EU Publishes 19th Sanctions Packages Against Russia

As Russia’s military aggression against Ukraine continues, the European Union (EU) has maintained its commitment to increasing economic and legal pressure on Russia. In 2025, the EU adopted its 16th, 17th, 18th, and now 19th sanctions packages, each introducing new measures and expanding existing restrictions. Below, we provide a summary of the 19th package and its key features, as well as a recap of the three packages that came before it, with a focus on the legal and practical implications for businesses and individuals operating in or with exposure to Russia and related jurisdictions.

19th sanctions package (October 23, 2025)

The 19th package represents the most comprehensive set of measures to date, with a focus on energy, finance, trade, and anti-circumvention:

• Energy sector: A total ban on Russian liquefied natural gas (LNG) was introduced, effective January 1, 2027, for long-term contracts and within six months for short-term contracts. Exemptions remain for oil imports from third countries and compliant oil transport to third countries.
• Shadow fleet and value chain: The number of listed vessels reached 557, with new sanctions on shadow fleet enablers, maritime registries, and oil trading companies in Hong Kong and the UAE.
• Financial measures: Five new Russian banks were added to the transaction ban, and new restrictions were imposed on Russia’s payment card and fast payment systems. For the first time, the EU sanctioned a ruble-backed stablecoin, its issuer, and a major trading platform, as well as a cryptocurrency exchange in Paraguay.
• Trade and export controls: The package expanded export bans on dual-use and advanced technology items, metals, salts, ores, and construction materials. Forty-five entities were added for supporting Russia’s military-industrial complex or engaging in circumvention, including entities in China, India, and Thailand.
• Special economic zones and service bans: The EU prohibited new contracts with entities in certain Russian special economic zones (SEZs) and imposed a ban on existing contracts for two SEZs focused on war-related activities. Service bans were extended to advanced digital and AI services, and re-insurance services for Russian vessels and aircraft were prohibited.
• Diplomatic and accountability measures: New requirements were introduced for Russian diplomats traveling within the EU, and additional listings targeted individuals involved in the abduction and indoctrination of Ukrainian children.

18th sanctions package (July 18, 2025)

The 18th package introduced further measures targeting Russia’s energy revenues, financial sector, and military-industrial complex:

• Energy measures: The oil price cap for Russian crude was lowered from $60 to $47.6, with a new dynamic mechanism to keep the cap 15% below the average market price for Urals crude. An import ban was imposed on refined oil products derived from Russian crude processed abroad.
• Shadow fleet expansion: Additional vessels were listed, bringing the total to 444. The EU also targeted companies managing shadow fleet vessels and a major Indian refinery with Russian ownership.
• Financial sector measures: The ban on specialized financial messaging services was transformed into a ban on provision of specialized financial messaging services with certain Russian banks into a full transaction ban. The package also broadened the transaction ban to include third-country financial operators and crypto-asset providers facilitating circumvention.
• Trade and anti-circumvention: Export restrictions were expanded to cover additional advanced technologies and industrial goods, with a dedicated catch-all provision to address circumvention via third countries.
• Accountability and protection measures: The package included new listings related to the indoctrination of Ukrainian children and introduced protective measures for EU Member States against arbitration claims by sanctioned persons.

17th sanctions package (May 20, 2025)

The 17th package further tightened restrictions, with a focus on battlefield technologies and energy revenues:

• Shadow fleet and entity listings: The EU listed additional vessels, bringing the total to 342, and expanded the port access ban and service prohibitions. Thirty-one new companies were added for supporting Russia’s military-industrial complex or engaging in sanctions circumvention, including entities in Turkey, Vietnam, UAE, Serbia, and Uzbekistan.
• Expanded individual and entity listings: Seventy-five additional listings targeted individuals and entities undermining Ukraine’s sovereignty, with a focus on the Russian military and defense sectors, as well as those involved in the looting of cultural heritage.
• Trade measures: The package broadened export restrictions on dual-use and advanced technology items, including chemical precursors used in missile propellants and spare parts for high-precision CNC machine tools.
• Sakhalin-2 exemption: The exemption from the oil price cap for the Sakhalin-2 project was extended for one year to ensure Japan’s energy security.

16th sanctions package (February 24, 2025)

The 16th package marked a significant escalation in the EU’s efforts to disrupt Russia’s military and industrial capabilities. Key measures included:

• Anti-circumvention measures: The EU expanded its list of targeted vessels to 153, focusing on Russia’s so-called “shadow fleet” and vessels contributing to Russian energy revenues. New listing criteria were introduced to target those supporting unsafe oil tanker operations.
• Export and import restrictions: The package imposed targeted export restrictions on 53 companies supporting Russia’s military-industrial complex, including 34 entities outside Russia. A direct import ban on Russian primary aluminum was introduced, with a quota mechanism to facilitate a transition for EU businesses.
• Dual-use and advanced technology controls: Additional dual-use items were restricted, including chemical precursors, software for Computer Numerical Control (CNC) machine tools, and video-game controllers used in military applications. Chromium ores and compounds were also added, due to their military relevance.
• Energy and transport measures: The EU prohibited temporary storage or free zone placement of Russian crude oil or petroleum products in EU ports, even if compliant with the oil price cap. Restrictions on software for oil and gas exploration were extended to crude oil projects.
• Financial sector measures: Thirteen financial institutions were added to the list of entities subject to specialized financial messaging service bans, and three banks were added to the transaction ban for using Russia’s Financial Messaging System of the Central Bank of Russia (SPFS) system to circumvent sanctions.
• Disinformation and media: The package suspended the broadcasting activities of eight additional media outlets supporting Russia’s war effort.

The EU’s 16th through 19th sanctions packages reflect a sustained and evolving effort to undermine Russia’s ability to finance and sustain its military aggression. Businesses and individuals subject to EU jurisdiction must remain vigilant, regularly update compliance programs, and closely monitor regulatory developments to mitigate legal and operational risks. The increasing complexity and extraterritorial reach of these measures underscore the importance of proactive risk management and legal review in all cross-border dealings involving Russia and related third countries.