On 23 October 2025, the EU adopted, so-called, 19th package of sanctions against Russia. Accordingly, Regulation 2025/2033 amended Regulation 833/2014 (which is setting out the EU sectoral sanctions against Russia) and Regulation 2025/2037 and Implementing Regulation 2025/2035 amended Regulation 269/2014 (which is the main regulation setting out the EU asset-freeze sanctions against Russia).
Key elements of the package are:
1. Definitions of “control” and “ownership” with respect to companies are made parts of Regulation 269/2014. An important clarification is made to the scope of Article 2 bringing it in line with the Commission FAQs and market practice. A new listing criteria (and corresponding designations of persons) is added to Regulation 269/2014 and allows to list persons responsible for the transfer of the Ukrainian children to Russia.
2. New listings to the blocking sanctions, e.g., Polyus, FESCO or Evraz, as well as important Chinese refineries which deal in Russian crude.
3. Import ban for LNG and tightening of transaction bans against Russian oil majors.
4. Noteworthy new restrictions to provide professional services to Russia, which now covers tourist services. The restriction is relevant for SMEs and private individuals who often do not have capacity to follow multiple sanctions’ developments and may be indadvertedly caught by these prohibitions.
5. New restrictions will also apply to the finance, shipping and aircraft sectors.
This package demonstrates that the EU increasingly uses “secondary sanctions” by designating entities in third-party jurisdictions, including China, Hong Kong, Kazakhstan, Kyrgyzstan, Tajikistan, and the United Arab Emirates.
The package also introduces mirror sanctions against Belarus by amending Regulation 765/2006.
We also publish today a video with a summary of key changes resulting from this package of sanctions.