The 19th package of EU-Russia sanctions

The 19th EU sanctions package in response to Russian aggression and Russia’s war in Ukraine has been negotiated over a long period of time. The negotiations, particularly with Slovakia, focused on considerations of the impact on the global energy sector. Russia is a major supplier to the global oil and natural gas markets, and the tightening of the supply market had raised concerns about the impact on price developments in these markets.

On October 23, 2025, the European Union agreed on EU Regulations 2025/2033 and 2025/2041 amending EU Regulation No. 833/2014, which will enter into force on October 24, 2027. With regard to Belarus, Decision 2012/642 has been extended again by Decision 2025/2040. EU Regulation 2025/2041 contains the corresponding amendments to EU Regulation 765/2006.

It comes as no surprise that measures affecting the energy sector are a key area of the extension. We will briefly explain the most important regulations in this regard and then highlight five other key areas in line with our focus. One of these key areas also affects measures in the maritime economy sector.

1. Reduction of Russian revenues from liquefied natural gas

In our opinion, the most far-reaching measure of the 19th sanctions package in economic terms can be found in a revised Article 3ra. According to paragraph 1, from April 25, 2026, it will be prohibited to purchase, import, or transport Russian liquefied natural gas (CN code 2711 11 00) directly or indirectly.

Paragraph 2 provides for an exemption for existing contracts concluded before June 17, 2025, with a term of more than one year; the ban on such contracts will not take effect until January 1, 2027.

This provision is likely to please the US government, among others, as it is expected to lead to an increase in revenues for LNG from the US.

However, when adopting the measure, the EU has already considered how to counter a possible increase in the price of liquefied natural gas. The focus is on diversifying energy sources, closely monitoring storage stocks, and identifying potential savings.

Previous exemptions for transactions with Rosneft and Gazprom Neft have been removed. This also applies to oil transactions.

It is noteworthy that, continuing what was already started in the 18th package of sanctions, the sanctions cover refineries and traders outside Russia and prohibit transactions with them. The 19th package lists Chinese refineries, Liaoyang Petrochemical Company and Shandong Yulong Petrochemical Co., Ltd, as well as oil trading companies, the Hong Kong-based Chinaoil (Hong Kong) Corporation Limited and the LLC Yadran-Group based in the Republic of Tatarstan.

This has led to a continuity in that the scope of the sanctions has been extended to companies that are based in other countries but enable and profit from Russian energy transactions.

2. Tightening of sanctions in the maritime economy

In this context, it is also important to remember the operation of the shadow fleet, which is also being reviewed again, and the 19th package of sanctions has led to the listing of 117 additional ships. This brings the total number of ships listed to 557.

The mere listing of these ships is not known to result in their banishment from the world’s oceans. The decisive factor is therefore how internationally applicable regulations can be enforced against these ships. Considerations are being made at both EU level and other diplomatic levels, but these have not yet led to an effective enforcement mechanism that would effectively contain the dangers posed by the shadow fleet.

A key challenge in connection with the shadow fleet is flag-related activities that lead to real or apparent registrations of ships that can be attributed to the shadow fleet. The 19th sanctions package addresses this challenge and includes, for example, the Dallas, USA-based company Aruba Maritime Administration & Offshore Company Registry, the Beverly Hills-based company MSTA-International Maritime Registries & Regulatory Inc., which allegedly operates on behalf of Sint Maarten, and the Essex, UK-based company International Maritime Ship Registry, which allegedly operates on behalf of Curaçao. These listings are all welcome but should not obscure the fact that Russia will not stop trying to profit from similar illegal activities.

Among the listings in the maritime sector, Far Eastern Shipping Company, alias FESCO, and Volgotanker, which are now listed, deserve special mention.

Litasco Middle East DMCC, a subsidiary of Lukoil based in Dubai, has been identified as an important vehicle for the expansion of the shadow fleet and is now also listed.

At the regulatory level, we believe two changes are particularly noteworthy. We can only provide a brief overview here without being able to comprehensively describe the far-reaching consequences at this point.

First, with regard to the shadow fleet, it is clarified that the ban on providing insurance for these ships also includes reinsurance; to this end, Article 3s contains a new version that explicitly mentions reinsurance.

We believe that a transaction and insurance ban on Russian tonnage, as set out in a revised Article 5u, is even more far-reaching than this regulation. This ban applies to both ships and aircraft, i.e. in particular airplanes. According to this, it is prohibited to sell, provide or sign a contract or agreement to sell ships or aircraft that were operated directly or indirectly by the Russian government or a legal entity, organization or institution established in Russia organization, or institution, in the five years following their sale or any type of agreement regarding their lease, to sell, provide, or sign or otherwise enter into a contract or agreement that results in a transfer or assignment of risks in connection with insurance coverage for such ships or aircraft.

This regulation significantly restricts the possibility of asset-related trading in ships and aircraft. It is therefore essential for both buyers of tonnage and insurers to be able to accurately trace the ownership history of each individual object prior to its inclusion in the portfolio with regard to the period specified in the regulation. It is recommended that the steps taken and results obtained be documented and kept on file.

We would also like to point out an extension of the ban on transactions with ports and locks, Article 5ae of EU Regulation 833/2014. The list of ports and locks affected by these transactions within Russia is still referred to as Annex XLVII Part A. What is new is that Part C of this Annex may in future also list ports and locks outside Russia. This sends a signal that Russia’s procurement industry is under observation not only on Russian territory but worldwide. It is advisable for players in the maritime industry to keep an eye on changes to the list in Part C and to be vigilant in this regard.

3. Access to dual-use goods

When it comes to the procurement industry, it is of course also important to consider the broader issue of dual-use goods. In this context, extensions to EU Regulation No. 269/2014 within the framework of EU Implementing Regulation 2025/2035 must be taken into account. Numerous Russian companies and companies in other countries, particularly in Asia, China, India, and Thailand, have been added to the list of companies subject to transaction bans because they have been proven to support the Russian arms industry. A similar case is the listing of the companies ICT Horizont and Horizont Holding in Belarus, in accordance with EU Implementing Regulations 2025/2038 and 2025/2039. Decision 2025/2040 on curbing trade relations with Belarus focuses on trade in goods that could contribute to the military and technological strengthening of Belarus.

4. Changes related to the finance sector

With regard to measures in the financial sector, the decision reflects the regulations that were also adopted with regard to Russia and the curbing of payment transactions by banks and crypto exchanges.

This includes making it more difficult in future to compensate for exclusion from the SWIFT payment system by using alternative services.

Therefore, legal entities, organizations, or institutions established in the Union and operating outside Russia are prohibited from using the System for Transfer of Financial Messages (SPFS) of the Central Bank of Russia or equivalent specialized messaging services for payment transactions and payment services established by the Central Bank of Russia from January 25, 2026, with systems of the Central Bank of Russia or with systems with a payment messaging function provided by another legal entity, organization, or institution established or registered under Russian law, including the System for Instant Payments (SBP) and Mir.

Various transition periods are specified for different systems; details are set out in Annex XLV of EU Regulation 833/2014.

Additional individual payment services and other banks have been listed in an amendment to EU Regulation 269/2014.

The amendment is anchored in EU Regulation 833/2014 in a new version of Article 5ad.

5. Restriction of circumvention transactions

Overall, the EU is taking a strict approach based on findings regarding circumvention practices. In addition to companies in Russia and Belarus, this also affects banks and other actors outside these countries – particularly in China, India, and Central Asia. Some of the listings explicitly refer to circumvention practices, as can be seen, for example, in the justification for the listing of Tianjin Xishanfusheng International Trading Co. LTD

6. Restriction of the freedom of movement of Russian diplomats within the EU

The 19th package of sanctions brings with it a change that may initially seem less significant in economic terms: restrictions on the freedom of movement of Russian diplomats. In future, they will have to register their travel within the EU before entering their destination country.

This part of the package of measures is certainly more of a regulation with political weight; it does not appear to weaken Russia’s economic power.

7. Outlook

The current debate on so-called reparations loans is likely to have more serious consequences, both economically and politically. Although Russia currently has no control over frozen assets, these assets are undoubtedly covered by property protection under international law. If these were already being used as so-called reparations loans to support Ukraine at this point in time, this would represent a significant step towards the necessary and foreseeable reparations payments by Russia to Ukraine, and another problem, namely the financing of support for Ukraine, would be virtually solved, as the assets in question are estimated to be worth around €200 billion. However, there is debate as to whether granting repayment to Russia in exchange for reparations payments by Russia is sufficient under international property protection law. To a certain extent, this could lead to a simple offsetting of amounts that Russia owes to Ukraine. In this context, it cannot be assumed that Russia will recognize Ukraine’s legitimate claims for reparations. In this respect, it is important to carefully examine the concerns expressed in particular by Belgium before the next EU summit. Belgium manages a large part of these assets in connection with the location of the clearing houses. Belgium emphasizes the risk that other countries could withdraw central bank funds from the eurozone if such a political signal is given with regard to Russian central bank funds. When answering the question of whether it makes sense to take this step, it could also be useful to consider the counter-question of whether it would be conceivable to simply transfer these frozen Russian assets back to Russia at the end of the war without Russia agreeing to meet Ukraine’s reparations claims. The decisive factor would have to be that the protection of property guaranteed under international law is ensured with regard to these funds. This is a highly complex issue. It is not apparent that the funds need to be protected against a decline in monetary value, for example in the context of inflation, or that they are worthy of protection. A mechanism for using these funds in the context of loans does not seem absolutely unthinkable. However, it must be required at least to specify clear rules on security concepts with regard to the loan amount. It seems understandable that the Belgian government does not accept that Belgium alone would be liable for this sum. Given Hungary’s well-known position on this issue, it is unlikely that a unanimous decision will be reached within the EU. Diplomatic discussions on this issue will not only be exciting to observe but also have far-reaching historical dimensions.

8. Comment

The 19th package of sanctions represents a further far-reaching intensification of sanctions measures, with a focus on limiting Russia’s military forces and reducing revenues from the oil and gas business. The maritime industry is once again particularly exposed, which must be seen in parallel with the importance of the shadow fleet for the Russian economy and the risks associated with it.

For players in the maritime industry, this means being particularly vigilant to ensure compliance with the sanctions regulations.

Geopolitical decisions will be of paramount importance for private players and their economic activities for the foreseeable future. Staying closely informed is more crucial than ever before in recent history.

Given the depth of detail in the regulations, it is advisable to seek legal advice if a need for consultation is identified; overview publications cannot replace advice in individual cases. This also applies to this article.

Do you have any further questions on these or other topics? Our experts will be happy to support you with solutions tailored to your individual needs.