The EU Council Adopts the 19th Package of Sanctions Against the Russian Federation

29.10.2025

• Restrictions on the Energy Sector
• “Ownership” and “Control” Definitions
• Banking and Financial Sectors
• These restrictions will take effect on 25 January 2026.
• Ban on the Provision of Certain Services
• Export Restrictions
• Restrictions on Special Economic Zones
• Contact a lawyer for further information

On 23 October 2025, the Council of the European Union (EU) adopted its nineteenth package of restrictive measures against the Russian Federation. The EU expanded the list of blocking sanctions, introduced new trade and financial restrictions, and broadened sectoral limitations concerning the provision of services.

REVERA lawyers have analysed the key measures introduced under this package.

Restrictions on the Energy Sector

The EU has imposed a ban on the import of Russian liquefied natural gas (LNG) to European markets — within six months for short-term contracts, and from 1 January 2027 for long-term contracts.

To enhance monitoring and enforcement of this ban, the EU has imposed sanctions on an additional 117 vessels belonging to the so-called “shadow fleet”. In total, 557 vessels are now subject to EU sanctions. The EU has also applied further restrictive measures along the entire “shadow fleet” supply chain: these include sanctions on certain maritime registries allegedly providing “false flags” to shadow fleet vessels, the largest container port operator in the Russian Far East, and a leading shipbuilder for Sovcomflot.

The assets of companies involved in purchasing Russian oil in breach of sanctions have also been frozen. Among these are two Chinese oil refineries, one Chinese oil trader, and a conglomerate based in Tatarstan active in the Russian oil sector. Oil traders from Tajikistan, Kyrgyzstan, the UAE and Hong Kong circumventing EU restrictions are now subject to a prohibition on conducting transactions.

“Ownership” and “Control” Definitions

The new restrictions clarify the definitions of “ownership” and “control”, which determine the scope of entities covered by sanctions against the Russian state sector. These definitions are now explicitly set out in the amended EU Regulation.

“Ownership” means the holding of 50% or more of the ownership rights of a legal entity or a controlling shareholding.

“Control” means, inter alia:

• the right to appoint or dismiss the majority of members of the management bodies;
• such appointment resulting from the exercise of voting rights;
• control of the majority of voting rights under an agreement with other shareholders;
• the right to exercise dominant influence under contract or the entity’s charter;
• actual exercise of such influence without formal rights;
• the right to use all or part of a company’s assets;
• operating on a consolidated basis and publishing consolidated financial statements;
• joint or several liability for financial obligations, or provision of guarantees for such obligations.

Previously, these concepts were interpreted based on the EU’s Best Practices for the effective implementation of restrictive measures. The EU has not substantially changed its approach but has now codified principles that were already applied in practice.

Banking and Financial Sectors

Within the banking sector, the EU has imposed full transaction bans on several banks from Tajikistan, Kyrgyzstan, the UAE and Hong Kong that, according to the EU, have been circumventing sanctions.

Five additional Russian banks — NKO “Istina”, Zemsky Bank, Absolut Bank, MTS Bank and Alfa-Bank — are now subject to a prohibition on transactions, as are four banks from Belarus and Kazakhstan, due to their connections with Russian financial messaging and payment systems.

The EU has further extended the ban on the use of Russian financial messaging and payment systems. The restrictions now apply to systems provided by any Russian legal entity that offer financial messaging functions, including:

• the Faster Payments System (SBP);
• the Mir payment system (National Payment Card System).

These restrictions will take effect on 25 January 2026.

Additionally, the EU has broadened its prohibition on the provision of services related to crypto-assets, wallets, accounts or custody of cryptocurrencies for Russian nationals and legal entities registered in Russia. The ban now encompasses a wider range of financial services, including:

• services involving crypto-assets;
• issuance of payment instruments, payment acquiring or payment initiation services;
• issuance of electronic money.

Ban on the Provision of Certain Services

The new sanctions package extends the prohibition on providing specific types of services, including:

• commercial space services such as satellite navigation and Earth observation;
• artificial intelligence (AI) services, including access to models, platforms for training, fine-tuning, and inference;
• high-performance and quantum computing services.

These restrictions apply particularly to entities within the Russian state sector.

Furthermore, services directly related to tourism activities in Russia are now restricted. Only the temporary completion of existing contracts is permitted during the transitional period.

Special attention should be paid to the requirement to obtain prior authorisation from the competent authority before providing any services to the Russian Federation, its government, state bodies, corporations, or agencies. This applies even to services not yet covered by the restrictive measures of the Regulation.

Export Restrictions

The 19th sanctions package extends the list of goods subject to EU export control. The additions include: specific electronic components, rangefinders, rocket propellants and chemical propellants, military-grade metals, oxides and alloys, among others; as well as products enhancing Russia’s industrial capacity, such as salts and ores, rubber products, pipes, tyres, millstones, and construction materials.

The new measures also amend Annex IV to the Regulation by adding 45 new items, thereby strengthening export controls on:

• dual-use goods and technologies;
• products contributing to Russia’s defence sector — such as CNC machine tools, microelectronics, and high-tech components.

Restrictions on Special Economic Zones

The newly adopted measures also extend to Russia’s special economic, innovation and preferential zones — including the Skolkovo Innovation Centre, the Far Eastern and Arctic zones (11 in total), as well as innovation clusters and industrial parks. The restrictions concern the following activities:

• establishment of new joint ventures or representative offices in such zones;
• conclusion of new contracts for the supply of goods, provision of services, or licensing of intellectual property for use in such zones;
• continuation of any of the above forms of cooperation after 25 January 2026;
• financing of organisations registered within these zones.

Author: Aliaksei Fedarovich.

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