Overview of potential restrictions resulting from the 19th EU sanctions package

The EU Commission is proposing a full ban on the import of Russian liquefied natural gas (LNG) into the territory of the European Union to take effect from 1 January 2027 – a year earlier than was envisaged in previous plans for phasing out Russian fossil fuels. 

There are expected to be limited exclusions from the ban for certain member states that are not connected to European gas infrastructure and rely on LNG imports for technical reasons.

Under Regulation (EU) No. 833/2014, with effect from 16 March 2022 a ban was imposed on transactions with legal entities controlled by the Russian Government, including Rosneft PJSC and Gazprom Neft PJSC (Article 5aa of the Regulation). However, the Regulation provides for limited derogations (exclusions) to be granted by the competent authorities of EU member states, for example, for purposes related to energy security (including the purchase, import and transportation of fossil fuels).

It is stated in the official press release that the Commission is proposing to abolish all existing exclusions.

The EU Commission has proposed adding a further 118 vessels involved in the transportation of Russian oil at prices exceeding the established price cap in the list of vessels prohibited from entering EU ports and from being provided with services, including insurance, bunkering and maintenance services.

If the 19^th package is passed, this will bring the total number of vessels on the list to over 560. It will be recalled that the 18^th EU sanctions package set the price cap for seaborne Russian oil at $47.60 per barrel with effect from 3 September 2025.

The EU Commission has proposed imposing blocking measures against oil refineries, traders and petrochemical companies registered in third countries, including China and India, which are found to be buying Russian oil at prices exceeding the established price cap.

As a reminder, the 18th sanctions package introduced blocking sanctions against a number of foreign (non-Russia-based) legal entities involved in oil supplies, mainly companies based in China, India and the UAE (including traders operating from the UAE and China as well as an Indian refinery (the Vadinar Refinery)).

In the 19^th sanctions package the EU Commission plans to toughen still further the restrictive measures levelled against Russia’s financial sector.

In particular, it plans to impose a transaction ban on more Russian banks and financial institutions in third countries which provide direct or indirect support to Russia’s military or facilitate sanctions evasion.

As a reminder, in the 18^th EU sanctions package in the summer of 2025 restrictive measures were imposed for the first time against two Chinese banks (Suifenhe Rural Commercial Bank and Heihe Rural Commercial Bank).

In the 19^th sanctions package the EU also proposes to introduce for the first time a full ban on the provision of cryptocurrency and blockchain services to Russian nationals. The measures would apply to both Russian and foreign platforms.

The draft package also envisages the introduction of new restrictive measures related to the use of the MIR and SBP payment systems. The specifics of the proposal have not yet been made public, but possible measures might include adding the operators of those systems to sanctions lists or sanctioning foreign persons who use the systems to make payments in circumvention of sanctions.

In addition to the existing restrictions on the insurance of vessels and aircraft alleged to be involved in the violation / circumvention of EU sanctions, the 19^th package also includes a direct ban on reinsuring such vessels and aircraft.

One of the key new features of the 19^th EU sanctions package is the proposal to impose a direct ban on investments in Russian special economic zones (SEZs) and other preferential zones.

It is reported in the mass media that this measure is intended to stop the influx of foreign investment into high-tech and critically important industries which are developed through SEZs with state support. Previously, a narrower ban was introduced targeting investments provided for in Article 3c (the energy sector) as well as in relation to blocked persons. 

The Commission plans to expand export restrictions for dual-use goods and other critically important goods:

• It is proposed to expand the export control list to include chemical substances, metals (including tungsten, manganese and molybdenum), rare earth salts and ores, materials for the aerospace and ship-building industries, and products containing aluminum, nickel and steel alloys.
• It is also planned to extend the restrictions to cover AI, satellite navigation, quantum technology and geospatial data related equipment.

Among other measures proposed in the 19^th EU sanctions package are restrictions related to tourism to Russia. According to media reports, the EU Commission is considering the possibility of tightening the conditions subject to which EU citizens may travel to Russia, including for tourism purposes. At the time of writing there is no information about the specific legal mechanisms that might be used to implement such restrictions.

There are also media reports about proposed restrictions on the movements of Russian diplomats within the EU. It is envisaged that Russian diplomats accredited in the capital city of one EU country would be required to notify other EU countries in advance of any plans to travel to those countries.