Editor’s Note
This article provides a chronological overview of the EU’s sanctions against Russia, beginning with the first package enacted on February 23, 2022, and detailing their progressive expansion, including the 19th sanctions package.
On February 23, 2022, the first EU sanctions against Russia in connection with the war in Ukraine came into force. They have been expanded progressively since then.
The Council of the European Union adopted a comprehensive 19th sanctions package on October 23, encompassing a series of economic measures. The aim is to address key sectors contributing to the financing and support of Russia’s invasion of Ukraine. These primarily include the energy, financial services, and military-industrial complex sectors.
Regulation (EU) 2025/2033 amends Regulation (EU) No 833/2014.
- Expansion of the goods list in Annex VII, including electronic components, rangefinders, additional chemicals for fuel production.
- Expansion of the goods list in Annex XXI, with a grandfathering clause for certain newly added goods for a transitional period of three months. The import prohibitions of Article 3i apply to goods in Annex XXI.
- Expansion of the goods list in Annex XXIII, including salts, ores, rubber products, pipes/hoses, tires, millstones, and building materials. The export prohibitions of Article 3k apply to goods in Annex XXIII. A grandfathering clause with a three-month transition period exists for newly included goods. The respective goods are listed in the new Annex XXIIIG.
- LNG Import Ban: From January 2027, no new long-term contracts may be concluded with Russian LNG suppliers. Short-term contracts must be terminated within six months. This particularly affects companies sourcing energy via spot markets or intermediaries.
- Oil Sector: Transaction prohibitions against Rosneft and Gazprom Neft were expanded. Additionally, a Tatar oil conglomerate was listed. Companies with indirect supply relationships should review their partner structures.
- Import ban on liquefied natural gas from April 25, 2026, Article 3ra.
- Third Countries in Focus: Sanctions against Chinese refineries and traders sourcing Russian oil could impact international trade routes and price developments.
Regulation (EU) 2025/2037 and Regulation (EU) 2025/2035 amend Regulation (EU) 269/14.
- Stablecoin A7A5: The EU prohibits any transactions with this cryptocurrency, which has been used to circumvent sanctions.
- Banks from third countries (including Tajikistan, Kyrgyzstan, UAE, Hong Kong) as well as five additional Russian banks were subjected to transaction prohibitions.
- Payment Systems: The use of the Russian payment system “Mir” and the “Fast Payments System (SBP)” is prohibited.
- Special Economic Zones: Companies in nine Russian zones relevant to the war economy may no longer receive economic support.
Regulation (EU) 2025/2033 amends Regulation (EU) 833/2014.
- Litasco Middle East DMCC, a key player in the Russian shadow fleet based in the UAE, was listed.
- Port access ban for an additional 117 vessels: A total of 557 vessels are now affected, including those transporting Russian oil, military goods, or stolen Ukrainian grain (Annex XLII).
- Reinsurance Ban: Shadow fleet vessels may no longer be reinsured – a significant impact on their operational capability.
- Expansion of the service prohibitions in Article 5n, paragraphs 1, 2, and 4, against the Government of Russia and legal persons established in Russia to include tourist activities, space-based services, AI services, as well as high-performance computing and quantum informatics services.
- Five-year sales ban on former Russian ships and aircraft, Article 5u.
Regulations (EU) 2025/2041 and 2025/2039.
- Sanctions against companies from China, India, Thailand, and the UAE that supply dual-use goods or military components to Russia.
- New listings also target actors involved in the inhumane treatment of Ukrainian prisoners of war.
- Prohibition on concluding certain business with companies in special economic, innovation, or preferential zones listed in Annex LII.
Furthermore, the EU has significantly expanded its measures against Belarus.