The EU's 19th sanctions package against Russia

For more information about UK, EU and US sanctions on Russia and our practical 5-step checklist, see our detailed blog which also includes our top tips for compliance.

This package has been debated for some time  in order to get unanimous approval from the Member States.

The Council of the European Union has adopted Council Decision (CFSP) 2025/2032 which amends Decision 2014/512/CFSP

Council Regulation (EU) 2025/2033 amends Regulation (EU) No 833/2014 (the "Regulation")

Energy Measures

• Liquified Natural Gas
  • A ban on imports of Russian liquified natural gas into European markets will be effective from 1 January 2027, bringing forward the date from 1 January 2028 that was proposed to member states previously
  • New Article 3ra has been inserted in the Regulation which prohibits, as of 25 April 2025, the purchase, import or transfer, directly or indirectly, of liquified natural gas (failing under CN code 2711 11 00) if it originates in Russia, or is exported from Russia.
  • This paragraph applies from 1 January 2027 if the contract is for the duration exceeding one year and was concluded before 17 June 2025 and where the contract was not amended thereafter (subject to some limited exceptions).
  • Acyclic Hydrocarbons
    • Annex XXI has been amended to include all Acyclic Hydrocarbons as these generate significant revenues for Russia. These are now subject to the prohibition of import and transfer prohibitions under Article 3i. Hungary has a time limited exemption.
  • Rosneft and Gazpromneft
    • Exemptions relating to Rosneft and Gazprom Neft from the transaction ban in article 5aa have been narrowed.
  • "Shadow Fleet" reinsurance prohibition
    • Article 3s has been amended to prohibit the direct or indirect reinsurance of any vessel listed in Annex XLII.
  • Oil Price Cap
    • The 19^th package does not amend the oil price cap. The review mechanism from the 18^th sanctions package remains in force.

Financial Measures

• Full transaction ban on certain financial institutions and crypto institutions
  • A full transaction ban on 5 further Russian banks (as listed in Annex XIV) and their operations in third countries have been implemented alongside third country banks in central Asia (as listed in Part A of Annex XLV)
  • Article 5b is amended to prohibit providing, directly or indirectly, the following services to Russian nationals or natural persons residing in Russia, or to legal persons, entities or bodies established in Russia:
    • crypto-asset services;
    • issuing of payment instruments, acquiring of payment transactions or payment initiation services; or
    • issuing of electronic money.
    • It is also prohibited to allow Russian nationals to hold any posts in an entity which is incorporated in the EU and provides crypto-asset wallet, account or custody services.
    • By way of derogation under Article 5c, the competent authorities may authorise the provision of the prohibited services if they determine it is necessary for the exclusive use of persons established in Russia that are owned by, or solely or jointly controlled by, a person which is incorporated in the EU or certain countries.
  • New Article 5ba has been added to the Regulation which includes a ban on EU persons engaging, directly or indirectly, in any transaction with the crypto-assets listed in Annex LIII (which currently lists crypto-asset A7A5).
  • Article 5ac of the Regulation is amended to introduce new bans on Russia's payment card (Mir) and fast payment system (SBP). It is prohibited for entities or bodies established in the EU, from 25 January 2026, to connect to Mir and SBP.
  • It is prohibited to directly or indirectly engage in any transaction with the entities listed in Annex XLIV. The annex now lists 7 overseas branches of Russian-established banks.
  • The new Article 5ah of the Regulation creates a ban on investments in Russian Special Economic Zones listed in Annex LII of the Regulation. 9 zones are currently listed.
  • Persons subject to EU jurisdiction are prohibited as of 25 January 2026 from maintaining contractual relationships with an entity registered in Alabuga and Technopolis Moscow (listed in Part A of Annex LII).
  • Asset Freeze
    • 22 persons and 42 entities have been added to Annex I of Regulation (EU) No 269/2014. All such persons will have all funds and economic resources belonging to, owned, held or controlled by them frozen.

Ports and Airports

• The port infrastructure ban in Article 5ae has been amended to enable the EU to list ports in third countries other than Russia in Part C of Annex XLVII. No third country port has been listed in the 19^th package.

Trade and anti-circumvention measures

• Anti-circumvention measures
  • Annex IV of the Regulation has been amended to include 45 persons, including 28 established in Russia, 12 in China (including Hong Kong), 3 in India and 2 in Thailand. These entities are captured under the anti-circumvention measures of Article 12 of the Regulation.
• Export controls
  • Article 2a requires authorisation for the export of certain goods, listed in Annex VII to the Regulation. The Annex has been expanded to include various items such as metals for the construction of weapons systems and products used in the preparation of propellants, not yet under sanctions.
  • Further, the ban on the sale, supply, transfer or export and transit (Article 3k) of certain chemicals, salts and ores which are useful to Russia's military have been expanded with an updated list in Annex XXIII.
  • The amended Article 5n prohibits the provision of services directly related to tourism activities in Russia to the Government of Russia or to legal persons, entities or bodies established in Russia. This includes:
    • travel agency and tour operator services; travel information; advice and planning services; services related to the arrangement of tours; accommodation; passenger and baggage transportation; and ticket issuance services;
    • tourist guide services; and
    • advertising services related to the above.

Listings

• Ships
  • A further 117 vessels have been listed, bringing the total to 557 vessels. (4 vessels have been removed from the annex XLII). These vessels are now banned from accessing EU ports and from receiving a wide range of maritime-related services under Article 3s.
  • Companies
    • A further 45 companies in Russia and third countries have been listed in Annex IV of the Regulation which have been providing direct or indirect support to the Russian military industrial complex. They are subject to the prohibition in Article 2b relating to supply of dual-use technologies.

Individuals

• A further 22 persons have been added to Annex I of Regulation 269/2014, including 11 individuals involved in the abduction, forced assimilation and indoctrination of Ukrainian children have been listed. They are now subject to asset freezes under Article 2 of 269/2014.

Tech

• High-tech services
  • Bans on providing high-tech services to the Government of Russia or legal persons, entities or bodies established in Russia have been added in the amended Article 5n. This includes commercial space-based services, AI and high-performance computing services.

General

• Diplomatic travel restrictions
  • New Article 5v introduces an obligation for Russian nationals' who are posted to a diplomatic mission within the Schengen area, to inform the accrediting EU Member State 24 hours prior to travelling within the Schengen area outside of the host state. This extends to such nationals' family members, holders of a residence permit or a valid visa issued by another Member State.
  • New Article 5w allows Member States to impose authorisation requirements on the travel or transit through their territory for Russian diplomatic or consular personnel or their family members.