The new package of sanctions came into force on 24 October 2025. This time, the scope of the regulations relates in particular to three sectors
- Service sector: The service sector is also further restricted by the revised Article 5n, in particular to prevent the strengthening of Russia’s technological capabilities, by prohibiting the provision of certain commercial space-based services, AI services, high-performance computing and quantum computing services. Other engineering services are also further restricted, as are related scientific and technical consulting services: geological, geophysical and other scientific prospecting, subsurface investigation, surface investigation and cartographic work. There is also a comparable extension of prohibited services with regard to Belarus.
- Energy sector: Among other things, a complete ban on imports of Russian liquefied natural gas (LNG) from April 2026 onwards, in accordance with Article 3ra of Regulation (EU) 833/2014. For long-term contracts with a term of more than one year that were concluded before 17 June 2025, an exception applies and the ban will not take effect until 1 January 2027.
- Financial sector: Transaction bans for banks. This involves a ban on transactions with the Russian payment service providers MIR and Fast Payment System. This concerns the prohibition of transactions with the Russian payment service providers MIR and Fast Payment System. In addition, Russians/Belarusians and Russian/Belarusian companies may no longer be granted services in the cryptocurrency sector.
New to this package is a mechanism that restricts the freedom of movement of Russian diplomats in the EU. They must give prior notification of any travel to countries other than those in which they are accredited. These countries, in turn, may restrict the transit or entry of diplomats. Whether this is just a minor annoyance or actually serves to counter espionage remains to be seen.
Also important for companies: the list of goods in Annex XXIII has been significantly expanded. There are 45 additional organisations on the list of legal entities, organisations or institutions, but also changes to the lists of goods and an expansion to include raw materials.
Conclusion – What do you need to do now?
- Adjust internal processes, if necessary, and terminate existing import/export relationships
- Communication within the company – training on the contents of the 19th sanctions package, if necessary
- Goods and services control – list checks
