EU adopts 19th package of restrictive measures against Russia

This 19th package supplements those detailed in our previous newsflashes, and includes five regulations that entered into force on 24 October 2025, the last two of which relate to Belarus:

• Council Regulation (EU) 2025/2041 of 23 October 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine
• Council Regulation (EU) 2025/2033 of 23 October 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
• Council Implementing Regulation (EU) 2025/2035 of 23 October 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
• Council Regulation (EU) 2025/2037 of 23 October 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening integrity, sovereignty and independence of Ukraine
• Council Implementing Regulation (EU) 2025/2039 of 23 October 2025 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

New designations

Russia’s largest gold producer, PJSC Polyus, is among the 22 individuals and 42 entities newly subject to asset freezes and bans on providing economic resources.

Amendments to the asset freeze framework

For the first time, the Council has introduced definitions of “owning” and “controlling” a legal person in its regulations on restrictive measures against Russia. These definitions are aligned with the existing framework in Council Regulation (EC) No 2580/2001 on specific restrictive measures directed against certain persons and entities with a view to combating terrorism.

In addition, the scope of asset freeze measures is narrowed by removing references to persons “associated with” listed individuals and entities.

A new asset-freeze listing criterion has also been introduced, targeting those responsible for the abduction, forced assimilation and militarised education of Ukrainian children.

Energy sector restrictions

EU operators will be prohibited from importing Russian LNG from 25 April 2026. A wind-down period will apply to contracts concluded before 17 June 2025 with a duration exceeding one year.

Existing exemptions for major Russian oil companies – including Rosneft and Gazprom Neft – have been lifted, thereby imposing a full transaction ban on these entities.

The Council also expanded the list of partner countries from which petroleum products may be imported without requiring proof of the origin of the crude oil used for refining. The list now includes Australia, Japan and New Zealand, in addition to Canada, Norway, the United Kingdom, the United States and Switzerland.

Russian “shadow fleet”

The Council added 117 vessels to the list of Russia’s “shadow fleet”. These ships are now banned from entering EU ports and locks, and from receiving a broad range of services related to maritime transport.

The agreed measures also introduce a prohibition on providing reinsurance for these vessels.

Financial sector restrictions

EU operators are now prohibited from engaging in any transaction with:

• five additional Russian banks: Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank;
• eight banks and oil traders from Central Asia, the UAE and Hong Kong, due to their involvement in sanctions circumvention;
• A7A5, a rouble-pegged stablecoin, its developer and a platform where it is heavily exchanged; and
• Russia’s National Payment Card System (Mir) and Fast Payment System (SPB).

Furthermore, the Council has extended existing restrictions on providing crypto services to Russian persons and on the operation of crypto platforms.

Export controls

Export bans on critical goods used in the production of military systems have been expanded. These now include certain: (i) electronic components, rangefinders and chemicals, (ii) metals, oxides and alloys, and (iii) salts, ores, rubber and construction materials.

In addition, 45 Russian and foreign companies supporting Russia’s military-industrial complex are now subject to stricter export restrictions on dual-use goods and technologies.

Restrictions targeting Russian Special Economic Zones

EU operators are now prohibited from investing in entities registered in nine listed Russian Special Economic Zones (SEZs), including any entities they own or control.

Effective 25 January 2026, maintaining any existing participation in two of these SEZs – Alabuga and Technopolis Moscow – will also be prohibited.

Transport assets restrictions

The agreed measures establish a five-year prohibition on providing reinsurance services for Russian-owned vessels and aircraft following their sale to third countries.

Services restrictions

As part of the new package, the Council introduced additional restrictions on the provision of certain services, notably in AI, high-performance computing and commercial space-based services.

The provision of any non-prohibited services to the Russian government is now subject to prior authorisation.

Travel restrictions on Russian diplomats

Russian diplomats are now required to notify EU Member States in advance when traveling across the Schengen area outside their country of accreditation.

Restrictive measures targeting Belarus

The Council added five Belarusian military sector entities to the asset freeze list due to their support for Russia’s war in Ukraine. In addition, this package applies several of the same trade restrictions imposed on Russia to Belarus.

Lastly, the Council expanded existing restrictions on Belarusian crypto-asset services and reinforced the ban on certain types of software used in banking, finance, space-based services, AI and quantum computing.