The new sanctions package entered into force on 24 October 2025. This time, its substantive scope focuses in particular on three sectors.
- Energy sector: Among other things, a comprehensive import ban on Russian liquefied natural gas (LNG) from April 2026, under Article 3ra of Regulation (EU) No 833/2014. An exception applies to long-term contracts with a duration of more than one year concluded before 17 June 2025, for which the ban does not apply until 1 January 2027.
- Financial sector: Transaction prohibitions affecting banks. This covers the prohibition of transactions with the Russian payment service providers MIR and the Fast Payment System. In addition, Russian and Belarusian nationals and Russian and Belarusian companies may no longer be provided with services in the crypto-asset sector.
- Services sector: The services sector is likewise further restricted through the revised Article 5n, in particular in order to prevent the strengthening of Russia’s technological capabilities, by prohibiting the provision of certain commercial space-based services, AI services, and high-performance computing and quantum computing services. Other engineering services are likewise further restricted, as are related scientific and technical consulting services: geological, geophysical, and other scientific prospecting, subsurface and surface surveying, and cartographic work. A comparable extension of prohibited services also applies with respect to Belarus.
Also important for companies: the list of goods in Annex XXIII has been significantly expanded. A further 45 organisations have been added to the list of legal persons, entities, or bodies, and there are also changes to the goods lists, together with an extension covering raw materials.
New in this package is a mechanism restricting the freedom of movement of Russian diplomats within the EU. They must give advance notice before travelling to states other than the one to which they are accredited. Those states, in turn, may restrict the diplomats’ transit or entry. Whether this amounts to no more than a minor irritant, or whether it will actually prove useful for counter-espionage purposes, remains to be seen.
Conclusion: What do you need to do now?
- Internal communication, including, where appropriate, training on the content of the 19th sanctions package.
- Goods and services screening, including list checks.
- Adjustment of internal processes, and, where necessary, suspension of existing import/export relationships.
