The 19th EU Sanctions Package against Russia (23 October 2025): LNG Ban, New Listings, and Expanded Transaction and Services Restrictions

On 23 October 2025, the EU adopted its 19th sanctions package against Russia. The centrepiece is a far-reaching ban on the purchase, import and transfer of Russian liquefied natural gas (LNG), with staggered entry into force. Beyond LNG, the package introduces multiple tightening measures that are highly relevant for contract and transaction due diligence in practice: expanded goods annexes, additional transaction prohibitions and exemptions, a broader ban on connecting to Russian payment messaging systems, new restrictions linked to designated Russian special zones, and a significant expansion of both services bans and crypto-related restrictions.

I. Regulations amended

The 19th sanctions package consists of several legal acts, all dated 23 October 2025. In substance, it amends and/or implements (i) the Russia embargo Regulation (EU) No 833/2014, (ii) the Belarus embargo Regulation (EC) No 765/2006, and (iii) the listing/financial sanctions Regulation (EU) No 269/2014.

II. Key amendments to the Russia embargo Regulation (EU) No 833/2014

Most changes are made to Regulation 833/2014. They primarily concern goods annexes, import and export prohibitions, energy (LNG), the so-called “shadow fleet”, transaction bans, payment messaging systems, special zones, as well as services and crypto.

Additions to Annexes IV and VII (military end-users, advanced technology)

Annex IV (military end-users / military-industrial complex) has been expanded by 45 new entries. For compliance practice, this means end-use and end-user diligence becomes even more critical again, as many prohibitions are effectively “triggered” by the listing of specific persons, entities or bodies (PEBs).

Annex VII (advanced technology) has been supplemented with additional items in Part A, while several tables in Part B have been recast (including, among others, cameras/sensors/optics, energetic materials and precursors, and chemicals/metals/alloys/composites and other advanced materials). As a result, the compliance focus shifts in part from “classic” dual-use screening towards highly technical annex checks at CN/HS level.

Luxury goods: restructuring without material liberalisation

Annex XVIII (luxury goods) has been streamlined and restructured across several tables. While certain HS headings are no longer listed in the luxury goods annex, this does not amount to a substantive relaxation: the relevant items have been moved to other annexes under Regulation 833/2014, meaning export-side restrictions continue to apply. For companies, this is a typical “annex shift” scenario that can lead to incorrect conclusions if only one annex is reviewed.

Import restrictions under Article 3i (Annex XXI)

Annex XXI has been amended so that all acyclic hydrocarbons under CN subheading 2901 10 00 are now covered on the import side. Accordingly, the purchase, import or transfer of these goods is prohibited where they originate in Russia or have been exported from Russia. A grandfathering clause for pre-existing contracts has been introduced. In addition, the package provides for an authorisation option for certain goods listed in Annex XXI (HS subheading 8539 49) in the context of drinking-water disinfection.

Export restrictions under Article 3k (Annex XXIII and transitional Annex XXIIIG)

Annex XXIII has again been expanded substantially. Particularly relevant is the broad coverage of HS Chapters 25 and 26 (salt/sulphur/stone and earths, etc., and ores/slag/ash), as well as additional goods from Chapters 40, 68 and 69 (rubber; articles of stone/plaster/cement, etc.; ceramic products).

The package also provides transitional periods (grandfathering for existing contracts): for newly covered goods under the CN codes listed in Annex XXIIIG, performance is permitted until 25 January 2026; for certain ceramic goods (HS heading 6902 and HS subheading 6909 19), until 25 April 2026. In addition, the authorisation option for certain private household uses in Russia has been extended to further goods.

Ban on purchasing, importing and transferring Russian LNG (Article 3ra)

The core measure is the LNG ban. From 25 April 2026, it is prohibited to purchase, import or transfer—directly or indirectly—liquefied natural gas under CN subheading 2711 11 00 where it originates in Russia or has been exported from Russia. The provision of ancillary services (including technical assistance, brokering services, financing/financial assistance or other services) connected with the prohibited activity is likewise prohibited.

For contracts concluded before 17 June 2025 with a term exceeding one year and not amended since, a later start date applies: in those cases the prohibitions only take effect from 1 January 2027. At the same time, the Regulation sets out a narrow catalogue of permitted “non-material” amendments (including reductions in volumes as well as price/fee reductions, adjustments to confidentiality and operational procedures, address changes, intra-group transfers, amendments resulting from court/arbitration proceedings, and certain delivery-point changes for landlocked countries). In practice, the decisive question will be whether and to what extent a “long-term contract” has truly remained unchanged.

Expanded restrictions on the “shadow fleet” (Article 3s and Annex XLII)

For restrictions concerning listed vessels, it has been clarified that the prohibition also covers reinsurance. Annex XLII has moreover been expanded significantly: four vessels were removed and 117 newly listed; the list now contains 557 vessels in total. This is particularly relevant across chartering, insurance, trading and logistics chains, as screening must be performed not only on counterparties but also at vessel and IMO level.

Transaction bans (including Articles 5aa, 5ad, 5ae, 5h) and the financial sector

The package includes several adjustments to transaction prohibitions. The exemption for winding up a joint venture or similar arrangements under Article 5aa(3)(d) has been extended until 31 December 2026. A narrowly framed exemption for certain oil-sector transactions has also been added. In addition, the authorisation option for transactions required for divestments has been extended until 31 December 2026.

Within the banking sector, additional banks have been added to the annexes and, in part, transitional rules (grandfathering/payment acceptance rules) have been introduced. The transaction ban concerning listed crypto-asset service providers (Article 5ad) has been expanded to cover comparable and successor organisations; Annex XLV has been supplemented and accompanied by grandfathering provisions. As regards the transaction ban involving listed ports and locks (Article 5ae), listing is now, in principle, possible also for facilities outside Russia; in practice, this is currently without effect because the relevant annex section remains empty.

Broader ban on participation in payment messaging systems (SPFS, SBP, Mir)

The prohibition on connecting to the Central Bank of Russia’s SPFS system will be significantly expanded from 25 January 2026. The ban will then also cover connections to payment messaging systems provided by other legal persons incorporated or registered under Russian law, including SBP and Mir. For banks, payment service providers and corporate treasury functions, this is operationally material because technical interfaces and payment rails themselves become sanctions-relevant.

New restrictions linked to Russian special zones (Article 5ah, Annex LII)

A new Article 5ah has been introduced in Regulation 833/2014 covering designated Russian special economic, innovation and preferential zones (Annex LII). Prohibited activities include, among others, new investments and the expansion of existing investments, establishing new joint ventures/branches/representative offices, and entering into new supply or services contracts (including IP/know-how-related rights) into, from, or for use in the listed zones, or with legal PEBs established there. A divestment obligation applies with a transitional period until 25 January 2026; certain control structures outside the zones are also captured.

Expanded crypto and services restrictions (Articles 5b, 5ba, 5n)

Crypto restrictions have been materially widened: Article 5b(2) now covers, in addition to traditional crypto services, the issuance of payment instruments, acceptance and processing of payment transactions, payment initiation, and the issuance of e-money. A further prohibition has been introduced on participating in transactions connected with certain crypto-assets listed in Annex LIII (Article 5ba).

Article 5n (services bans) has been fully recast and expanded, including services in the areas of artificial intelligence, high-performance computing/quantum computing, and tourism-related services. For service providers (consulting, IT, engineering, travel), the scope of work must therefore be mapped more granularly and tested against the catalogue of prohibited services.

III. Amendments to the Belarus embargo Regulation (EC) No 765/2006

In parallel, the Belarus measures have been aligned more closely with the Russia framework. In addition to further listings, services bans have been expanded (including accounting, integrated engineering, urban planning, technical consulting, technical testing and analytical services) and software prohibitions have been added for certain uses in the banking and financial sector. From 25 November 2025, it is also prohibited to provide certain commercial space-based services (earth observation/satellite navigation), AI-related services (access to models/platforms for training/fine-tuning/inference), and high-performance computing/quantum computing services. Goods annexes and grandfathering rules were also updated; on the import side, all acyclic hydrocarbons under CN subheading 2901 10 00 are now likewise covered.

IV. Listing and financial sanctions under Regulation (EU) No 269/2014: new listings and defined ownership/control criteria

Regulation 269/2014 has been expanded through new listings (22 natural persons and 42 legal PEBs), including companies established in third countries such as China, Hong Kong, the United Kingdom, the United States, the UAE and Kyrgyzstan. The EU thereby again emphasises that circumvention scenarios and third-country intermediaries are treated as core sanctions-risk vectors.

In addition, a new listing criterion has been introduced for PEBs responsible for acts or policies contributing to the deportation, unlawful transfer or forced assimilation of Ukrainian minors. Also relevant in practice is the clarification that financial sanctions apply only to listed PEBs; PEBs that are merely mentioned but not listed are not automatically subject to asset-freeze measures. Finally, the concepts of ownership and control have now been defined in Regulation 269/2014, giving legally binding form to what had previously been reflected primarily in practice guidance (“Best Practices”).

V. Practical takeaways

With the LNG ban, the 19th sanctions package marks an energy-policy milestone—while at the same time expanding the sanctions architecture across multiple technical and operational dimensions (annex-level goods screening, transaction prohibitions, payment messaging systems, special zones, services and crypto). Companies should therefore review existing contracts and future transactions not only against traditional goods lists, but also with a sharper focus on payment rails, IT and services scopes, logistics (including vessel screening), and intra-group structures. It is equally important to factor in transitional periods, new exemptions and available authorisation pathways.

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Your contact: Attorney-at-Law Dr. Hendrik Müller-Lankow (German and EU qualified lawyer)