23 October 2025
EC ¦ EU adopts 19th Package of Sanctions against Russia
EU’s 19th Sanctions Package Tightens the Noose on Russia’s Energy, Financial and Evasion Networks
The European Union’s 19th sanctions package, adopted on 23 October 2025, represents a major step up in tactical and structural pressure on Russia’s war economy. The measures notably combine an unprecedented energy embargo with targeted financial restrictions (including the first explicit crypto measures), expanded trade controls against the military‑industrial base, and strengthened anti‑circumvention tools that reach third‑country enablers. For financial crime practitioners, compliance officers and investigators, the package broadens the list of sanctioned counterparties, tightens transaction prohibitions, and expands mechanisms for identifying and disrupting opaque value chains such as the oil shadow fleet and offshore crypto conduits.
Energy: LNG ban, shadow fleet expansion and new service prohibitions
The headline energy move is a phase‑out of Russian liquefied natural gas (LNG) imports: long‑term contracts will be banned from 1 January 2027, and short‑term contracts within six months after the measures enter into force. The package also removes previous carve‑outs for Rosneft and Gazprom Neft by imposing a full transaction ban on these major companies (while preserving narrow exemptions for third‑country oil originating outside Russia and oil traded under the international price cap when destined for non‑EU markets).
Targeting the logistics that keep sanctioned crude flowing, the EU added 117 vessels to its shadow fleet list, bringing the total to 557 tankers now subject to port entry and service bans. Sanctions extend beyond ships to actors across the maritime value chain: shadow‑fleet enablers, maritime registries issuing false flags, and trading intermediaries in Hong Kong and the UAE are specifically sanctioned, while the port infrastructure ban can now be used against third‑country ports that materially support Russian oil movements. The package also prohibits certain energy‑related scientific and technical services — for example geological prospecting and mapping — further tightening service restrictions that facilitate upstream production and export.
Financial measures: banks, payment rails and the first direct crypto prohibitions
Financially, the package widens transaction bans and severs more access points. Five additional Russian banks have been added to the transaction ban, precluding EU entities from direct or indirect dealings. New restrictions target Russian payment systems, banning the use of the Mir card system and Russia’s fast payment system (SBP) for EU operators, and listing four financial institutions in Belarus and Kazakhstan that make use of Russia’s SPFS.
Critically for financial crime risk management, the EU for the first time imposes full sanctions on components of a sanctioned crypto ecosystem: the developer of a rouble‑backed stablecoin (named A7A5 in the package), its Kyrgyz issuer, and an associated major trading platform. The measures explicitly prohibit the use of that cryptocurrency and sanction a Paraguayan exchange that has been instrumental in sanction circumvention. EU operators are also banned from providing crypto services and certain fintech services that could help Russia build alternative financial rails. Separately, transaction bans target five third‑country banks in Central Asia that have been identified as enabling Russia’s war economy.
Trade and export controls: expanding dual‑use and upstream choke points
Export restrictions widen the scope of prohibited dual‑use and advanced technology transfers to Russia, including specific metals used in weapon systems and inputs for propellant production. The EU also added export bans on certain salts, ores, construction materials and rubber products — items with a combined 2024 export value to Russia of approximately EUR 155 million — and listed companies and individuals in the Russian military‑industrial complex and overseas suppliers in the UAE and China.
Anti‑circumvention and listings: more entities, new criteria
The package strengthens anti‑circumvention targeting by adding 45 entities involved in supporting the military‑industrial complex or evading sanctions (28 based in Russia and 17 in third countries including 12 in China/Hong Kong, 3 in India and 2 in Thailand). In total 69 additional listings impose asset freezes, prohibitions on making funds or economic resources available, and travel bans where applicable. Notably, the package introduces a new listing criterion focused on those responsible for the abduction, forced assimilation and militarized education of Ukrainian children, and lists 11 additional individuals tied to those abuses.
Services, special economic zones and diplomatic controls
The package also restricts services that facilitate advanced digital capabilities: certain space‑based services and AI services accessible within the EU are now banned to Russia, and a requirement for prior authorisation will be introduced for any non‑prohibited services provided to the Russian government. Measures targeting Russian special economic zones (SEZs) prohibit EU entities from entering new contracts with entities in specified SEZs and require divestment from two zones — Alabuga and Technopolis Moscow — that have been identified as contributing to the war effort. A prohibition on re‑insurance for vessels and aircraft owned by the Russian government or sanctioned persons applies for up to five years after sale to third countries. Finally, new rules increase oversight of Russian diplomats’ travel across EU territory as a counterintelligence measure.
Practical compliance implications and enforcement priorities
For compliance and investigations teams the package raises several immediate actions and enforcement priorities.
First, transaction screening and sanctions lists must be updated to reflect the newly listed banks, companies, vessels and individuals across jurisdictions, including the newly identified third‑country enablers in China, Hong Kong, UAE, Paraguay, Central Asia and elsewhere. Payment‑processing teams must block interactions with Mir and SBP where EU nexus exists and review any merchant or settlement routes that could route around those systems.
Second, crypto and fintech compliance programs must be revised: the explicit prohibition of a rouble‑backed stablecoin and associated platforms, plus the ban on EU providers supplying crypto services to pro‑Russian actors, means KYC/KYB, transaction monitoring, and de‑risking policies need immediate reassessment. Firms should consider enhanced transaction monitoring for stablecoins and peer‑to‑peer flows, sanctions‑screening for counterparties in Paraguay, Kyrgyzstan and other jurisdictions named in the package, and stricter onboarding controls for customers with connections to the listed entities.
Third, trade compliance must account for expanded dual‑use controls and new commodity bans. Export control teams should map supply chains for newly restricted items (metals, propellant precursors, salts, ores, construction materials, rubber articles) and apply enhanced due diligence for customers in the defence sector and entities from the listed third‑country suppliers.
Fourth, maritime and commodities compliance needs to reflect the enlarged shadow‑fleet list and the port infrastructure extension. Corporates involved in ship services, bunkering, insurance and port operations should update watchlists, blocklisted‑vessel procedures, and screening of ship managers and registries. The prohibition on re‑insurance creates ripple effects for insurers and brokers who must ensure no treaty or facultative re‑insurance reinstates cover in contravention of the prohibition.
Finally, stronger anti‑circumvention rules and new listing criteria require a more proactive investigative stance. Firms and enforcement agencies should prioritise intelligence‑led approaches to identify front companies, intermediaries and service providers that facilitate sanctions evasion, and expand cooperation with counterpart regulators and financial intelligence units in affected jurisdictions.
Outlook: widened reach, enforcement complexity, and persistent gaps
This package is notable for the breadth of sectors it covers and the explicit targeting of circumvention corridors — maritime registries, offshore trading companies, foreign refineries, and cryptocurrency platforms. It signals a sustained EU intent to close loopholes and to make third‑country enablers pay a higher cost. Enforcement complexity will rise: multinational compliance teams must coordinate rapid list updates across banking, payments, trade, maritime and crypto operations, and interpret new authorisation regimes.
Gaps and challenges remain.
Russia will seek new partners, develop alternative payment rails, and continue efforts to disguise ownership and origin through complex shipping, trading and crypto structures. Effective enforcement will therefore depend on co‑operation with partners outside the EU, real‑time intelligence sharing, strengthened beneficial‑ownership transparency, and targeted financial investigations that follow the money into and through third‑country nodes.
Conclusion
For investigators, compliance officers and policy practitioners, the 19th EU package is a material escalation: it closes several known loopholes, introduces novel sanctions on crypto instruments and service providers, and extends reach into third‑country facilitators. The package raises the bar for sanctions avoidance but also increases the operational demands on private‑sector compliance and public enforcement alike. Continuous update of screening systems, closing monitoring blind spots in crypto and maritime logistics, and stepped‑up international cooperation will be essential to translate these legal measures into effective disruption of the financial lifelines for Russia’s war effort.
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