Review of the 19th package of EU sanctions

On October 23, 2025, the EU Council approved the 19th package of sanctions against Russia. The new measures in the 19th package are mainly aimed at the energy, financial and military-industrial complexes, as well as, among other things, against the activities of the so-called “shadow fleet” used to transport Russian oil. In particular, 117 vessels have been added to the list of vessels that are prohibited from entering the ports of the EU member States. In addition, an additional criterion was introduced for inclusion in the sanctions lists, and in order to avoid ambiguity in the interpretation of a number of terms regarding ownership and control of legal entities, new definitions were included in Regulation 269 (the concept of “ownership” and “control” in relation to legal entities).

– Blocking sanctions –

(i) Updating the sanctions lists

The list of persons subject to the blocking sanctions of the European Union was supplemented by 21 individuals and 42 organizations. The updated sanctions list includes, among other things::

Nikita Yuryevich Anisimov is the rector of the National Research University Higher School of Economics.
Maxim Sokolov is the head of AvtoVAZ.
Alexey Vadimovich Lowus is the General Director of PJSC Energia.
CHA Yong Beom is a lieutenant general in the Korean People’s Army.
PJSC Polyus is a gold mining company.
AvtoVAZ JSC is an automobile plant.
Evraz PLC is one of the largest mining companies.
Maxima Legal is a law firm.

Separately, it should be noted that the Russian law firm Maxima Legal was included in this package of sanctions for the first time. The basis is criterion h (circumvention of sanctions) of Regulation 269. Rationale: “The law firm has submitted numerous requests to the competent national authorities for the unblocking of assets frozen by restrictive EU measures. Maxima Legal LLC provided forged documents to substantiate its claims with the sole purpose of achieving the lifting of the freeze on its clients’ funds.” Thus, the EU is expanding the practice of applying blocking measures against individuals and legal entities, paying attention to law firms that provide services to clients for unfreezing assets in the EU.

– Sectoral sanctions –

(i) The energy sector

The 19th package of measures introduces a complete ban on the conclusion of new contracts for the purchase of Russian reduced natural gas (LNG) for short–term contracts – for six months; for long-term contracts – from January 2027.
New restrictions against PJSC Rosneft and PJSC Gazprom Neft. The existing ban on transactions involving two major Russian oil companies has been tightened.
Sanctions have been imposed against companies from China – two refineries and one trader who purchase oil from Russia, including Tianjin Xishanfusjeng International Trading Co., Liaoyang Petrochemical Company, Shandong Yulong Corporation Limited.
Strengthening measures against the “shadow fleet”. 117 ships of the “shadow fleet” have been added to Appendix XLII. The 19th package includes Litasco Middle East DMCC, a major intermediary of Lukoil’s shadow fleet based in the United Arab Emirates, on the sanctions list.
Flag registries and shipbuilders contributing to the illegal activities of this fleet have been blocked.
In addition to the existing restrictions on insurance of ships and aircraft allegedly involved in violating/circumventing the EU sanctions regime, the 19th package introduces a direct ban on reinsurance services.

(ii) Financial sector

The developer, issuer and trading platform of the ruble-denominated stablecoin A7A5 were sanctioned. All transactions with this asset are prohibited in the EU.
In accordance with annex XIV, 8 banks and oil traders from Tajikistan, Kyrgyzstan, the United Arab Emirates and Hong Kong and 5 Russian banks — Istina, Zemsky Bank, Absolut Bank, MTS Bank and Alfa-Bank, which provide direct or indirect support to the Russian military or they contribute to circumventing sanctions. The sanctions list also includes 4 banks from Belarus and Kazakhstan for participating in alternative payment systems with Russia.
New restrictive measures have been introduced in connection with the use of the MIR and SBP systems, the EU prohibits interaction with them.
Restrictions on the activities of companies in nine Russian special economic zones, which play a key role in Russia’s industrial potential, have been strengthened.

(iii) Military and defense structures

The EU is imposing sanctions against individuals and legal entities that are part of the Russian military-industrial complex (MIC), as well as suppliers of dual-use products from the UAE and China.

(iv) Trade and exports

Restrictions have been imposed against 45 companies supporting the Russian military-industrial complex (MIC), including suppliers of electronics, drones and technologies, of which 17 are located outside Russia, 12 in China (including Hong Kong), 3 in India, 2 in Thailand.
The list of goods under the export ban has been expanded: microelectronics, chemicals for gunpowder, metals, oxides, rubber products, pipes, tires, building materials.
A ban is imposed on the purchase and import of all acyclic hydrocarbons important for the petrochemical sector.

(v) Services

Any services provided to the Russian government now require prior EU approval.
The provision of services in the field of artificial intelligence, high-performance computing and commercial space systems is limited.
Article 5n of Regulation 833 has been supplemented with a ban on providing travel services in Russia, according to the preamble of the Regulation, “the ban was introduced in order to reduce the income that Russia receives from such services and to curb the promotion of non-essential travel and recreation in Russia, especially in conditions where EU citizens are at increased risk of arbitrary arrests and detentions.”

– Other sanctions restrictions –

(i) New definitions in Regulation 833/2014 and Regulation 2580/2001

Regulation 833/2014 has been supplemented with new definitions to specify sectoral prohibitions in relation to certain business areas. In particular, definitions of “crypto assets”, “payment services”, and “services directly related to tourism activities” have been added to Regulation 833.
In order to avoid ambiguity of interpretation, a number of terms and definitions regarding ownership and control of legal entities have been brought into line with Anti-terrorism Regulation 2580/2001. Regulation 269 now includes definitions of “ownership of a legal entity” and “control”.

(ii) In respect of the Republic of Belarus

Five enterprises of the Belarusian military-industrial complex (MIC) and structures associated with the Lukashenko regime were sanctioned.
The ban on software has been expanded, including products for banks, AI, quantum computing, and data analysis.

(iii) In relation to children

The EU has added 11 persons involved in the deportation of Ukrainian children to Russia to the sanctions list.
A new criterion is being introduced for future sanctions – for the abduction and forced assimilation of children.

(iv) In relation to diplomats

Russian diplomatic and consular staff traveling on a Schengen visa outside the country of accreditation must notify the authorities of the relevant state in advance, and EU countries may require additional entry permits for such diplomats.

How Jingsh Law Firm can help you:

We support Chinese companies operating in Russia and Russian companies operating in China, providing comprehensive legal support on issues of sanctions and compliance regulation.

Our services include:

Preparation of reviews of existing sanctions and clarification of the procedure for their application in the relevant jurisdictions;
Risk analysis when interacting with counterparties and recommendations for their reduction;
Identification of sanctions risks in a specific field of activity;
Legal opinion training (if necessary, with the involvement of foreign specialists);
Checking contracts for sanctions restrictions and recommendations for their adjustment;
Advising on structuring contractual and corporate relations, taking into account sanctions legislation (without the purpose of circumventing sanctions);
Conducting a sanctions check of counterparties;
Preparation of requests to the competent authorities of sanctions regulation;
and other legal support.

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