On 23 October 2025, the Council of the European Union adopted the nineteenth package of sanctions in response to the conflict between Russia and Ukraine. These restrictive measures reinforce the EU’s economic and political pressure to reduce the income and military-industrial capacity of Russia and its facilitators, closing loopholes (finance, crypto assets, the ghost fleet, Special Economic Zones) and extending control over advanced services and the mobility of diplomats.
- Gradual veto on liquefied natural gas and associated services; closure of financial and payment routes (including third countries) and crypto-asset services; reinforced action against the ghost fleet and ports/locks; extension of annexes on goods, technologies and entities; and limits on advanced services with prior authorisation to the Russian public sector
Council Regulation (EU) 2025/2033 amending Regulation (EU) No 833/2014 and Council Decision (CFSP) 2025/2032 amending Decision 2014/512/CFSP, introduce a ban on the purchase, import or transfer of liquefied natural gas of Russian origin. The application is staggered; in general, from 25 April 2026, and from 1 January 2027 when the transaction is carried out under supply contracts of more than one year signed before 17 June 2025 without subsequent substantive amendments (only technical adjustments or downward adjustments in price and/or volume, among other cases, are permitted).
Related services (technical assistance, intermediation, financing or insurance) that enable such operations are also prohibited.
At the same time, the crackdown on energy revenues is being tightened; the Council highlights measures on state-owned oil producers, the increase in designated vessels within the opaque fleet and the ban on reinsuring vessels linked to that fleet. In addition, the veto is extended to ‘all acyclic hydrocarbons’ due to their revenue relevance for Russia.
The ban on transactions is also extended to entities that connect or facilitate payments through Russian financial infrastructures, such as the Russian National Payment Bank’s card system and the Russian instant payment system. It also applies to banks and payment service providers in third countries when they facilitate circumvention or provide services to listed entities. The Council establishes limited exemptions (e.g. for diplomatic functions or the settlement of existing contracts) and specifies that payment initiators and acquirers are not required to verify nationality for each individual transaction, so as not to distort the technical obligations of the sector.
In view of the increased use of crypto-assets to circumvent sanctions, the Council prohibits the provision of crypto-asset services and payment services to Russian entities and intermediaries in third countries that support such circumvention. Specific cases are mentioned (including a crypto asset identified as “A7A5”), supported by Russian authorities, with a ban on transactions involving that asset in the Union, and the operational framework is integrated into the sectoral text, extending the scope to ‘successor’ or ‘mirror’ providers seeking to replicate already designated entities.
Measures against the ‘shadow fleet’ are strengthened: 117 additional vessels (bringing the total to 557 vessels) are designated as subject to a ban on calling at Union ports and a prohibition on a wide range of services (insurance, reinsurance, brokerage, assistance). action is also taken against maritime registers that grant false flags of convenience and against logistics companies and/or ports relevant to the diversion of hydrocarbons or military equipment. The Council includes a ban on reinsuring ships in the opaque fleet, restricting their operations.
The list of entities (including those from third countries) that support Russia’s industrial and military base is being expanded, subjecting the export of dual-use goods and other advanced items (CNC machine tools, microelectronics, unmanned aircraft systems, etc.) to stricter controls.
In addition, the export ban is extended to electronic components, new chemicals (including precursors for propellants), metals, oxides and alloys relevant to military systems; rubber items, pipes and tyres, grinding wheels and construction supplies, among others, are also added. The Council sets out these changes in extensive annexes (e.g. updating Annex XXIII with new tariff headings) and records the extension of the ban to all acyclic hydrocarbons in the Annex on import prohibitions.
Prior authorisation is required for any service provided to the Russian Government, in order to assess ex ante the risk of contributing to military, technological or industrial capabilities.
The provision of space-based commercial services (Earth observation and satellite navigation), artificial intelligence services (access to models, training or fine-tuning and inference platforms) and high-performance and quantum computing services is restricted. The scope of engineering, scientific and technical consulting, prospecting and testing services (UN Central Product Classification family 867) is also expanded, and services directly related to tourism activities in Russia are prohibited.
- Listings and affected parties: expansion to third-country networks, freezing effects and indirect prohibition due to expanded ownership/control, and compliance programme with in-depth screening, sanctions clauses and strictly justified licences
The Council adds individuals and companies that finance, facilitate or sustain Russian military-industrial, logistical and propaganda capabilities, and incorporates third-country networks (banks, payment processors, crypto-asset platforms, logistics operators and manufacturers) when they act as bridges for circumvention. Council Decision (CFSP) 2025/2032 updates the 2014 policy basis for sectoral measures and adds 45 entities to the annex listing companies providing ‘support to the military-industrial base,’ including organisations outside Russia that contribute indirectly to such support (e.g., CNC machine tools, microelectronics, UAVs, or advanced technology). This move is reflected operationally in Council Regulation (EU) 2025/2033, which amends the 2014 sectoral framework and translates the new restrictions (export, services, transactions) into obligations. At the same time, the layer of individual listings is being expanded: Council Decision (CFSP) 2025/2036 updates the 2014 Decision underpinning the designations, and the Council announces 69 new additions to the package as a whole (individuals and entities), with a particular focus on actors involved in the deportation and assimilation of Ukrainian minors and on crypto platforms and assets associated with the Russian state.
The designation entails the freezing of funds and assets in the Union and a prohibition on making funds or economic resources available to the listed person or entity, directly or indirectly, and Council Regulation (EU) 2025/2037 reinforces and harmonises the definitions of ‘ownership and control’ in the 2014 regime: registered ownership is not sufficient; voting rights, shareholders’ agreements, the ability to appoint and dismiss directors, decisive financing, binding instructions or mirror vehicles created after a designation also count. In practice, if a transaction actually benefits a listed entity (even through a subsidiary, a front man or a chain of companies in third countries), it must be blocked. This conceptual adjustment in Regulation (EU) 2025/2037 is key for business groups; if a subsidiary is owned or controlled by a listed entity, the risk of being treated ‘as listed’ is high, even if the subsidiary is not nominally listed in the annex. Hence the need to map corporate structure, voting agreements, financiers, key individuals and revenue streams before concluding whether there is real independence.
Operationally, it is advisable to tighten the screening of counterparties, beneficial owners and effective beneficiaries (including spelling variations and transliterations), map ownership chains to the ultimate person/entity, and document voting agreements, options, guarantees and other indications of control.
Adjust contracts and policies with penalty clauses (suspension/termination, certifications, audit rights) and establish an orderly termination procedure when there is exposure: notification, suspension, liquidation permitted by assessed derogations, and evidentiary filing. If the relationship needs to continue for legitimate reasons (basic expenses, reasonable legal fees, humanitarian or settlement of pre-existing contracts within time windows), apply for a licence from the competent authority and prove that it does not generate profit for listed entities. This evidentiary standard should also cover exposure in third countries. Regulation (EU) 2025/2033 enables action against non-European banks, payment gateways and crypto providers when they facilitate circumvention or provide services to listed entities, so correspondents and gateways must be required to have equivalent controls, traceability of settlement routes and updated filters – and access to digital assets designated by the Council must be cut off.
- Key dates and transitory provisions of Package No. 19: phased end of LNG and associated services, phased cut-off with special economic zones, expiry deadlines for payments/banking/crypto from third countries and immediate ban by listed ports and locks; strict licences only for settlements and assessed cases
Firstly, with regard to liquefied natural gas of Russian origin, the general ban on purchasing, importing or transferring it comes into force on 25 April 2026. For contracts of more than one year signed before 17 June 2025, the ban applies from 1 January 2027, provided that no substantive changes have been made (only technical or downward adjustments in price and volume are tolerated). The ban also covers services that enable the operation (financing, insurance, brokerage, technical assistance).
Secondly, with regard to relations with special economic zones in Russia, since the entry into force of the regulations, no new contracts may be signed and no exposures may be increased. From 25 January 2026, it will also be prohibited to maintain existing holdings, joint ventures, branches or other contracts with entities based in these zones or with companies that control them or are controlled by them.
Thirdly, with regard to payments, banking and crypto assets in third countries, staggered cut-off dates are set to terminate pre-existing contracts with banks, payment gateways and crypto providers located outside the Union when they facilitate circumvention or provide services to listed entities.
Finally, third-country ports and locks: when a port or lock is added to the annex, all operations and services linked to it are prohibited from the effective date indicated for that entry, with the sole exceptions provided for closures already in progress.
- Belarus regime in parallel with Package 19. Update of listings and material adjustments to close loopholes in payments, logistics and distribution, under the architecture of Regulation (EU) 2012/642/CFSP and 765/2006
On the same day that the European Union adopted the 19th package on Russia, it reinforced its own regime on Belarus with three coordinated acts updating lists and adjusting the material scope of the restrictions: Implementing Decision (CFSP) 2025/2038, which adds new persons and entities to Decision 2012/642/CFSP; Implementing Regulation (EU) 2025/2039, which reflects these additions in Regulation (EC) 765/2006 for direct application; and Decision (CFSP) 2025/2040, which substantially amends 2012/642/CFSP by extending the goods, services and software affected, introducing prior authorisations, exemptions and transitional periods. This parallel move aims to close loopholes through Belarusian operators, payment brokers or logistics chains that could serve as a ‘bridge’ to the measures imposed on Russia.
The updated framework adds individuals and companies relevant to Belarus’ military-industrial and technological efforts. For screening purposes, it is worth mentioning representative examples such as executives and conglomerates in the electronic and industrial ecosystem (e.g., Ilya Ikan and Yuri Predko; JSC Holography Industry, ICT Horizont and Horizont Holding), included in Implementing Decision (CFSP) 2025/2038 and Implementing Regulation (EU) 2025/2039. These inclusions immediately trigger the freezing of funds and the prohibition on making funds or economic resources available to them, including indirectly through intermediary structures, subsidiaries or successor vehicles.
With regard to payments, Decision (CFSP) 2025/2040 strengthens the scope by prohibiting the provision of crypto-asset services, the issuance of payment instruments, the acquisition and initiation of payments, and the issuance of electronic money to nationals and residents of Belarus and entities established in that country, with limited exemptions and case-by-case licences. The decision itself clarifies that the initiator or acquirer is not required to verify nationality in each transaction, with the primary responsibility falling on the account management provider; in any case, the settlement route must be documented and kept traceable. If any part of the circuit passes through a listed Belarusian financial institution or a foreign correspondent providing services to listed entities, the transaction must be blocked under Regulation (EC) 765/2006 in accordance with the operational inclusions of Implementing Regulation (EU) 2025/2039 derived from Implementing Decision (CFSP) 2025/2038.
In logistics and insurance, transhipments, storage, terminals and operators linked to listed persons or entities trigger the prohibition on ‘making available’ through insurance, reinsurance, brokerage, assistance or expert services. The specific additions to Implementing Decision (CFSP) 2025/2038 and its implementation in Implementing Regulation (EU) 2025/2039 intensify logistics screening. This particularly affects ¡door-to-door’ coverage and floating policies: brokers must verify ownership and control of terminals and operators, and retain technical evidence (contracts, reservations and AIS tracks) when there is risk.
In components, spare parts and distribution networks, the Council is strengthening control over distributors based in third countries that are owned or controlled by Belarusian entities, or that act as successor vehicles following a designation: even if the commercial destination or intermediary is Russia, such intermediation ‘contaminates’ the operation and makes it contrary to the regime.
In services and software, as of 25 November 2025, according to Decision (CFSP) 2025/2040, commercial space services (Earth observation and satellite navigation), artificial intelligence services (access to models and platforms for training, tuning and inference), high-performance computing services, including graphics-accelerated computing and quantum computing. Along with these services, technical assistance, brokering, financing and the transfer of associated intellectual property or trade secrets are also prohibited. Certain software for financial-banking, business management or industrial design and manufacturing use is now included, with strictly limited exceptions and licences. For any other service to the Belarusian government not already prohibited, a system of prior authorisation by the competent authority is introduced on a case-by-case basis.
The transitional periods defined in Decision (CFSP) 2025/2040 allow for orderly exits without prolonging business. There are specific windows for combined nomenclature codes affecting industrial goods and construction materials; start dates are set for new services that are prohibited or subject to authorisation (generally from 25 November 2025) and exemptions are provided for basic needs, reasonable legal assistance, humanitarian purposes, maintenance of frozen funds and compliance with court rulings, always subject to a licence and documentary evidence of no direct or indirect benefit to designated persons. In payments and crypto assets, in addition to exemptions, settlement routes, beneficial ownership and traceability must be documented; in logistics and insurance, penalty clauses with the right of immediate suspension or termination and obligations of cooperation and auditing of subcontractors are recommended.
The operational message is clear: treat Belarus as an autonomous regime that operates in parallel to Russia and can block payment, logistics, insurance or technology supply operations on its own. To mitigate risks, it is advisable to institutionalise the ‘double gate’ rule in the screening of counterparties and routes; maintain ownership and control matrices that reach beneficial owners and governance agreements; and keep a complete evidence file for each decision (list queries in accordance with Implementing Decision (CFSP) 2025/2038 and Implementing Regulation 2025/2039, banking routes, contracts, policies, communications and technical evidence), applying the new material perimeters, authorisations and exemptions contained in Decision (CFSP) 2025/2040.
With the collaboration of José Luis Iriarte, Professor of Private International Law at the Universidad Pública de Navarra.
******
More information:
Lupicinio International Law Firm
C/ Villanueva 29
28001 Madrid
P: +34 91 436 00 90
