Europe increases pressure: 19th package of sanctions targets Russian energy and financial sectors

Key elements of the 19th sanctions package

Ban on the import of liquefied natural gas (LNG)

The new package of sanctions imposes a ban on the purchase, import or transit of liquefied natural gas originating in Russia (or exported from Russia), with effect from 1 January 2027.

Prohibition on the issuance of payment instruments

Under the new sanctions package, the issuance of payment instruments is prohibited to Russian nationals or natural persons residing in Russia, or to any legal person, entity or body established in Russia.

Prohibition on the involvement in certain Special Economic Zones (SEZs)

Recognising the potential risks arising from attracting new companies to Russian special economic zones (SEZs) that could contribute to the enhancement of Russia’s military capabilities, the new sanctions prohibit any participation in the ownership structures of companies located in certain Russian SEZs, inter alia including the establishment of joint ventures and the conclusion of any type of contract with such companies.

Authorisation requirement for the provision of non-prohibited services

For the provision of services that are not prohibited under the EU law to the Russian authorities a person must obtain prior authorisation from the competent authority of the Member State.

New definitions introduced for the terms “Owning” and “Controlling”

The targeted sanctions introduce, for the first time within the EU’s restrictive measures framework, legally binding definitions of the terms “owning” and “controlling”, thus enhancing legal certainty, and ensuring uniform application across all EU. Previously, these concepts were interpreted and applied through guidance documents issued by the EU institutions. Their inclusion in the Regulation 269/2014 now makes them legally binding, while maintaining consistency with the interpretations already provided in existing EU guidance — therefore, the practical application of these terms remains unchanged.

The EU sanctions lists have been supplemented with:

• 45 legal entities supporting Russia's defence and security sector, including legal entities established in third countries;
• 8 credit institutions, with which it is prohibited to engage in any transactions;
• 116 "shadow fleet" ships or vessels;
• 4 banks located outside Russia that use the Russian Central Bank's SPFS, developed by the Russian Central Bank;
• 6 financial institutions providing crypto-asset services;
• 11 special economic zones (SEZs) where it is not permitted to be a participant, establish a new joint venture, entity, or structure, or conclude contracts for the purchase of goods or services with a legal entity registered in any of the listed SEZs;
• 1 crypto-asset.

Impact of the 19th sanctions package on Belarus

To avoid the risk of sanctions being circumvented via Belarus, a large part of the new restrictions also applies to Belarus. Additional restrictions have been imposed on the provision of computer software development, installation, and maintenance services.

A more detailed summary of the 19th sanctions package.

More information on the new round of sanctions (in English) is available in the Official Journal of the EU.

Since April 2024, the FIU has been the national competent authority for sanctions enforcement in Latvia.