology access.

Brief summary

The 19th sanctions package targets in particular the energy sector (in particular LNG), shipping/transport logistics (shadow fleet), financial systems (including crypto), and cross-border flows via third-country intermediaries.

1. Key elements of the 19th sanctions package in detail

Energy sector measures

• The EU has agreed a phased import-ban on Russian liquefied natural gas (LNG): under the new rules, long-term LNG contracts with Russia will no longer be permitted as of 1 January 2027, and shorter-term contracts must end six months after the entry into force of the sanctions.
• The ban is widened to include certain imports of Russian LPG (liquefied petroleum gas) to close previously exploited loopholes.
• 180 additional vessels belonging to the so-called “shadow fleet” of Russia (ships used to evade sanctions) have been added to the sanctions list.
• Further bans and restrictions on port-infrastructure services, and on energy-related technical and scientific services (e.g., geological prospecting, mapping) for Russian energy projects.

Financial/cryptocurrency measures

• The package introduces full transaction bans for additional Russian banks and also targets banks in third countries (Central Asia, etc) that facilitate Russian funding.
• New restrictions on Russian payment and fast-payment systems, and explicit sanctions on cryptocurrency platforms used to evade financial restrictions — including stablecoins issued in or via third countries.
• Given the expansion of trade in cryptocurrencies and fintech services linked to Russia’s war-economy, the EU prohibits EU-based operators from offering certain crypto and fintech services to Russian end-users or facilitating their access.

Trade / export / dual-use goods measures

• Additional dual-use goods, advanced technologies, specific chemicals, metals, oxides, alloys, salts, rubber products and electronic components that can assist Russia’s war industries are subject to the embargo (Building on earlier packages.)
• Services supporting Russia’s Special Economic Zones (SEZs), which facilitate import-export and technology transfer that supports the war, are also targeted.

Other measures / listing and enforcement

• Additional natural and legal persons were added to the sanctions list, including oligarchs, Russian energy-sector actors, shadow-fleet facilitators, foreign refineries and oil-traders that assist Russia.
• Measures also include insurance and re-insurance bans (notably for shipping and aviation connected to Russia), and enhanced monitoring/notification obligations for services rendered to listed persons/entities.
• Diplomatic restrictions: the EU is introducing controls on the movement of Russian diplomats in EU member states, designed to curb destabilisation efforts and sanction-evasion.
• Belarus: While the main focus remains Russia, the package also imposes further sanctions on Belarus insofar as it supports Russia’s war machine — new listings tied to Belarus’s military-industrial complex and the Lukashenko regime.

2. Practical implications and compliance pointers

• Contract review and planning: Companies engaged in energy, shipping, logistics, finance, crypto/fintech, and technology export should review existing contracts with Russian (or Belarusian) counterparties or via third-country intermediaries. Particularly, any long-term LNG contracts with Russia must be flagged and planned for termination or transition by 1 January 2027 (or earlier depending on contract type).
• Third-country risk / indirect exposure: One of the strategic shifts in this package is the stronger focus on third-country actors (non-EU, non-Russia) facilitating evasion of sanctions. If your business involves counterparties in third countries (e.g., China, India, UAE, or Central Asia) linked to Russian energy, exports or shipping, you should map and assess exposure to potential sanctions breaches.
• Crypto / fintech diligence: If you provide or use fintech or crypto-services in connection with Russian or Belarusian parties (or through third-country entities), you should carefully assess whether those services are now prohibited.
• Export controls and dual-use goods: It is essential to verify whether any goods, services or underlying components handled by your company fall under the expanded list of dual-use goods now captured. Transactions with listed foreign companies or refineries may now be prohibited.
• Asset/freezing obligations: Ensure that your company’s internal compliance systems can identify newly listed persons, entities, vessels or banks and prevent making funds or economic resources available to them.
• Enforced vigilance: The focus of this package and of the authorities clearly lies of avoiding and prosecuting circumvention activities. It is essential that sufficient measures are taken to ensure due diligence in daily business.

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