19th sanctions package targets energy sector and extends export bans

On 23 October 2025, the Council of the European Union adopted the 19th sanctions package against Russia[1]. The package primarily targets the energy (see I.) and financial (see II.) sectors. Apart from new measures in the area of financial sanctions on individuals (see III.), it also includes new export bans on construction materials (see IV.) and extends the ban on services (see V.). Finally, one good piece of news is that the possibilities for obtaining authorisations in connection with exits from Russia have been extended again (see VI.).

The amendments enter into force on 23 October and 24 October 2025; transitional periods are provided for in some cases.

I. Financial sector: bans on transactions extended

In the financial sector, the transaction ban set out in Article 5ac(2) of Regulation (EU) No 833/2014 has been expanded as of 2 December 2025 to include four additional banks in Belarus and Kazakhstan. These banks have been found to support the Russian war economy, thereby undermining the effectiveness of EU sanctions.

Five further Russian banks (Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank and Alfa-Bank) will be subject to the transaction ban under Article 5h of Regulation (EU) No 833/2014 from 12 November 2025.

In addition, further entities involved in cryptocurrencies and sanctions evasion have been made subject to transaction bans under Article 5ad(1) of Regulation (EU) No 833/2014, with eight further financial institutions now being listed, including from Tajikistan and Kyrgyzstan. To combat circumvention structures, successor entities are also covered by the transaction ban if they replace listed entities (Article 5ad(2)(b) of Regulation (EU) No 833/2014). Criteria for identifying such mirror or successor entities are laid down in Article 5ad(2a) of Regulation (EU) No 833/2014.

The stablecoin A7A5, which is based on the rouble, is the first cryptocurrency to come into the EU’s focus.

II. Energy: phasing out Russian liquefied natural gas

Earlier than expected, the EU will ban imports of liquefied natural gas originating in or exported from Russia. Article 3ra of Regulation (EU) No 833/2014 states that this ban will generally apply from 25 April 2026, although long-term/existing supply contracts will only be affected from 1 January 2027. Nevertheless, the ban will come into force one year earlier than originally envisaged in the Commission’s plan to phase out imports of Russian fossil fuels.

In addition, sanctions on the “shadow fleet” have been extended, with 117 more ships being listed.

III. Financial sanctions clarified and extended

The details to the freezing of funds and the prohibition on making them available set out in Article 2 of Regulation (EU) No 269/2014 have been clarified. The extension to “natural or legal persons, entities or bodies associated with” listed persons has been removed, although this should have no impact on the scope of the prohibitions.

The terms “ownership” and “control” within the meaning of the Regulation have been legally defined for the first time. Ownership is now explicitly defined as being in the possession of 50 % or more of the ownership rights in a legal entity. In addition, Article 1(j) of Regulation (EU) No 269/2014 now lists examples of control over a legal entity, such as the right to recall members of the management or supervisory body or sole control over the majority of voting rights. In terms of content, this codifies the familiar requirements of the EU Council’s “Best Practices”.

Annex I of the above regulation, which lists the natural and legal persons affected by the asset freeze and the prohibition on making funds available, has been expanded to include 22 individuals and 42 companies. These primarily consist of Russian companies from the defence, raw materials and transport sectors, as well as companies from China and the United Arab Emirates.

IV. Export restrictions on ores, rubber products and construction materials

The Council has imposed export restrictions on other goods, including ores, rubber products and construction materials. Chapters 25 (including stone, earths and cement) and 26 (ores) of the Harmonised System are now fully subject to the prohibitions under Article 3k of Regulation (EU) No 833/2014.

The export restrictions now also apply to the entire headings 4008 (sheets etc., of vulcanised rubber), 4009 (tubes, pipes and hoses, of vulcanised rubber), 6904 (bricks) and 6909 HS (ceramic wares) as well as parts of heading 4011 HS (new pneumatic tyres of rubber).

Further, headings 4013 (inner tubes, of rubber), 6815 (articles of mineral substances), 6902 (refractory ceramic constructional goods) and 6903 HS (other refractory ceramic goods) have been added to Annex XXIII of Regulation (EU) No 833/2014. For existing contracts covering the newly listed goods, a transitional period until 25 January 2026 applies (Article 3k(3aj) of Regulation (EU) No 833/2014). For goods under headings 6902 (refractory ceramic constructional goods) and 6909 19 HS (ceramic wares), this privilege will continue until 25 April 2026 (Article 3k(3aj) of Regulation (EU) No 833/2014).

In addition, the list of goods that could contribute to Russia’s military and technological strength has been expanded. The export restrictions now also extend to surface-mounted device inductors, nettings, canopies, tents, blankets and apparel, specially designed or suitable for use in military combat, field operations, or for camouflage purposes, the metal molybdenum and constituent chemical for propellants.

Finally, 45 additional entities have been added to the list of legal persons supporting Russia’s war of aggression and are therefore now subject to stricter export restrictions on dual-use goods. These are not only Russian companies, but also entities from third countries such as China, India and Thailand.

V. Further measures: service bans, special economic zones and aircraft

The extension and tightening of the existing service bans for persons in Russia and the Russian government (Article 5n of Regulation (EU) No 833/2014) is also of practical relevance. On the one hand, this ban now covers services in the areas of space (in particular Earth observation and satellite navigation), artificial intelligence and high-performance/quantum computing (Article 5n(1), points (f) to (h) of Regulation (EU) No 833/2014).

The Council has also addressed Russian special economic zones by prohibiting any participation in or provision of financial resources to companies located in the zones listed in the new Annex LII of Regulation (EU) No 833/2014. This also applies to the maintenance of participation and the establishment of joint ventures.

In order to limit the Russian state’s revenue from the sale of used aircraft or ships, Article 5u of Regulation (EU) No 833/2014 prohibits the offering of reinsurance for a period of five years following the sale.

VI. Russian exits still privileged: possibilities for authorisation extended

The EU’s decision to extend the timeframe for obtaining authorisations under Article 12b(1) of Regulation (EU) No 833/2014, is a positive development. Authorisations can now be applied for until the end of 2026 for a wide range of activities that are currently prohibited if this serves to withdraw investments from or wind down business activities in Russia.

VII. Outlook

The 19th sanctions package sends a clear message: the EU’s support for Ukraine is unbroken. The aim is to deal a further blow to the Russian war economy. The next steps in this direction are on the horizon: EU High Representative for Foreign Affairs Kallas has already announced work on a 20th sanctions package.

Affected companies will once again be obligated to satisfy more stringent and comprehensive requirements under EU sanctions law to ensure their continued compliance. It remains to be seen whether and to what extent the German authorities will provide relief to affected companies. One possible option would be to extend General Authorisation 42 (Allgemeine Genehmigung 42) to the newly covered services.

 

 

 

 

[1] Regulation (EU) 2025/2033 amending Regulation (EU) No 833/2014 and Regulation (EU) 2025/2037 amending Regulation (EU) No 269/2014 were enacted in relation to Russia. In addition, Implementing Regulation (EU) 2025/2035 amending Regulation (EU) No 269/2014 was enacted. In relation to Belarus, Regulation (EU) 2025/2041 amending Regulation (EC) No 765/2006 and Implementing Regulation (EU) 2025/2039 implementing Article 8a(1) of Regulation (EC) No 765/2006 were enacted.