By: Tommaso Fonti LL.M., Lucia Boccarossa, Cristina Piangatello
On 23 October 2025, the European Union published its 19th package of sanctions against Russia, further strengthening the existing restrictive regime.
The new package introduces far-reaching measures affecting trade, technology, services, finance, and energy, significantly expanding the number of entities and activities subject to restrictions.
It is also noteworthy that the new package extends the existing restrictive measures to Belarus.
Impacts on Businesses
The new measures entail significant operational consequences for companies active in the above-mentioned sectors. It is therefore essential to:
a) Verify counterparties and ultimate beneficial owners;
b) Map supply chains and trade flows;
c) Check goods, technologies, and services subject to restrictions;
d) Review contracts and internal procedures to ensure full compliance.
Key New Measures
1. Strengthening of Targeted Restrictions
i. 45 new entities have been listed, including companies in China, India, and Thailand involved in supporting the Russian industrial and technological complex;
ii. The list of individuals and entities subject to restrictive measures has been expanded;
iii. A ban has been introduced on new investments and shareholdings in companies located in the Special Economic Zones (SEZs) of the Russian Federation.
2. Bans on Goods, Technologies, and Sensitive Products
i. Prohibitions have been extended to electronic components, advanced materials, dual-use technologies, as well as metals, alloys, oxides, rubber articles, pipes, tyres, and construction materials;
ii. The import, purchase, and transfer of acyclic hydrocarbons have been banned.
3. Services and New Operational Restrictions
i. A prior authorisation requirement has been introduced for all services provided to the Russian government;
ii. The provision of artificial intelligence, high-performance computing, and commercial space services to Russian entities has been restricted.
4. Financial Sector and Crypto-Assets
i. Restrictions on payment services and crypto-assets have been reinforced, including the blocking of the A7A5 stablecoin and associated exchange platforms;
ii. Eight new financial institutions and traders from Tajikistan, Kyrgyzstan, the United Arab Emirates, and Hong Kong, as well as five Russian banks, have been sanctioned;
iii. The ban on transactions has been extended to four banks in Belarus and Kazakhstan linked to Russian payment systems;
iv. Any interaction with the MIR and SBP payment systems is prohibited.
5. Energy and Maritime Sector
i. As of 1 January 2027, a total ban on the import of Russian LNG will apply, with a six-month transition period for short-term contracts;
ii. Restrictions against Rosneft and Gazprom Neft have been tightened, imposing a total ban on transactions, together with sanctions against a major conglomerate from Tatarstan;
iii. Chinese refineries and companies involved in purchasing Russian oil below the price cap have been sanctioned;
iv. 117 new vessels from the Russian “shadow fleet” have been added to the blacklist.
6. Measures Against Belarus
Restrictions have been extended to the Belarusian industrial complex and the Lukashenko regime, in line with those imposed on Russia.
How We Can Support You
The professionals at Bacciardi Partners are ready to assist you in assessing the impact of the new sanctions on your international operations, updating contracts and internal procedures, and ensuring full regulatory compliance. Contact us for a tailored compliance review or to receive dedicated insights.
Tommaso Fonti, LL.M. – Head of Tax, Customs Law and Global Mobility
Lucia Boccarossa – Senior Associate Tax
Cristina Piangatello – Of Counsel