On 23 October 2025, the European Union adopted its 19th package of sanctions, representing the broadest set of restrictive measures to date impacting Russia’s economy. For businesses with cross-border operations, corporate or trust structures, and exposure to regulated sectors, understanding these developments is essential.

 

Key Provisions

Energy Sector Restrictions

• A complete ban on imports of Russian liquefied natural gas (LNG). For short-term contracts, the prohibition enters into effect within six months; for long-term contracts concluded before 17 June 2025 that haven’t been amended, the ban becomes effective as of 1 January 2027.
• Removal of remaining exemptions for major Russian oil and gas companies (notably Rosneft and Gazprom Neft), meaning no more import, direct or indirect, of oil/gas from these companies into the EU.
• Expansion of sanctions to the so-called “shadow fleet”: 117 additional vessels have been listed, facing port-access bans and service restrictions.

Financial and Crypto-Asset Controls

The package introduces targeted measures on financial institutions and cryptocurrency:

• Prohibition of the state-supported stablecoin A7A5, including its developer, Kyrgyz issuer, and platform operator.
• All EU transactions involving A7A5 are prohibited.
• Transaction bans apply to:

1. Eight banks and oil traders in Tajikistan, Kyrgyzstan, UAE, and Hong Kong.
2. Five Russian banks — Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank.
3. Four banks in Belarus and Kazakhstan involved in financial messaging or payment systems.

• EU operators are prohibited from engaging with Russia’s National Payment Card System (Mir) and the Fast Payments System (SBP).
• Economic relationships with entities operating in nine Russian special economic zones are restricted due to industrial and technological activities.

Trade, Export Control and Technology

• Forty-five new entities supporting industrial or military activities face stricter export restrictions, including dual-use and defence-related items.
• Expanded export bans cover electronic components, machinery, chemicals, metals, construction materials, and acyclic hydrocarbons.
• Russia’s largest gold producer has been listed, further restricting key revenue sources.

Services

• Services to Russian government entities now require prior authorization.
• Restrictions apply to AI, high-performance computing, and commercial space services to Russian entities, including state bodies.
• Tourism-related services in Russia are restricted, adding another layer to the EU’s comprehensive sanctions framework.

Measures Targeting Belarus

• Five new Belarusian listings aligned with Russian sanctions, covering military-industrial and technology sectors.
• Expanded prohibitions include crypto-related payment services and software applications for finance, AI, quantum computing, and commercial space services.

Compliance Challenges

The 19th sanctions package introduces significant complexity for cross-border operations, corporate/trust structures, financing, and trade. Companies must carefully assess exposure, review contracts, and ensure robust compliance frameworks to mitigate risk.

How Our Cyprus Law Firm Can Help

As a Cyprus-based law firm specializing in corporate, trust law and international advisory services, we assist clients with:

• Compliance & Risk Assessment: Identifying potential exposure across corporate and trust structures.
• Contract & Transaction Support: Reviewing, restructuring, or renegotiating agreements to ensure compliance.
• Due Diligence & Screening: Performing enhanced checks on counterparties, subsidiaries, or entities in special economic zones.
• Regulatory & Licensing Advice: Advising on export controls, licensing, and lawful operations.
• Corporate Governance & Structuring: Guidance on managing compliance risks or restructuring arrangements.
• Ongoing Monitoring: Keeping clients informed of new sanctions and regulatory developments.

Final Thoughts

The 19th EU sanctions package represents the broadest set of measures to date, affecting energy, finance, trade, technology, and services. For businesses with international operations or exposure to regulated sectors, compliance is essential.

At Antoniou Law Firm, we focus on helping clients stay alert to emerging risks and operational implications arising from these developments. From compliance audits and transactional reviews to due diligence and corporate-structuring support, we equip your organisation with the clarity needed to make well-informed decisions.

If you would like to discuss how these developments may affect your business, please reach out:

info@antonioulegal.com
+35725008600
https://antonioulegal.com