EU’s 19th sanctions package against Russia: What it means for European trade and compliance.

Tougher EU sanctions, broader business impact

The EU’s latest sanctions package against Russia, adopted in October 2025, is its most comprehensive to date. Building on earlier rounds, the 19th package targets Russian liquefied natural gas (LNG), financial systems, cryptocurrency platforms and advanced technologies – as well as non-EU entities helping Moscow to evade existing restrictions. For European traders and logistics operators, the implications are clear: compliance frameworks must now extend well beyond direct trade with Russia to include every layer of the supply chain, from payment processing to vessel selection.

For importers, exporters and logistics businesses, this development is not just another layer of bureaucracy – it’s a structural shift in how European trade must operate under sanctions pressure. Below, we outline what’s included in the 19th package, what it means in practice, and how Gaston Schul helps businesses navigate the changes with confidence.

EU sanctions explained: What the 19th package includes

The 19th sanctions package builds on the EU’s earlier measures, tightening controls across energy, finance, technology and trade.

Energy restrictions: LNG bans and shadow-fleet crackdown

The EU introduces a phased ban on imports of Russian liquefied natural gas (LNG) – with short-term contracts ending within six months and long-term contracts by 1 January 2027. A full transaction ban now applies to Rosneft PAO and Gazprom Neft, closing previous exemptions.

The EU also targets Russia’s so-called “shadow fleet” – adding 117 more tankers to its port-access and service bans, bringing the total to 557 vessels. In addition, it is now prohibited to engage, directly or indirectly, in transactions with the ports and locks listed in Part A and Part C of Annex XLVII of the EU sanctions regulation – covering both Russian ports and ports or locks in third countries that facilitate Russian oil and LNG exports. This measure reinforces maritime restrictions, aiming to cut off alternative export routes and service networks supporting Russia’s energy trade.

Several Chinese refineries and an oil trader are also listed for continuing to buy Russian crude, reflecting Brussels’ broader enforcement against third-country enablers. For logistics providers, port operators and freight forwarders, this means enhanced due diligence is essential – verifying that vessels, ports and service providers are not connected to the restricted facilities or networks identified under the latest EU listings.

Financial and crypto sanctions: Closing digital escape routes

New restrictions hit Russian banks and third-country financial institutions that facilitate war-related transactions or help to circumvent existing measures. For the first time, the EU sanctions cryptocurrency platforms and stablecoins used to bypass financial restrictions – including the A7A5 stablecoin and its Kyrgyz issuer.

The 19th sanctions package also introduces additional measures under Article 5ad to combat the proliferation of new entities replacing those already listed. The prohibition on transactions now extends to equivalent entities when specific criteria are met – preventing sanctioned businesses from simply rebranding or transferring operations to avoid restrictions.

Furthermore, the existing prohibition on engaging in transactions with credit institutions, financial institutions, and providers of crypto-asset services from third countries has been extended to include entities offering payment services – particularly those whose crypto-asset or digital payment operations undermine the effectiveness of EU sanctions.

For financial operators, logistics firms handling payments, and trade facilitators, this means a much broader compliance perimeter: screening must now include newly formed entities, payment intermediaries, and digital platforms that could indirectly connect to sanctioned networks.

Export controls and trade restrictions: Expanding the military list

The EU widens export bans on dual-use goods, AI and high-performance computing technologies, and materials used in Russia’s defence production. Forty-five new entities, including several non-EU companies, are now listed for supporting Russia’s military-industrial base. The new listings target not only manufacturers but also distributors and intermediaries that supply critical components to Russia’s arms sector.

The 19th sanctions package also strengthens end-use monitoring and closes loopholes that allowed high-risk goods to transit through third countries before reaching Russia. Special economic zones (SEZs) in Russia are additionally targeted – with investment bans and divestment requirements now applying to EU businesses still active in those zones.

For exporters and logistics providers, this means compliance teams must verify not only the goods and technologies they handle, but also the ultimate end-users, destinations, and intermediaries involved in every shipment to ensure no indirect links to sanctioned entities or controlled zones.

Additional measures: Individuals, diplomacy and enforcement

Further listings include 69 individuals connected to human-rights violations, including the abduction and forced transfer of Ukrainian children. Russian diplomats travelling within the EU will now face prior-authorisation requirements, and the EU introduces new anti-circumvention tools extending to a wider range of services – including re-insurance, satellite and space-based technologies, digital services and AI-enabled platforms.

These measures broaden the EU’s capacity to disrupt circumvention networks and apply consistent restrictions across financial, technological and diplomatic channels.

For international businesses, this signals a continued shift towards cross-sector enforcement – where compliance risks may arise not only from trade in goods but also from service provision, data access, and technology partnerships linked to sanctioned actors.

Business impact: How EU sanctions affect European trade

For businesses engaged in logistics, manufacturing, energy or financial services, the 19th sanctions package demands proactive adaptation.

1. Energy and logistics supply-chains under pressure

Importers of Russian LNG must restructure contracts well ahead of the 2027 deadline. Maritime operators, freight forwarders and insurers face new due-diligence duties as hundreds of vessels are now blacklisted. The risk of inadvertent involvement in the “shadow fleet” has never been higher.

2. Financial compliance and crypto risk

Companies handling cross-border payments must ensure partners are not linked to sanctioned banks or digital-asset platforms. While payment-service restrictions are broad, they do not require payment initiators or card acquirers to screen individual transactions; primary responsibility lies with the account-servicing payment service provider. Restrictions on crypto-asset services also extend to entities operating under the EU 2023/1114 transitional regime, bringing newly regulated providers within the scope of sanctions enforcement.

3. Export control tightening

Exporters of industrial machinery, metals, advanced computing or drone components must reassess their supply chains. New listing regimes mean even indirect links to sanctioned entities in Asia or the Middle East can lead to enforcement action.

4. Customs scrutiny and operational complexity

EU customs authorities will apply enhanced checks on dual-use goods and shipments connected to listed entities. Delays, detentions or licence denials could increase unless businesses integrate real-time sanctions screening into their customs workflows.

5. Strategic repositioning across Europe

Although sanctions raise compliance costs, they also open opportunities. Businesses that can demonstrate sanctions-proof supply chains, EU-compliant sourcing, and digital customs solutions will gain a competitive edge as others struggle to adapt.

Strengthen your compliance with our free due diligence checklist

The EU’s 19th sanctions package highlights how quickly compliance obligations can evolve. Our due diligence checklist helps you assess risks across any trade partner, route or transaction – not just those linked to Russia.

Download your free checklist here and make due diligence part of your daily trade resilience.

How Gaston Schul helps your business stay compliant and competitive

Gaston Schul combines pan-European customs expertise with hands-on regulatory support to help your business navigate EU sanctions and trade controls without disruption. Our approach turns complex compliance requirements into practical, business-ready solutions.

We assist with:

• Interpreting and applying EU sanctions – translating evolving regulations into clear operational steps for your business.
• Classifying controlled goods and technologies – ensuring accurate tariff and export-control classification to avoid costly errors.
• Screening partners, goods and trade routes – identifying exposure to listed entities, high-risk shipments and sanction-linked intermediaries.
• Preparing export documentation and licence applications – embedding compliance into your customs and logistics processes.
• Providing tailored training and readiness programmes – equipping your teams to recognise and manage sanctions risks confidently.

With Gaston Schul as your compliance partner, you can focus on growing your business – while we help you stay compliant, audit-ready and resilient across every stage of your cross-border trade.

Turning EU sanctions compliance into a competitive advantage

The EU’s 19th sanctions package against Russia marks a decisive escalation in Europe’s trade restrictions – affecting everything from LNG contracts to crypto transactions. For businesses across the continent, compliance is no longer optional; it’s a strategic differentiator.

We help you gain clarity, resilience and control over your cross-border operations. Talk to our experts about your customs and compliance strategy – and keep your business moving securely under the new EU sanctions regime.