On the following day, 23 October 2025, the European Union (“EU”) announced the adoption of its 19th sanctions package and published the legal acts formalising it, including:
- Council Regulation (EU) 2025/2033 amending Regulation (EU) No. 833/2014 (“Regulation No. 2033” and “Regulation No. 833,” respectively); and
- Council Implementing Regulation (EU) 2025/2035 implementing Regulation (EU) No. 269/2014 (“Regulation No. 269”); and
- Council Regulation (EU) 2025/2037 amending Regulation No. 269.
New EU blocking sanctions
The list of EU blocking sanctions was expanded to include restrictions on 22 individuals and 42 legal entities (including from China, the UAE, Kyrgyzstan, the UK, and the US), including:- PJSC Polyus, a Russian gold mining company, one of the largest in the world and the largest in Russia by gold production volume;
- JSC AvtoVAZ, a Russian car manufacturing company, the largest car manufacturer in Russia;
- JSC Krasmash, one of the largest enterprises in the Russia’s defence industry;
- PJSC Far Eastern Shipping Company (the parent company of the FESCO Group), one of Russia’s largest shipping companies;
- LLC Shipbuilding Complex Zvezda, a Russian shipbuilding and ship repair company;
- JSC Signal, a large Russian chemical engineering company;
- Evraz plc (UK), the parent company of the EVRAZ Group, one of the largest steel producers in the world;
- Litasco Middle East DMCC (UAE), a subsidiary of PJSC Lukoil;
- Liaoyang Petrochemical Company (China), an oil refinery, one of the leading refineries in China for Russian-sourced crude oil;
- Grinex (Kyrgyzstan), a cryptocurrency exchange and the main trading platform for the A7A5 stablecoin; and
- top managers of Russian companies (in particular, A.A. Belyaev, General Director of JSC SEGZ; M.Y. Sokolov, President of JSC AvtoVAZ; R.V. Titkov, General Director of OJSC Dalpribor, and A.V. Nizkous, General Director of PJSC Energia).
- EU PersonsThe EU sanctions measures are binding:
- within the EU territory;
- on EU nationals regardless of their location;
- on EU-registered legal entities and their branches and representative offices;
- on any persons within the EU territory, regardless of their nationality; and
- on board any aircraft or vessel under the jurisdiction of an EU Member State.
- EU Persons are prohibited from directly or indirectly making funds and economic resources available to or for the benefit of sanctioned persons.
Definition of “ownership” and “control” notions
EU blocking sanctions apply not only to a sanctioned person but also to persons they “own” or “control.”Previously, the criteria to be taken into account when assessing whether a legal person is owned or controlled by another natural or legal person were set out, in particular, in:
- Council Regulation (EC) No. 2580/2001 of 27 December 2001 on specific restrictive measures directed against certain persons and entities with a view to combating terrorism; ande
- EU Best Practices for the effective implementation of restrictive measures, which, however, are not binding and only provide interpretative guidance.
“Owning” a legal person, entity or body means being in possession of 50% or more of the proprietary rights of a legal person, entity or body, or having a majority interest therein.
The notion of “controlling” is defined through the following non-exhaustive list of criteria that may indicate the existence of control over a legal person by a natural or legal person:
- having the right or exercising the power to appoint or remove a majority of the members of the administrative, management or supervisory body of a legal person, entity or body;
- having appointed solely as a result of the exercise of one’s voting rights a majority of the members of the administrative, management or supervisory bodies of a legal person, entity or body who have held office during the present and previous financial year;
- controlling alone, pursuant to an agreement with other shareholders in or members of a legal person, entity or body, a majority of shareholders or members voting rights in that legal person, entity or body;
- having the right to exercise a dominant influence over a legal person, entity or body, pursuant to an agreement entered into with that legal person, entity or body or to a provision in its memorandum or articles of association, where the law governing that legal person, entity or body permits its being subject to such agreement or provision;
- having the power to, de facto, exercise the right to exercise a dominant influence, without being the holder of that right (including by means of a front company);
- having the right to use all or part of the assets of a legal person, entity or body;
- managing the business of a legal person, entity or body on a unified basis, while publishing consolidated accounts; or
- sharing jointly and severally the financial liabilities of a legal person, entity or body, or guaranteeing them.
New ground for imposing EU blocking sanctions
A new ground for imposing blocking sanctions was added to Regulation No. 269 in point (n) of Article 3(1). Sanctions can now be imposed against “natural or legal persons, entities or bodies responsible for, supporting or implementing actions or policies contributing to the deportation, forced transfer, forced assimilation, including indoctrination, or militarised education of Ukrainian minors.”As at the date of this legal update, this ground has not yet been used to impose sanctions.
EU sanctions against foreign banks using the SPFS and similar systems
Within the framework of the 14th sanctions package, the EU introduced a prohibition on the use of the System for the Transfer of Financial Messages (“SPFS”) and similar Russian systems, and also prohibited EU Persons from conducting transactions with persons specified in Annex XLIV to Regulation No. 833.The criterion for being included in such Annex was the use of the SPFS and similar systems.
As of 25 January 2026, EU Persons operating outside Russia will also be prohibited from connecting to any systems of the Central Bank of Russia or to systems provided by any other Russian legal person, entity or body that include a financial messaging functionality, including the Faster Payments System (SBP) and MIR. Furthermore, the use of such systems by legal persons established outside Russia may now also be grounds for their inclusion in Annex XLIV to Regulation No. 833.
As of 2 December 2025, Annex XLIV will include four new banks: CJSC Alfa-Bank (Belarus), OJSC Sber Bank (Belarus), CJSC VTB Bank (Belarus) and Subsidiary JSC VTB Bank (Kazakhstan). Nevertheless, the abovementioned prohibition will not apply until 25 April 2026 to the execution of contracts concluded with such banks before 24 October 2025, or of ancillary contracts necessary for the execution of such contracts.
Other EU sanctions against financial institutions
As we previously reported, as part of the 18th EU sanctions package, the prohibition established by Article 5h of Regulation No. 833 was significantly expanded: now, a complete prohibition on any transactions with entities listed in Annex XIV and their Russian subsidiaries applies. Amendments to Annex XIV will enter into force as of 12 November 2025, and will include five new Russian financial institutions: NPO Istina (JSC), LLC Zemsky Bank, JSCB Absolut Bank (PJSC), PJSC MTS Bank, and JSC Alfa-Bank.In addition, as part of the 19th sanctions package, Article 5ad of Regulation No. 833 was expanded. Annex XLV now contains three parts that may include legal persons, entities and bodies established outside of the EU that:
- are credit or financial institutions or entities providing crypto-asset services or payment services that (i) provide such services to legal persons, entities and bodies listed in Annexes of Regulations No. 833 and No. 269 or (ii) are otherwise significantly frustrating the purpose of the prohibitions in those Regulations (Part A of Annex XLV);
- are credit or financial institutions or entities providing crypto-asset services or payment services that support Russia’s actions, including by processing transactions or providing export financing for trade operations that frustrate the purpose of Regulation No. 833 (Part B of Annex XLV); and
- are not credit or financial institutions or entities providing crypto-asset services or payment services and are significantly frustrating the purpose of the prohibitions set out in Articles 3m, 3n and 3s of Regulation No. 833 that relate to the Russian oil price cap, “shadow fleet” vessels etc. (Part C of Annex XLV).
- as of 12 November 2025 — CJSC JSCB Tolubay (Kyrgyzstan), OJSC Eurasian Savings Bank (Kyrgyzstan), CJSC Dushanbe City Bank (Tajikistan), CJSC Spitamen Bank (Tajikistan), OJSC Commerzbank of Tajikistan (Tajikistan), Blackford Corporation Limited (Hong Kong), and Fuel and Oil Dynamics FZE (UAE); and
- as of 25 November 2025 — Payeer cryptocurrency platform.
Other amendments to Regulation No. 833
Regulation No. 2033 introduced a number of other amendments to provisions of Regulation No. 833, in particular:- as of 25 April 2026, EU Persons are prohibited from purchasing, importing or transferring, directly or indirectly, liquified natural gas (“LNG”), if it originates in Russia or is exported from Russia. Furthermore, EU Persons are also prohibited from providing, directly or indirectly, technical assistance, brokering services, financing or financial assistance or any other services related to the abovementioned prohibition. However, if the purchase, import or transfer is executed under a contract, the duration of which exceeds one year and which was concluded before 17 June 2025 and where that contract was not amended thereafter, the prohibition enters into force as of 1 January 2027;
- 117 vessels were added to the list of vessels of the so-called “shadow fleet” of Russia in Annex XLII, which are subject to prohibitions on access to ports and on the provision of a wide range of services related to maritime transportation. In addition, the 19th package prohibits EU Persons from reinsuring the specified vessels. This list currently contains 557 vessels;
- 45 new legal persons from Russia, China, India and Thailand were added to Annex IVThis Annex lists individuals, legal entities, organisations or bodies that are military end users, part of the Russian military-industrial complex, have commercial or other ties with or otherwise support the Russian defence and security sector.. EU Persons are prohibited from directly or indirectly selling, supplying, transferring or exporting to these persons goods and technology, including the dual-use goods and technology listed in Annex VIIThis Annex lists goods and technology that could contribute to Russia’s military and technological strengthening or to the development of Russia’s defence and security sector.;
- Article 5ah was added, which prohibits EU Persons from making new investments in Russian special economic, innovation or preferential zones (“SEZ”), as well as entering into legal relations with their residents (in particular, acquiring new or expanding existing participation in legal entities registered as SEZ residents; creating new joint ventures, branches, or representative offices in SEZs, etc.), and, as of 26 January 2025, from maintaining investments previously made in certain SEZs and fulfilling contracts previously concluded with residents of certain SEZs. The list of SEZs is set out in Annex LII to Regulation No. 833 and includes, among others, the Skolkovo Innovation Centre, Technopolis Moscow, Innopolis, Alabuga, and the Free Port of Vladivostok;
- new Article 5ba was added that prohibits EU Persons to engage, directly or indirectly, in any transaction involving the crypto-assets listed in Annex LIII to Regulation No. 833. As of 25 November 2025, this Annex will include the A7A5 stablecoin;
- the prohibition on the provision of services by EU Persons to the Russian Government and Russian legal persons (Article 5n) was expanded to also include (i) integrated engineering, urban planning, engineering-related scientific and technical consulting or technical testing and analysis services; (ii) commercial space-based services consisting of Earth observation or satellite navigation; (iii) artificial intelligence services consisting of access to models or to platforms for their training, fine tuning and inference; (iv) high-performance computing, including access to graphic processing unit-accelerated computing, or quantum computing services. Furthermore, Article 5n now also prohibits EU Persons to provide services directly related to tourism activities in Russia;
- new export restrictions were established and new exemptions were added in relation to certain export and import restrictions; and
- definitions of such notions as “crypto-asset,” “payment services” and “services directly related to tourism activities” were added.
Expansion of the US sanctions list
OFAC expanded the list of persons subject to US blocking sanctions (“SDNs”) to include Russia’s largest oil companies, PJSC Rosneft Oil Company and PJSC LUKOIL, as well as several dozen of their subsidiaries, the full list of which is available in an official press release.As we previously reported, the UK also imposed blocking sanctions on PJSC Rosneft Oil Company and PJSC LUKOIL on 15 October 2025.
As a reminder, the US blocking sanctions have the following consequences:
- all property of SDNs that are in the US or in the possession or control of US Persons are to be blocked; and
- US PersonsUS sanctions are applied to:
- US citizens or lawful permanent residents, regardless of their physical location;
- entities organised under the laws of the United States or any jurisdiction within the United States (including their branches and representative offices outside the US); and
- other persons in the United States
The abovementioned restrictive measures also target legal persons that are not included on the SDN List, but which are 50% or more owned, directly or indirectly, by one or more SDNs.
General Licenses issued by OFAC
OFAC issued four General Licenses authorising certain transactions in connection with the new sanctions restrictions:- General License No. 124A authorises all transactions involving PJSC Rosneft Oil Company, PJSC LUKOIL and/or their subsidiaries that are related to the Caspian Pipeline Consortium or Tengizchevroil projects;
- General License No. 126 authorises until 21 November 2025 all transactions that are ordinarily incident and necessary to the wind down of transactions involving PJSC Rosneft Oil Company, PJSC LUKOIL and/or their subsidiaries provided that any payment to a blocked person is made into a blocked account;
- General License No. 127 authorises until 21 November 2025 all transactions that are ordinarily incident and necessary to the divestment or transfer, or the facilitation of the divestment or transfer, of debt or equity issued or guaranteed by PJSC Rosneft Oil Company, PJSC LUKOIL and/or their subsidiaries, to non-US persons; and
- General License No. 128 authorises until 21 November 2025 all transactions that are ordinarily incident and necessary to the purchase of goods and services from, or the maintenance, operation, or wind down of PJSC LUKOIL retail service stations located outside of the Russian Federation, provided that any payment, directly or indirectly, to a blocked person — other than blocked PJSC LUKOIL retail service stations — is made into a blocked account.
