Russia: the EU’s 19th sanctions package raises the bar

LNG, payments, crypto, export controls, SEZs and services: what materially changes for businesses

The European Union has adopted its 19th package of restrictive measures against Russia. It is broad—and, crucially, highly operational. It addresses energy (with a phased prohibition on Russian LNG), targets the “shadow fleet” (including a reinsurance ban), tightens payments (a ban on MIR/SBP and transaction bans for third-country intermediaries involved in circumvention), enters the crypto space (the first EU prohibition on the use of a specific stablecoin), expands export controls on dual-use and high-tech items, and restricts services (AI, HPC, space; plus ex ante authorisation for services to the Russian government). It is a toolkit designed to reduce Russia’s financial and industrial capacity—yet it has very concrete effects on EU supply chains.

Energy: LNG and the “shadow fleet” (with a reinsurance ban)

On LNG, the direction of travel is clear: short-term contracts must be terminated within six months of the package’s entry into force; long-term contracts are prohibited as of 1 January 2027. For operators, this requires recalibrating supply portfolios, “blend” clauses and end-to-end documentation to substantiate the provenance of molecules.

The shadow fleet is targeted where it hurts most. Beyond enlarging the vessel list (now 557 ships), the package bans reinsurance and designates complicit flag registries, port operators and enablers. Expect higher premiums, longer lead times and a need to renegotiate safe-port, insurance and force-majeure clauses in transport and offtake contracts.

Finance and payments: MIR/SBP banned; transaction bans for third-country intermediaries

EU operators are prohibited from engaging with Russia’s payment systems MIR and SBP. In parallel, the EU imposes transaction bans on selected banks and energy traders in Tajikistan, Kyrgyzstan, the UAE and Hong Kong that facilitate circumvention, alongside additional Russian banks added to the lists. In practice: potential interruptions in payment flows and trade finance whenever listed actors appear in the chain. A precise mapping of correspondent banks and payment service providers is now essential.

Crypto and digital compliance: first EU prohibition on a specific stablecoin

For the first time, the EU prohibits the use of a specific stablecoin (A7A5) within the Union, designating the developer, the (Kyrgyz) issuer and the trading platform. Immediate impact for merchants, PSPs and CASPs: policies, technical blacklists, wallet-screening and on/off-ramp controls must be updated. The signal is unambiguous: “para-financial” channels are fully within the scope of sanctions enforcement.

Export controls and anti-circumvention: dual-use, high-tech and acyclic hydrocarbons

The EU extends listings (including entities in China/Hong Kong, India and Thailand) linked to triangulations in CNC machinery, micro-electronics, UAV components and sensitive chemicals. It also introduces a prohibition on all acyclic hydrocarbons, which will affect parts of the basic chemical industry. Businesses should expect tariff-line reclassifications, strengthened end-use/end-user statements and deeper supply-chain checks involving third-country hubs.

Services and SEZs: ex ante authorisation and targeted bans (AI, HPC, space, tourism)

Two key messages. First, any service to the Russian government not already prohibited is now subject to prior authorisation by the competent authority. Second, there are new prohibitions on services in AI, high-performance computing and space-based commercial services, as well as on services directly connected to tourism in Russia. In addition, special economic zones (SEZs) face severe restrictions—for some (e.g., Alabuga, Technopolis Moscow) the prohibition extends to existing contracts; for others, no new contracts may be concluded. Businesses need to inventory exposures and plan orderly contractual off-ramps where required.

What to do now—immediate actions

  • Payments. Exclude MIR/SBP from your payment stack; reassess correspondent banking and PSPs; update sanctions-change and termination for sanctions clauses in commercial and finance documentation.

  • Energy & shipping. Renegotiate coverage and clauses affected by the shadow-fleet measures (reinsurance, registries, ports). For LNG, set an internal roadmap: phase-out short-term contracts within six months; plan long-term exits by 1 January 2027.

  • Export controls. Reclassify tariff lines; update licences and catch-all controls for third-country hubs; enhance due diligence for CNC, micro-electronics and chemicals.

  • Crypto/CASPs. Implement a technical block on A7A5; refresh KYC/KYB procedures and chain-analysis tooling; adjust merchant and custody workflows.

  • Services & SEZs. Inventory “sensitive” engagements, check prior-authorisation needs, and design a compliant exit path for SEZ-related contracts where the ban already covers ongoing arrangements.

Legal references (structure and publication)

The package amends and supplements the existing EU legal framework—most notably Regulation (EU) No 833/2014 (sectoral measures) and Regulation (EU) No 269/2014 (asset freezes/designations)—as well as the related CFSP Decisions. The Council press release of 23 October 2025 provides the publication details in the Official Journal and the EUR-Lex references (including measures on LNG, the shadow fleet and reinsurance, payment systems MIR/SBP, the A7A5 stablecoin, SEZ restrictions and service prohibitions).

How Studio Legale Rosano can assist

  • Trade & Energy. LNG exit planning; insurance/reinsurance strategies; impact on charter parties and offtake agreements.

  • Finance & Payments. Payment-stack adjustments (MIR/SBP), PSP/banking contracts, transaction-ban playbooks.

  • Crypto & MiCA. Technical blacklisting (A7A5), wallet screening, KYC/KYB, chain-analysis audits.

  • Export Controls. Dual-use/high-tech classifications, licensing and catch-all controls, “deemed export” assessments.

  • Services & SEZs. Prior-authorisation workflows, contract sanctions-change and termination clauses, SEZ exposure mapping and off-ramp implementation.

  • Governance & Audit. Sanctions-compliance programmes, KPIs/controls, training and incident-response across business, finance and IT.

07/11/2025