The European Union (EU) member states have agreed to strengthen restrictive measures against the aggressor state Russia and its supporter Belarus, adopting the 19th sanctions package on October 23, 2025. The new round of sanctions will significantly affect Russia's energy sector, imposing a ban on the import of liquefied natural gas, the financial sector, restricting the issuance of payment instruments, and the shadow fleet, including 116 new shadow fleet vessels on the sanctions list.
Key elements of the 19th round of sanctions
The list of goods and technologies subject to export bans has been expanded to include goods that can be used to develop Russia's military capabilities.
Goods that, due to their physical and chemical properties, can be used to develop Russia's military and defense capabilities, as well as be used in hostilities in Ukraine, include, for example, military rangefinders or various chemical alloys and metals used in the production of electronic devices, the export of which to Russia is prohibited.
Ban on the import of liquefied natural gas (LNG)
In order to negatively impact one of Russia's most profitable sectors, namely restricting the flow of electricity resources, the new round of sanctions imposes a ban on the purchase, import, and transportation of liquefied natural gas of Russian origin (or exported from Russia) from January 1, 2027.
Stricter restrictions on cashless transactions
Similar to the SPFS system created by the Central Bank of Russia, which was created in response to Russia's exclusion from the SWIFT network, the 19th round of sanctions prohibits transactions with certain persons using Mir (the Russian national payment card system) and SBP (Fast Payment System), which were created by the Central Bank of Russia or another legal entity registered in Russia.
Measures to restrict crypto asset transactions
Recognizing the risks that may arise from the use of crypto-assets to circumvent sanctions and finance war, EU Member States have decided to add to the list of transaction prohibitions those third-country financial institutions that provide services related to crypto-assets.
Prohibition on issuing payment instruments
The new round of sanctions prohibits the EU from issuing payment instruments to Russian nationals or natural persons residing in Russia, or to any legal person, entity or body established in Russia. A payment instrument is understood to be any personalised device and/or set of procedures agreed upon between a payment service user and a payment service provider and used to initiate a payment order.
Potential, the development of which can contribute to Russia's military capabilities – SEZ ban
Special economic zones, or SEZs, attract new companies with favorable tax rates, customs exemptions and other advantages for legal entities. Several such SEZs are located in different regions of Russia. The economic activities that take place in them can serve Russia's technological and industrial development, for example, unmanned aerial vehicles, combat weapons, military vehicles and other equipment that can be used for military purposes are produced under legally and economically favorable conditions. Recognizing the potential risks that attracting new companies to SEZs can pose, thereby strengthening Russia's military capabilities, sanctions prohibit any kind of involvement in the ownership structures of companies located in certain Russian SEZs, including establishing joint ventures, as well as concluding any kind of contracts with such companies.
Prohibition of the provision of artificial intelligence, quantum computing and commercial space services
In view of the rapid development of technologies, especially in the field of information technology, new restrictions have been imposed on the provision of services to persons registered in Russia in the following areas: artificial intelligence, commercial space services and quantum computing. The provision of such services can be used in the interests of Russia to develop its skills and technological solutions in geological exploration and the creation of precise geographical maps.
Russia as an undesirable tourist destination
In order to reduce the number of non-essential trips by EU citizens to Russia, the provision of tourism services to persons wishing to visit Russia on tourist trips is being restricted. Given that EU Member States are undesirable for Russia, citizens of Member States risk their freedom, which may be restricted under Russian jurisdiction. In such cases, EU Member States have limited diplomatic and consular possibilities to release their citizens and bring them to EU territory.
The provision of services requires authorization from the competent authority.
For the provision of such services (which are not prohibited) to Russian authorities, it will be mandatory to obtain a permit from the competent authority of the Member State. Before providing a specific service, the service provider will need to justify the need for this service. If the competent authority of the Member State decides to grant a permit after a thorough assessment of this justification, a permit will be issued on the basis of which the specific service may be provided.
Prohibition of reinsurance for Russian aircraft and ships
To reduce financial gain from selling old, unmaintained and unused aircraft and ships owned by Russia, it is prohibited to reinsure them for five years from the date of sale.
Extended deadline for transactions to ensure the closure of companies owned by EU nationals in Russia
Legal and natural persons of EU Member States with registered companies in Russia are being granted an extension of the deadline of 31 December 2026 for transactions related to the disposal or liquidation of these companies in Russia. The EU Member States reiterate that Russia is a country outside the rule of law, therefore, no reaction from Russia is foreseeable and decisions have been issued in relation to companies whose owners are from “undesirable countries”, including the European Union. This may lead to the risk of freezing the assets of such companies in Russia and other adverse actions against such companies. In particular, the EU calls for careful consideration and assessment of all possible risks for citizens of Member States who are considering establishing companies or joint ventures in Russia.
Stricter travel restrictions for Russian diplomats
A prior notification requirement is introduced for Russian diplomats and consular officials entering the Schengen area and Member States other than their Member States of accreditation. Member States will now have the right to prohibit Russian diplomats from entering their territory on the basis of entry documents issued by another country.
List of partner countries for oil imports expanded
The list of partner countries from which proof of origin is not required for imports of petroleum products, in accordance with Article 3ma of Regulation (EU) 833/2014 and Annex LI thereto, has been expanded to include Australia, Japan and New Zealand, in order to promote cooperation and energy security in Europe.
EU sanctions lists have been supplemented with:
Targeted financial sanctions set new definitions for the terms: “owned” and “controlled”
The definition of the above-mentioned terms will strengthen legal certainty and uniform practice in the EU Member States. Until now, the EU institutions have explained these terms in the form of guidelines. Now the terms have been incorporated into the regulations and become legally binding. It is important to emphasize that the definitions incorporated in the regulation correspond to the definitions previously explained by the EU institutions, therefore the practice of applying the terms will remain unchanged.
New definitions have been established in Article 1 of Regulation (EU) 833/2014 for the following terms:
Annex I to Regulation (EU) 269/2014 may further include persons involved in criminal offences against Ukrainian children and their assimilation in the interests of Russia, including deportation, forcible transfer and
Impact of the 19th round of sanctions on Belarus
In order to avoid the risk of possible circumvention of sanctions through Belarus, the elements of the 19th round of sanctions are also applicable to Belarus. Almost all of the above-mentioned prohibitions or restrictions, for example, in connection with the addition of new goods that can be used for the development of the military sector to the export ban list, restrictions on the provision of artificial intelligence services, restrictions on transactions using crypto assets, etc. Additionally, restrictions have been imposed related to the provision of computer software development, installation and maintenance services.
More information about the new round of sanctions is available in the Official Journal of the EU .
To help entrepreneurs develop and implement a set of measures, or internal control system (ICS), to mitigate and manage sanctions risks in transactions with merchants in countries with increased sanctions risk, the FID has published guidelines “Managing Sanctions Risks in Transactions with Increased Risk Countries”.
Since April 2024, the FID has been the national competent authority for sanctions enforcement issues in Latvia.
