Sanctions adopted following Russia’s military aggression against Ukraine.

MARILOU PAVLOU CHRISTODOULIDES LLC (MPC Legal)

ADVOCATES & LEGAL CONSULTANTS

ARTICLE ON 19th EU SANCTIONS PACKAGE

Sanctions adopted following Russia’s military aggression against Ukraine.

The European Union (EU) continues to adopt further packages of economic sanctions against Russia due to the continuance of its military aggression against Ukraine, the latest of which is summarised below. The relevant legal framework is EU Regulation 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine (“Regulation 269”) and EU Regulation 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine (“Regulation 833”) (hereinafter collectively referred to as the “EU Sanctions”).

Note: The position is constantly evolving. Additional sanctions may be introduced in the coming days, and these will be the subject of future articles.

This information is:

• of a general nature only and is not intended to address the specific circumstances of any particular individual or entity;
• not necessarily comprehensive, complete, or up to date;
• not professional or legal advice (if you need specific advice, you may consult us).

19th SANCTIONS PACKAGE

The 19th EU Sanctions package (“This Package”) was released on 23/10/2025 and was adopted by the European Union in response to Russia’s ongoing war against Ukraine.

The major amendments are as follows:

Article 5(ad) of EU Regulation 833/2014 is amended as follows:

(a)paragraph 1 is replaced by the following:

1. It shall be prohibited to directly or indirectly engage in any transaction with a legal person, entity or body established outside of the Union that:

• is a credit or financial institution or an entity providing crypto-asset services or payment services that provides such services to legal persons, entities and bodies listed in this Regulation or Regulation (EU) No 269/2014 or is otherwise significantly frustrating the purpose of the prohibitions in those Regulations, as listed in Part A of Annex XLV to this Regulation;
• is a credit or financial institution or an entity providing crypto-asset services or payment services that supports Russia’s war of aggression against Ukraine, including by processing transactions or providing export financing for trade operations that frustrate the purpose of this Regulation, as listed in Part B of Annex XLV to this Regulation;
• is not a credit or financial institution or an entity providing crypto-asset services or payment services and is significantly frustrating the purpose of the prohibitions set out in Articles 3m, 3n and 3s of this Regulation, as listed in Part C of Annex XLV to this Regulation.’

2.It shall be prohibited to engage, directly or indirectly, in any transaction with a legal person, entity or body established outside Russia as listed in Annex XLIV.

Annex XLIV shall include the legal persons, entities or bodies established outside Russia that use the SPFS of the Central Bank of Russia or equivalent specialised financial messaging services set up by the Central Bank of Russia or the Russian State, or any systems of the Central Bank of Russia and any systems provided by any other Russian entity that include a financial messaging functionality, including the Fast Payment System (SBP) and Mir.

3.The prohibition in paragraph 2 shall not apply until 25 April 2026 to the execution of contracts concluded before 24 October 2025 with the legal persons listed in Annex XLIV by Council Regulation (EU) 2025/2033, or of ancillary contracts necessary for the execution of such contracts.

4.The prohibition in paragraph 2 shall not apply to the reception of payments due by a legal person, entity or body listed in Annex XLIV by 24 October 2025 pursuant to contracts performed before 25 April 2026.;

Decision (CSFP) 2025/2032 regarding the 19th Sanctions package, expands the transaction ban that applies to legal persons, entities or bodies that are connecting to the system for transfer of financial messages (‘SPFS’) of the Central Bank of the Russian Federation (‘Central Bank of Russia’) or equivalent specialised financial messaging services set up by the Central Bank of Russia, to other payment services, such as the Russian National Payment Card System (in Russian, ‘Mir’) or the Fast Payments System (‘SBP’), set up by the Central Bank of Russia or by other Russian entities. It also adds exemptions for transactions that are necessary for the functioning of diplomatic and consular representations of the Union and of the Member States in third countries and for transactions made by nationals of a Member State who are residents of a third country, for transactions that are necessary for existing contracts and the reception of payments, and for Member States’ ethnic minorities in Russia.

Annex XLIV to Regulation (EU) No 833/2014 is replaced by the following:

‘ANNEX XLIV

List of legal persons, entities and bodies referred to in Article 5ac

Name of the legal person, entity or body       Entry into force

1. Bank BelVEB                                   25 February 2025
2. Belgazprombank                       25 February 2025
3. VTB Bank (PJSC) Shangai Branch 25 February 2025
4. CJSC Alfa-Bank (Belarus)           2 December 2025
5. OJSC Sber Bank (Belarus)           2 December 2025
6. VTB Bank (Belarus)                       2 December 2025
7. VTB Bank (Kazakhstan)           2 December 2025

In Part A of Annex XLV to Regulation (EU) No 833/2014, the following entities are added:

Name of the legal person, entity or body         Entry into force

‘Payeer                                                             25 November 2025

CJSB JSCB Tolubay                                       12 November 2025

OJSC Eurasian Savings Bank                        12 November 2025

CJSC Dushanbe City Bank                             12 November 2025

CJSC Spitamen Bank (Tajikistan)                   12 November 2025

OJSC Commerce Bank of Tajikistan              12 November 2025’.

In Part C of Annex XLV to Regulation (EU) No 833/2014, the following entities are added:

Name of the legal person, entity or body       Entry into force

‘Blackford Corporation Limited                       12 November 2025

Fuel and Oil Dynamics FZE                           12 November 2025

With regards to the other measures introduced by the 19th Sanctions Package a brief description for each sector is indicated below:

1. Energy

• ban on imports of Russian liquefied natural gas (LNG) into the EU, starting January 2027 for long-term contracts, and within six months for short-term contracts, and tightens the existing transaction ban on two major Russian state-owned oil producers (Rosneft and Gazprom Neft)
• the 19th package includes the listing of Litasco Middle East DMCC, Lukoil’s prominent shadow fleet enabler based in the United Arab Emirates
• An additional 117 vessels have been made subject to a port access ban and a ban on the provision of a broad range of services related to maritime transport, bringing the total number of designated vessels to 557 (19th package targets non-EU tankers – part of the shadow fleet circumventing the oil price cap mechanism

1. Financial

• Listing of stablecoin A7A5 (crypto-asset), following the evidenced Russia’s increasing use of crypto in circumventing sanctions
• eight banks and oil traders from Tajikistan, Kyrgyzstan, the UAE and Hong Kong that circumvent EU sanctions are subject to a transaction ban
• five additional Russian banks – Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank, and Alfa-Bank – are targeted using the same measure
• four banks from Belarus and Kazakhstan are also put under a transaction ban, due to their connections to Russian financial messaging and payment systems

1. Russian Diplomats

• When travelling across the Schengen area beyond their country of accreditation, Russian diplomats will be obliged to inform in advance the relevant EU member state. EU member states may impose an authorisation requirement on Russian diplomats for traveling to their territories, based on visas or residence permits issued by another state

1. Children

• EU is reinforcing accountability of those involved in activities of forced adoption of Ukranian children by listing 11 additional individuals

1. Military

• targeting businesspersons and entities forming part of the Russian military-industrial complex, and operators from UAE and China producing or supplying military and dual-use goods to Russia

1. Trade

• 45 new entities directly supporting Russia’s military and industrial complex by, inter alia, enabling the circumvention of export restrictions on computer numerical control (CNC) machine tools, microelectronics, unmanned aerial vehicles (UAVs) and other advanced technology items are subject to export restrictions

1. Services

• Prior authorization for provision of services to the Russian government is mandatory (e.g. offering of AI services, high-performance computing services and commercial space-based services to Russian entities, including the Russian government)
• This Package prohibits European operators from providing services directly related to tourism activities in Russia

Next Steps

MPC Legal monitors developments within the EU closely and expects that additional rounds of sanctions may be imposed as events unfold.

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Authors

Marilou Pavlou Christodoulides | Partner

Stella Kagia | Senior Associate