Latest information on the 19th package of sanctions against Russia and its impact on the financial industry

RegCORE Client Alert | Banking Union, Capital Markets Union + Savings and Investment Union, Digital Single Market

Brief overview

On 23 October 2025, the EU Member States adopted the 19th package of sanctions against Russia, which is intended to significantly increase pressure on the Russian war economy. This package of sanctions was published in the Official Journal of the European Union on 3 November 2025. The new package of sanctions consists of the following legal acts:

• three Council Regulations, specifically Regulations (EU) 2025/2033, 2025/2037 and 2025/2041, 
• two Council implementing regulations, namely Regulations (EU) 2025/2035 and 2025/2039, 
• three Commission Delegated Regulations (EU) 2025/2150, 2025/2151, 2025/2152, 
• two Commission Implementing Regulations (EU) 2025/2146, 2025/2153, 
• three Council Decisions (CFSP) 2025/2032, 2025/2036, 2025/2040 and one Council Implementing Council Decision (CFSP) 2025/2038 (hereinafter referred to as the “19th sanctions package” or the “sanctions package”). 

The sanctions package includes measures in the energy sector, financial and trade policy measures, measures against the circumvention of sanctions and the expansion of sanctions lists. It is also directed against actors who enable or profit from Russia's war of aggression. The key points of the sanctions package are a complete ban on LNG imports, a ban on purchases and transfers, a ban on the provision of intermediary services or financial assistance in this context, significantly stricter measures against the so-called shadow fleet and new transaction bans in the banking sector; for the first time also against Russian payment infrastructures, stablecoins and offshore crypto exchanges. In line with previous practice, selected trade, finance and service-related regulations from the package have been incorporated into the Belarusian sanctions regime.

Key findings

The sanctions package amends Regulation (EU) 833/2014,Council Regulation (EU) No 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.Show Footnote which forms the core of the sanctions regime against Russia:

1.   Ban on imports of Russian liquefied natural gas (LNG):

Regulation (EU) 833/2014 is supplemented by Article 1(4) of Regulation (EU) 2025/2033 with a new Article 3ra, which provides a ban on imports of Russian LNG. Pursuant recital 10 of Regulation (EU) 2025/2033, the material scope of the ban covers, on the one hand, the direct or indirect purchase, import or transport of liquefied natural gas falling under CN code 2711 11 00, provided that it originates in Russia or is exported from Russia. The ban also extends to the provision or supply of direct or indirect technical assistance, brokering services, financing or financial assistance and other services related thereto.

Pursuant to Article 1 lit. (o) of Regulation (EU) 833/2014, the term “financing or financial assistance” means any action, irrespective of the particular means chosen, whereby the person, entity or body concerned, conditionally or unconditionally, disburses or commits to disburse its own funds or economic resources, including but not limited to grants, loans, guarantees, suretyships, bonds, letters of credit, supplier credits, buyer credits, import or export advances and all types of insurance and reinsurance, including export credit insurance; payment as well as terms and conditions of payment of the agreed price for a good or a service, made in line with normal business practice, do not constitute financing or financial assistance.

The new regulation will generally apply from 25 April 2026. For existing contracts that were concluded before 17 June 2025 and have remained essentially unchanged since then, the following transitional arrangement applies: Contracts with a term of more than one year may continue unchanged until 1 January 2027. Only adjustments that are limited to the following are permissible within the meaning of this transitional provision:

• lowering contracted quantities;
• lowering prices and fees;
• amending confidentiality clauses; 
• amending operational procedures, such as communication procedures;
• changes of addresses of contract parties; 
• transfers of contractual obligations between affiliated undertakings; 
• changes required by judicial or arbitration procedures or, for landlocked countries, changes between national delivery points. 

2.   Expansion of the sanctions lists:

• The sanctions list targeting the Russian shadow fleet in Annex XLII to Regulation (EU) 833/2014 has been expanded by 117 ships in Annex XII to Regulation (EU) 2025/2033. This means that a total of 557 ships are now subject to a ban on port access and the use of services.
• According to recital 4 of Regulation (EU) 2025/2033, Council Decision (CFSP) 2025/2032 adds 45 organisations to Annex IV of Council Decision 2014/512/CFSP.Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.Show Footnote This Annex lists legal persons, entities and bodies that support Russia's military-industrial complex in its war of aggression against Ukraine and are subject to stricter export restrictions on dual-use goods and technologies, as well as other goods and technologies.
• Under Implementing Regulation (EU) 2025/2035, Annex I to Regulation (EU) 269/2014Council Regulation (EU) No 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.Show Footnote is extended to include 69 persons and organisations. As a result, the assets of the persons and entities concerned are frozen in the EU and no funds or economic resources may be made available to them. In addition, travel bans will be imposed on individuals in/through all EU Member States.

3.   Banking:

• According to recital 23 of Council Decision (CFSP) 2025/2032, the EU is adding five more Russian credit/financial institutions to the list of transaction bans:
  o    NPO ‘Istina’ (JSC)
  o    LLC ‘Zemsky Bank’
  o    Commercial Bank Absolut Bank (PAO)
  o    PJSC ‘MTS Bank’
  o    ‘ALFA-BANK’ JSC.
• Relevant Russian subsidiaries of financial institutions from third countries are also included, provided they are functionally relevant to the Russian financial system or support payments that strengthen Russia's economy and industry. The addition serves to further restrict Russian payment and financing channels.

4.   Payment transactions:

• Article 1, No. 7 of Regulation (EU) No. 2025/2033 expands Article 5ac of Regulation (EU) No. 833/2014 by introducing a prohibition that forbids EU companies operating outside Russia from connecting to the Russian financial messaging system SPFS or similar systems of the Russian Central Bank.
• From 25 January 2026, this prohibition will be extended to other payment messaging systems operated by entities established under Russian law, explicitly including SBP and Mir. Recital 15 of CFSP 2025/2032 clarifies that the existing transaction ban is thus deliberately extended to these Russian systems.
• Four financial institutions in Belarus and Kazakhstan that use the Financial Messaging System of the Bank of Russia SPFS have been added to the sanctions list.
• These four financial institutions are: 
  o    CJSC Alfa-Bank
  o    Sber Bank OJSC
  o    VTB Bank (Belarus)
  o    VTB Bank JSC (Kazakhstan).

5.   Cryptocurrencies and exchanges:

Furthermore, pursuant to Regulation (EU) No 833/2014, sanctions are imposed on the developer of a widely used stablecoin pegged to the rouble, “A7A5”, the Kyrgyz issuer of this stablecoin (LLC Old Vector) and a large trading platform associated with it (Grinex). These measures prohibit the use of this cryptocurrency for the first time. By extending sanctions to the use of stablecoins and offshore exchanges, the EU aims to close loopholes and strengthen the integrity of its financial sanctions framework.

6.   Crypto services:

Furthermore, according to recital 21 of Council Decision (CFSP) 2025/2032, EU operators are prohibited from providing crypto services and certain FinTech services (provision of payment services under Directive (EU) 2015/2366 and provision of e-money) that enable Russia to develop its own financial infrastructure and potentially circumvent sanctions.

7.   Transactions:

• There is also a transaction ban on five banks from third countries in Central Asia that support the Russian war economy.
• These five banks are: 
  o    NPO ‘Istina’ (JSC)
  o    LLC ‘Zemsky Bank’
  o    Commercial Bank Absolut Bank (PAO)
  o    PJSC ‘MTS Bank’
  o     ‘ALFA-BANK’ JSC.
• Market participants from the EU are prohibited from conducting business with any of these banks.

8.   Measures against Russian Special Economic Zones (SEZs):

• According to Council Decision (CFSP) 2025/2032, Russian special economic zones are intended to attract foreign investment. These play a crucial role in promoting economic growth and infrastructure development.
• To make it clear that EU companies should stay away from these zones, the package proposes, under recital 19 of Regulation 2025/2033, a ban on entering into new contracts with entities established in certain Russian SEZs.
• In addition, the ban will also apply to existing contracts for two of these SEZs: Alabuga and Technopolis Moscow. This decision, which essentially forces divestment, is a response to the fact that the activities of these two zones are primarily intended to contribute to the war effort.

9.   Prohibition on reinsurance:

•  In view of recital 25 of Regulation (EU) No 2025/2033, Council Decision (CFSP) 2025/2032 prohibits the provision of reinsurance for used Russian aircraft or ships within five years of their sale or lease, provided that these transactions take place after the entry into force of the Regulation.
• In addition, recitals 11 and 25 set out further measures. These include additional listings of vessels and a new listing criterion that allows for the inclusion of persons or entities involved in the deportation, forcible transfer, forced assimilation or militarised training of Ukrainian minors. EU economic operators remain prohibited from providing insurance or reinsurance services to listed vessels.
• The aim is to reduce Russia's ability to generate revenue from obsolete assets.

Key considerations for practice

The 19th sanctions package goes beyond a mere extension of existing restrictions. The comprehensive ban on LNG from Russia requires adjustments along the entire value and financing chain. For market participants in the energy and transport sectors, ensuring seamless contractual partner compliance will become an essential management tool. It may become necessary to expand KYC checks with the aim of obtaining reliable proof of origin: traceable, audit-proof evidence of geographical and economic origin as well as the integrity of transport and payment routes will be required. In practice, this could result in standardised certificates of origin, technical tracking solutions and documented due diligence path dependencies (chain of custody).

In supply and transport contracts, the sanctions regime will force a significant consolidation of assurances and sanction clauses. These include assurances regarding origin and non-sanction proximity, inspection and audit rights along the supply chain, and extended information and cooperation obligations. Effectively designed contractual penalties with clear trigger mechanisms and rules of evidence are also conceivable. In addition, termination and suspension rights in cases of suspicion, escrow mechanisms for payments pending verification, and graduated remedial measures for compliance violations are conceivable. The system and instruments of the Supply Chain Due Diligence Act could be used for this purpose: risk analysis, remedial measures, complaint mechanisms and documentation obligations offer an established framework for translating sanction-related origin and integrity requirements into the contract and process landscape in an operational manner.

The implications for credit institutions and financial service providers are also significant. The ban on providing any financial assistance in connection with sanctioned LNG covers not only traditional loans, but also guarantees, sureties, (reverse) factoring, payment deferrals and indirect forms of financing. Institutions may therefore need to develop their sanctions and embargo checks from a purely transaction-based approach to a comprehensive control framework covering all products and counterparties. This means that, as part of sanctions and embargo checks, it will no longer be sufficient to examine individual business and annual financial statements; instead, the partners involved and the background to the transactions will need to be clarified. More precise negative definitions and exclusion lists, improved origin and purpose tests in credit and trade finance practice, and robust contractual mechanisms for information rights, audit rights and immediate termination rights in the event of sanctions violations are required. As part of internal governance, it will be necessary to ensure the integration of clear escalation paths, sanctions compliance, credit risk management and the legal department, regular training and regulatory-compliant documentation of demarcation decisions.

Companies that establish transparent origin processes at an early stage, expand their KYC frameworks to include sanctions-specific origin controls, and implement contractually binding protection through assurances, audit and inspection rights, and contractual penalties not only minimise legal and reputational risks, but also ensure their ability to act in an increasingly restrictive market environment. For financiers, conservative interpretations of financial assistance prohibitions and consistent exclusion criteria currently offer the lowest risk. In the medium term, it is conceivable that market-wide standardised proofs of origin, sector-specific sanction clauses and harmonised verification processes along the supply chain will become common practice.

Outlook

With the 19th package, the EU is visibly shifting its sanctions policy towards structural revenue and infrastructure blockades, particularly in the energy and financial sectors. The explicit addressing of stablecoins and offshore exchanges points to closer integration between financial markets, technologies and enforcement instruments. In the short to medium term, further list adjustments and more precise guidelines are to be expected, including increased cooperation with flag states and enhanced port and insurance supervision. Companies should make consistent use of the transitional and exemption provisions, while at the same time focusing early on structural decoupling, supply chain diversification and more resilient financial and data architectures.

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