On 23 October 2025, the EU Council adopted its 19th sanctions package to intensify pressure on Russia’s war economy and close circumvention routes. Core measures include:
- Direct ban on Russian liquefied natural gas (LNG) imports and related assistance;
- Expansion of the “revenue-generating goods” ban to cover all acyclic hydrocarbons;
- Broader export controls on battlefield-critical items and industrial-capacity goods;
- New restrictions targeting Russian special economic, innovation and preferential zones by prohibiting EU participation, investment, financing, joint ventures and contracts with enterprises operating there.
Financial measures extend transaction bans to Russian payment and messaging systems (SPFS, Mir, SBP) and certain third-country intermediaries implicated in evasion, alongside tighter limits on crypto-asset services and e-money issuance. Maritime and circumvention rules are sharpened, including measures affecting designated vessels and third-country ports and locks linked to UAV/missile transfers or oil-price-cap evasion. With this package, the number of listed vessels in Russia’s shadow fleet reaches a total of 557.
The listings framework is reinforced with a new legal criterion covering responsibility for, support of, or implementation of policies contributing to the deportation, forced transfer/assimilation, or militarised education of Ukrainian minors.
This package adds 45 entities to the list of those providing direct or indirect support to Russia’s military industrial complex or engaged in sanctions circumvention. This includes 28 established in Russia and 17 in third countries. Furthermore, this sanctions package contains 69 additional listings subjected to asset freezes and the prohibition to make funds and economic resources available to them, and – in the case of individuals – also to travel bans.
The Council also tightened the Belarus framework to curb Russia-related circumvention by widening controls on military/dual-use and industrial goods, introducing new restrictions on software and high-tech services (including AI, quantum/HPC and commercial space-based services), adding limits on crypto/payment services and services to public bodies, and listing two individuals and three entities. Targeted humanitarian carve-outs ensure continued trade in medical, pharmaceutical, agricultural and food products and safeguard access to judicial and arbitration proceedings.
For assistance with setting up an affective Sanctions Monitoring Program, contact Shoulder Compliance on info@shoulder.mt
