Skadden, Arps, Slate, Meagher & Flom LLP and Affiliates

EU Adopts 19th Russia Sanctions Package Alongside New Sanctions Being Imposed by US and UK

Skadden Publication / White Collar Defense and Investigations

Eytan J. Fisch Ryan D. Junck Margot Sève Michael Albrecht vom Kolke Jonathan Benson Wesley Lainé Philipp Mueller Greg Seidner Gregory Vianesi

Executive Summary 

  • What’s new: The EU adopted its 19th sanctions package against Russia, introducing new asset freezes and restrictions and putting into law ownership/control conditions.
  • Why it matters: These developments significantly expand the scope of EU sanctions. The far-reaching rules will:
    • affect entities dealing with Russia’s energy, finance, defense and professional services sectors; and
    • increase compliance obligations and enforcement risks for companies producing AI technology and computing services, tourism services and transport-related goods such as chemicals and tyres.
  • What to do next: Companies should review the new restrictions, assess their exposure to sanctioned sectors and entities and prepare full compliance with the updated EU sanctions regime by the approaching deadlines.

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On 23 October 2025, the European Union (EU) adopted its 19th package of sanctions against Russia, imposing asset freeze restrictions against 64 individuals and entities,1 and introducing extensive sectoral sanctions to put further pressure on Russia’s energy, finance and defense sectors.2 Notably, the EU imposed a ban on the import of Russian liquefied natural gas (LNG) into the EU, expanded the scope of measures banning transactions to cover additional components of Russia’s financial services architecture and adopted new restrictions targeting Russia’s special economic zones. The adoption of the package came after protracted negotiations between the EU member states and followed intense military activity by Russia in Ukraine, as well as renewed efforts by the US and the EU to coordinate on Russia sanctions.

Importantly, the EU also introduced specific definitions for the concepts of ownership and control for designated entities under Council Regulation (EU) 269/2014 (Regulation 269). These definitions are intended to provide a consistent and binding interpretation of the asset-freezing measures that apply to sanctioned targets. The new definitions also align with the guidance set out in the EU Best Practices for the Effective Implementation of Restrictive Measures published on 3 July 2024.

The asset-freezing measures under Regulation 269 took effect on 23 October 2025, and the new sectoral sanctions under Council Regulation (EU) 833/2014 (Regulation 833) came into force on 24 October 2025.3

Notably, the EU included a law firm (Maxima Legal) in the 19th sanctions package because the firm was accused of facilitating Russia’s evasion of asset-freezing measures by providing falsified documents. This marks the first time a law firm has been sanctioned and serves as an enforcement warning to professional advisers.

As part of its 19th sanctions package, the EU has also introduced new restrictive measures targeting Belarus. These measures include asset freezes on individuals and entities involved in the Belarusian military-industrial complex, as well as additional sectoral sanctions designed to further align EU policy with the sanctions already imposed on Russia.4

The new sanctions package followed closely on the heels of the designations by the US Treasury’s Office of Foreign Assets Control (OFAC) of PJSC Rosneft Oil Company (Rosneft) and PJSC Lukoil Oil Company (Lukoil) on 22 October 2025 and the UK’s imposition on 15 October 2025 of asset-freezing sanctions on dozens of companies operating in the Russian energy sector, including Rosneft and Lukoil. Collectively, the EU’s 19th sanctions package and the actions taken by the United States and United Kingdom represent a continuation of the long-standing coordination across the US, UK and EU in sanctioning Russia and a significant expansion of their efforts to stymie Russia’s cash flows and bring about an end to the war in Ukraine.

This alert explores the EU’s 19th sanctions package and its ramifications in further detail.

Areas of Update and Key Points

Asset Freezes and Definitions of ‘Owning’ and ‘Controlling’ Under Regulation 269

  • The EU has imposed asset-freezing restrictions against 22 individuals and 42 entities under Regulation 269. The sanctioned entities include Russian energy companies, Chinese petrochemical and oil refinery companies, and a major Chinese state-owned entity.
  • The EU has added a new criterion allowing the EU to impose asset-freezing measures against individuals and entities that allegedly support or implement actions or policies that contribute to the deportation, forced transfer or assimilation, or militarized education of Ukrainian children.
  • The EU has introduced specific definitions of “owning” and “controlling” an entity under Regulation 269.
    • In this context, ownership means being in possession of 50% or more of the proprietary rights of an entity or having a majority interest therein for the purpose of EU asset-freezing restrictions.
    • For the purpose of assessing control, Regulation 269 provides a nonexhaustive list of criteria that includes a situation where an EU-designated person has the right to exercise dominant influence over an entity, among other factors.
  • To improve clarity regarding the scope of asset-freezing restrictions, the EU has amended the asset freeze provision under Regulation 269. Specifically, the amendment removes the term “associated” persons from the obligation to freeze all funds and economic resources of listed persons, and the prohibition on making funds and economic resources available to such persons.

Sanctions Targeting Russia’s Energy Sector – Ban on Russian LNG; Ban on Reinsuring Shadow Fleet Vessels

  • The EU has banned the purchase, import or transfer into the EU — whether directly or indirectly — of LNG that originates in, or is exported from, Russia. The ban also applies to covered services relating to the banned LNG. The ban will take effect on 1 January 2027 for contracts lasting more than one year that were entered into before 17 June 2025 (excluding natural gas derivatives). For all other contracts, the ban will apply starting 25 April 2026.
  • The EU has bolstered the transaction ban on Rosneft and Gazprom Neft under Article 5aa of Regulation 833. These companies are no longer eligible for certain energy-related exemptions that previously allowed the import of specific covered products into the EU. As noted above, Rosneft, along with Lukoil, is now also subject to US blocking sanctions and a UK asset freeze. Gazprom Neft has been subject to US and UK sanctions since January 2025.
  • Sanctions were imposed on an additional 117 shadow fleet vessels the EU determined are engaged in sanctionable activities in support of the war in Ukraine.
  • The EU has amended the sanctions provision relating to shadow fleet vessels.

Financial Sector Restrictions – Prohibition on Cryptoasset and Specified Payment Services

  • The EU has imposed several transaction bans targeting Russia’s financial sector under Regulation 833, including bans against the Russian National Card Payment System (in Russian, “Mir”) and the Fast Payments System (SBP), both established by the Central Bank of Russia or other Russian entities.
  • Regulation 833 prohibits EU persons from engaging directly or indirectly in any transaction involving the rouble-backed and Kyrgyzstan-based stablecoin A7A5.
  • Under Regulation 833, EU persons are now also prohibited from providing cryptoasset services or specified covered payment services or issuing electronic money to Russia.

Special Economic Zones in Russia – Restrictions on Business Relationships

  • The EU has also introduced significant restrictions on business relationships with 11 Russian special economic, innovation and preferential zones (SEZs) listed in Annex LII of Regulation 833.
  • For two Russian SEZs — Alabuga and Technopolis Moscow — Regulation 833 imposes a ban that applies to existing contracts, effectively requiring EU business to divest from these SEZs.

Professional Services Restrictions – AI, Space, Computing and Tourism

  • The EU has extended the scope of the ban on certain professional services to certain commercial space-based services, certain artificial intelligence services, and high-performance computing and quantum computing services. These restrictions will take effect on 25 November 2025.
  • Regulation 833 also prohibits EU businesses from providing services directly related to tourism activities in Russia.
  • Regulation 833 requires prior authorization to provide, directly or indirectly, any service not specified in paragraphs 1 and 2 of Article 5n if the service is intended for the Russian government.

Trade Measures – Electronic Components, Rangefinders, Chemicals, Tyres, etc.

  • The amended regulation further restricts the sale, supply, transfer or exporting of goods that could contribute, in particular, to enhancing Russian industrial capacities. The rules now include electronic components, rangefinders, new pneumatic rubber tyres and additional chemicals used in the preparation of propellants, as well as additional metals, oxides and alloys used in the manufacturing of military systems.
  • Regulation 833 also prohibits the purchase, transfer or importing of acylic hydrocarbons from Russia.

Transportation Measures – Ban on Insurance Coverage Regarding Vessels or Aircrafts

  • Regulation 833 introduces a new prohibition effective for five years after the sale or lease of vessels or aircraft that were operated, directly or indirectly, by the Russian government or by any Russian legal entity. During this period, selling, providing, underwriting or entering into any contract or arrangement that transfers or cedes insurance risks related to these vessels or aircraft is prohibited.
  • The EU now has the authority to extend its ban on ports and locks in Russia to also include ports and locks located outside of Russia, provided they are listed in Part C of Annex XLVII. At the time of writing, the EU has not added any new ports or locks outside of Russia to this list. However, the EU may choose to do so if such ports or locks are used to transfer UAVs, missiles or related technology or components to Russia, or to circumvent other EU restrictive measures, including the oil price cap.

Anticircumvention Measures – Extension of Port Infrastructure Ban

  • The EU has extended the ban on Russian ports and locks and airports to now include certain ports and locks listed in Part C of Annex XLVII that are outside of Russia and used to transfer UAVs, missiles or related technology or components thereof to Russia, or for the circumvention of other EU restrictive measures, including the oil price cap.
  • The updates added 45 entities connected to Russia’s military-industrial complex to Annex IV of Regulation 833, making those entities subject to stricter export restrictions on dual-use goods and technology and advanced technology items.

Russian Exit Transactions – Extended Deadline to 31 December 2026

  • The deadline for the divestment derogation for Russian exit transactions involving the sale, supply or transfer of controlled goods, or the provision of restricted professional services, has been extended to 31 December 2026.

Asset Freezes

New Individuals and Entities Listed by the EU

As referenced above, the EU has imposed asset-freezing restrictions against 22 individuals and 42 entities under the latest round of sanctions. The asset freeze targets include Russian energy companies, a large Russian company involved in gold production, a Russian company managing the so-called shadow fleet and Chinese refineries facilitating oil trade with Russia. The EU has also imposed asset-freezing restrictions against businesspersons and entities that are part of the Russian military-industrial complex.

At the time of writing, the EU has imposed asset freeze sanctions on more than 2,700 individuals and entities for their actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

New Criterion To Impose Asset Freeze Restrictions

As part of the EU’s 19th sanctions package, the Council of the EU (Council) has introduced a new listing criterion under Regulation 269 to impose asset freeze restrictions on individuals or entities that are responsible for supporting or implementing actions or policies contributing to the deportation, forced transfer or assimilation — including indoctrination or militarized education of — Ukrainian minors. Under this new criterion, the EU imposed asset-freezing sanctions against 11 individuals pursuant to Regulation 269.

Specific Definitions of the Concepts of Ownership and Control Under Regulation 269

Under Regulation 269, EU operators must freeze all funds and economic resources that belong to or are owned, held or controlled by the listed persons. In addition, EU operators are prohibited from making any funds or economic resources available, either directly or indirectly, to or for the benefit of these listed persons.

Historically, the EU has provided nonbinding guidance on key concepts such as ownership and control to support the effective implementation of asset freeze requirements. This guidance aims to clarify how these measures should be applied in practice. For example, in a July 2024 update to the EU Best Practices for the Effective Implementation of Restrictive Measures, the Council clarified that, for the purposes of EU asset-freezing restrictions, “ownership” means possessing 50% or more of the proprietary rights in an entity or holding a majority interest in it. The EU Best Practices also further clarifies the concept of control in this context.

With the adoption of the 19th sanctions package, the Council has now incorporated this guidance into binding EU law by introducing specific definitions of ownership and control in the asset freeze regulation: Under Regulation 269, as referenced above, ownership is defined as possessing 50% or more of the proprietary rights in an entity or having a majority interest in it. For control, consistent with the EU Best Practices, Regulation 269 sets out a nonexhaustive list of eight criteria. These criteria relate to both formal and de facto powers to direct management or operations — including rights to appoint or remove board members, control voting majorities, exercise dominant influence (by agreement or practice), use assets, manage business activities on a consolidated basis or share financial liabilities.

Removal of the Reference to Associated Entities and Individuals

The asset freeze provisions in Article 2(1) and Article 2(2) of Regulation 269 previously included references to entities or individuals “associated” with sanctioned persons. EU guidance warned that asset-freezing restrictions imposed on sanctioned persons could also impact transactions involving these associated entities or individuals, some of whom are identified in the “Identifying information” and/or “Reasons” columns of Annex I to Regulation 269. To enhance clarity on the scope of the asset freeze restrictions, the Council has amended Article 2(1) and Article 2(2) of Regulation 269 by removing the references to “associated” entities or individuals.

Sanctions Targeting Russia’s Energy Sector

Ban on Russian LNG

The EU has imposed restrictive measures that prohibit EU operators from purchasing, importing, or transferring — either directly or indirectly — LNG that originates in, or is exported from, Russia. Although the provision’s wording omits “into the Union,” the recitals clarify that the ban targets “the purchase, import, or transfer, directly or indirectly into the Union,” mirroring the approach taken under the Regulation 833 import ban on Russian crude oil.5 This drafting again creates uncertainty about whether the prohibition also extends to purchase agreements for Russian LNG not destined for the EU.

The measures further prohibit EU operators from providing technical assistance, brokering services, financing, financial assistance or any other services related to Russian LNG. As referenced above, the ban on Russian LNG will take effect on 1 January 2027 for contracts lasting more than one year that were entered into before 17 June 2025 (excluding natural gas derivatives). For all other contracts, the ban will apply starting 25 April 2026.

The Council emphasized that this import ban must be observed, regardless of any provisions in other EU legislation that may have a similar or overlapping scope.

Further Restrictions on Dealings With Rosneft and Gazprom Neft

Removal From Certain Exemptions

As referenced above, the Council has strengthened restrictions on the two major Russian energy companies, Rosneft and Gazprom Neft, by removing certain exemptions that previously applied to them.

Rosneft is excluded from the exemption that permits transactions strictly necessary for the direct or indirect purchase, import or transport of certain commodities. Specifically, Rosneft cannot benefit from the exemption for:

  • Transactions involving the purchase, import or transport of natural gas, titanium, aluminum, copper, nickel, palladium and iron ore from or through Russia into the European Union, any member country of the European Economic Area, Switzerland or the Western Balkans.
  • Transactions involving the purchase, import or transport of oil, including refined petroleum products, from or through Russia.

An exception remains for the transit of oil or refined petroleum products that originate in a third country and are merely being loaded in, departing from or transiting through Russia, provided that both the origin and the owner of those goods are non-Russian. In such cases, the exemption may still apply.

Gazprom Neft is also excluded from the two exemptions outlined above. Furthermore, Gazprom Neft is not eligible for the exemption that allows certain transactions related to energy projects located outside of Russia. This means that any transactions involving Gazprom Neft, even if they pertain to energy projects outside Russia, are not covered by this particular exemption.

New Exemption

The Council introduced a new exemption that permits transactions with Rosneft and Gazprom Neft when these transactions are necessary for the trading, brokering or transport of Russian crude oil (classified under CN code 2709 00) and petroleum products (classified under CN code 2710). This exemption also covers the provision of related services. However, these activities are only allowed if they comply with the oil price cap and do not conflict with the prohibition set out in Article 3m of Regulation 833.

Expansion of Shadow Fleet Sanctions

The EU’s restrictive measures against the so-called shadow fleet prohibit EU operators from providing a wide range of maritime services to the sanctioned vessels listed in Annex XLII of Regulation 833. As referenced above, the EU has now amended a specific provision in these measures to clarify that reinsurance services are now explicitly prohibited. Additionally, the Council has added a specific criterion allowing the EU to impose sanctions on vessels transporting Russian mineral products using irregular and high-risk shipping practices as set out in the International Maritime Organisation General Assembly Resolution A.1192(33).

Financial Sector Restrictions

Expanded Scope of Transaction Ban

The EU has expanded the scope of its transaction ban measures to cover additional components of Russia’s financial services architecture. In particular, as referenced above, the Council has extended the EU transaction ban on the Central Bank of Russia’s System for Transfer of Financial Messages (SPFS) to include the Russian National Card Payment System (Mir) and the Fast Payments System (SBP), both established by the Central Bank of Russia or other Russian entities. This ban will take effect on 25 January 2026.

In addition, the EU has imposed transaction bans on the following:

  • Five additional Russian banks have been added to Annex XIV of Regulation 833. These banks will be subject to a transaction ban starting 12 November 2025.
  • Six entities providing cryptoasset and payment services have been included because the EU considers that they have taken actions undermining the sanctions provisions of Regulation 269. The ban will apply to five of these entities from 12 November 2025, and to the remaining entity from 25 November 2025.
  • Two oil traders are now subject to a transaction ban for circumventing certain energy-related restrictions under Regulation 833. This ban will take effect on 12 November 2025.
  • Four banks from Belarus and Kazakhstan are subject to a transaction ban for their use of the Russian SPFS. This ban will take effect on 2 December 2025.

Prohibition on Cryptoasset and Payment Services; E-Money Issuance

Regulation 833 prohibits EU persons from providing cryptoasset services or certain specified payment services or issuing electronic money to Russian nationals or residents, as well as to Russian entities. For the purposes of the sanctions, cryptoasset services are defined by Regulation (EU) 2023/1114 and electronic money is defined by Directive 2009/110/EC. The specified payment services are: (i) issuing payment instruments and/or acquiring of payment transactions; and (ii) payment initiation services, as these services are defined by Directive (EU) 2015/2366.

Restrictions on Russia’s Special Economic Zones

The EU has imposed sanctions on 11 Russian Special Economic Zones (SEZs) to prevent EU businesses from engaging with these areas. These SEZs are intended to attract foreign investment and promote economic growth and infrastructure development in Russia.

With respect to the 11 listed Russian SEZs listed in Annex LII, Regulation 833 prohibits:

a. Acquiring new or increasing existing participation in the ownership or control of entities that are residents of, or that have a registered office, principal place of business or permanent establishment within these SEZs.

b. Creating any new joint venture, branch or representative office in these SEZs, or with an entity falling within the scope of item (a) above.

c. Entering into any new contract or arrangement to supply goods or services, or related intellectual property rights or trade secrets to, from or for use in these SEZs, or with an entity falling within the scope of item (a) above.

d. Granting, participating in or being part of any arrangement to grant any loan, credit or other form of financing — including equity capital — to these SEZs, or for the documented purpose of financing such SEZs. Additionally, providing investment services to these SEZs is prohibited.

As referenced above, Regulation 833 imposes a ban on two specific SEZs — Alabuga and Technopolis Moscow — that will take effect for existing contracts on 25 January 2026. This ban will require EU businesses to divest from these SEZs. Specifically, the ban prohibits:

x. Maintaining any existing participation in ownership or control of any entity that is formally registered as a resident of, or that has a registered office, principal place of business or permanent establishment within these SEZs.

y. Maintaining any existing joint venture, branch or representative office in these SEZs, or with an entity falling within the scope of item (x) above.

z. Maintaining any existing contract or arrangement to supply goods or services, or related intellectual property rights or trade secrets to, from, or for use in these SEZs, or with an entity falling within the scope of item (x) above.

All of the restrictions outlined above also apply to any entity located outside these SEZs if it is owned or controlled by an entity that is subject to the same restrictions.

Professional Services Restrictions

Prior Authorization Mandatory for All Non-Prohibited Services to the Russian Government

To mitigate the risk of a service contributing to Russia’s military, technological or industrial capacity, Regulation 833 introduces a new requirement for prior authorization from an EU national competent authority before an EU person or entity can provide any service not already subject to an existing professional service restriction, where that service is intended for the Russian government.

In relation to this new prohibition, the EU has provided a wind-down period until 1 January 2026 for contracts concluded before 24 October 2025, or provides for an ancillary contract necessary for the satisfaction of such a contract.

Further Prohibition on Services Enhancing Russia’s Technological Capabilities

Regulation 833 further restricts the provision of services that could contribute to the enhancement of Russia’s technological and industrial capacity. The prohibition now extends to the following categories of services:

  • Commercial space-based services consisting of Earth observation and satellite navigation. An EU national competent authority may authorize these services if they are deemed necessary for intergovernmental space cooperation.
  • Artificial Intelligence (AI) services, covering access to AI models or platforms used for training, fine-tuning or inference. An EU national competent authority may authorize these services only if they are strictly needed for Russian nationals’ work on international open-source projects.
  • High-performance computing and quantum computing services. An EU national competent authority may authorize these services only if they are strictly needed for Russian nationals’ work on international open-source projects.
  • Integrated engineering, urban planning, engineering-related scientific and technical consulting services, including geological, geophysical and other scientific prospecting, subsurface surveying, surface surveying and mapmaking.

New Prohibition on Tourism-Related Services

Regulation 833 also now explicitly prohibits EU entities from providing services directly connected to tourism activities in Russia, in particular travel agency and tour operator services, tourist guide services and advertising services related to these services. This new prohibition underscores the EU’s intent to reduce the revenues that Russia derives from such services and to deter the promotion of nonessential travel and leisure activities to Russia.

Regulation 833 provides a wind-down period until 1 January 2026 for contracts concluded before 24 October 2025, or provides for an ancillary contract necessary for the satisfaction of such a contract.

Transportation Measures

Regulation 833 introduces new restrictions to limit Russia’s ability to derive income from aged aircraft and vessels, and to disrupt its access to international shipping routes. Specifically, for five years following the sale or lease of vessels or aircraft previously operated by the Russian government or Russian entities, EU operators are prohibited from selling, providing, underwriting or entering into any contract or arrangement that transfers or cedes the insurance risk for these assets. This includes both direct insurance and reinsurance contracts, meaning no risk associated with these vessels or aircraft may be covered by EU operators during the five-year period.6

Insurance is essential for the commercial viability of ships and aircraft because they cannot access major ports or operate internationally without coverage. By banning these insurance services for five years after sale or lease, the EU aims to prevent Russia from using old or poorly maintained assets to generate revenue or evade sanctions.

Anticircumvention Measures

The EU is also enhancing its ability to prevent sanctions evasion by targeting third-country actors and networks involved in circumventing restrictions on Russia.

Expansion of Transaction Ban Criteria

The EU has started listing financial institutions, cryptoasset service providers and payment service providers in Annex XLV that are subject to the transaction ban for, in the EU’s view, having facilitated or supported sanctioned individuals or entities, or having undermined the objectives of the EU’s sanctions. This includes five non-Russian banks in Central Asia.

The new sanctions have also strengthened the transaction ban criteria to apply not only to non-listed entities acting on behalf or at the direction of listed entities but also to non-listed entities providing cryptoasset services or payment services that act as a mirror or as successor entities to those listed in Annex XLV. This prevents entities from evading sanctions through rebranding or restructuring. A mirror or successor entity is defined by Regulation 833 as one that meets at least two criteria indicating it effectively continues or replicates the listed entity, such as maintaining similar content or transaction flows; continuing branding or technical infrastructure; overlapping ownership or management; or redirecting users from the listed entity.

Regulation 833 allows a wind-down period until 25 April 2026 for transactions with entities listed in Annex XLV (Part A) in order to fulfill contracts that were concluded before 24 October 2025, as well as any related ancillary contracts. In addition, transactions necessary to receive payments under contracts that were performed before 24 October 2025 are exempt.

Expanded Transaction Ban on Ports and Locks Supporting Russia’s War Efforts

Regulation 833 already prohibited transactions with Russian ports and locks listed in Part A of Annex XLVII and with Russian airports listed in Part B. The new sanctions add Part C to Annex XLVII (no ports or locks have been listed there yet), extending the transaction ban to ports and locks located in other countries outside Russia. This restriction addresses the risk that foreign ports and locks have been used as transit points or logistical hubs to bypass existing sanctions targeting Russian maritime infrastructures, including for the transfer of unmanned arial vehicles (UAVs) or missiles or related technology or components to Russia, or for the circumvention of the oil price cap.

Expanded Export Restrictions on Entities Supporting Russia’s Military-Industrial Complex

As referenced above, The EU added 45 entities to Annex IV of Regulation 833 after identifying those entities as directly supporting Russia’s military and industrial complex by enabling the circumvention of export restrictions on computer numerical control (CNC) machine tools, microelectronics, UAVs and other advanced technology items. Of the 45 newly listed entities, 28 are established in Russia and 17 in third countries (12 in China, including Hong Kong, 3 in India and 2 in Thailand). These entities are now subject to stricter export restrictions with respect to dual-use goods and technology and advanced technology items. This update reflects the EU’s efforts to cut off foreign actors acting as backdoor suppliers to Russia’s military sector. The expanded scope extends beyond Russia’s borders to disrupt indirect supply routes and complex ownership structures designed to bypass sanctions, which intensifies pressure on foreign subsidiaries and third-country operators supporting Russia’s war efforts.

Trade Measures

Additional Export Restrictions

The EU has expanded the scope of certain trade-related restrictions under Regulation 833 to include new export restrictions on additional dual‑use items and advanced technologies. As referenced above, the new sanctions have added electronic components, such as microelectronics and certain chemicals used in propellant production, as well as metals, oxides and alloys used in manufacturing military systems, to the list of controlled goods. In addition, the new sanctions now ban the direct and indirect export of, or the provision of technical and financial assistance related to the export of, additional goods that could contribute in particular to the enhancement of Russian industrial capacities — such as salts, ores, rubber articles, tubes, tyres, millstones and construction materials.

Regulation 833 allows a wind-down period until 25 January 2026 for contracts concluded before 24 October 2025. Ancillary contracts that are necessary to complete these contracts are also exempt.

Additional Import Restrictions

The EU has introduced a ban on purchasing, importing or transferring all acyclic hydrocarbons, including saturated acyclic hydrocarbons, which were previously excluded from import restrictions. This reflects the significant revenue these materials generate for Russia’s economy. The new sanctions introduce a targeted exemption allowing EU competent national authorities to authorize the import of (or the provision of related technical and financial assistance for) ultraviolet lamps used for disinfecting drinking water.

Russian Exit Transactions

Extended Deadline

Regulation 833 allows EU national competent authorities to authorize EU businesses to divest from their Russian business operations involving restricted goods or services, provided certain conditions are met to prevent circumvention of the relevant measures under the guise of divestment. The deadline for this divestment derogation has been extended to 31 December 2026 for Russian exit transactions that involve: (i) the sale, supply, transfer or importing of controlled goods; (ii) the sale, licensing or transfer of IP rights or trade secrets relating to controlled goods; or (iii) the provision of restricted professional services as part of such divestment transaction (e.g., transitional services).

The EU has also extended the deadline to 31 December 2026 for the derogation allowing the sale, supply, transfer or provision of goods listed in Annex II, Annex VII and Annex XXIII. This extension applies where such transactions are strictly necessary for divestment from an EU-incorporated joint venture (established before 24 February 2022) that involves a Russian entity and operates gas pipeline infrastructure between Russia and a third country.

Furthermore, the EU has extended the deadline to 31 December 2026, for transactions — including sales — that are strictly necessary to wind down a joint venture or similar legal arrangement established before 16 March 2022 with an entity subject to an EU transaction ban under Article 5aa of Regulation 833 and listed in Annex XIX of the regulation. Similarly, entities subject to Article 5aa (or their subsidiaries within the EU) now have until 31 December 2026 to divest from entities established in the EU.

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1 See Council Regulation (EU) 2025/2037 of 23 October 2025 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. See also Council Implementing Regulation (EU) 2025/2035 of 23 October 2025 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

2 See Council Regulation (EU) 2025/2033 of 23 October 2025 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.

3 This client alert is for informational purposes only and does not constitute legal advice. Complex assessments often have to be made regarding which sanctions regime applies in any given instance, given the multinational touchpoints of many entities and individuals. In that regard, given the complex and dynamic nature of these sanctions regimes, there may be developments not captured in this summary. Additionally, while the summary was accurate when written, it may become inaccurate over time given developments. For all of these reasons, you should consult with a qualified attorney before making any judgments relating to sanctions, as there are potentially severe consequences for failing to adhere fully to sanctions restrictions.

4 See Council Regulation (EU) 2025/2041 of 23 October 2025 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine. See also Council Implementing Regulation (EU) 2025/2039 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine.

5 See Recital 10 of Council Regulation (EU) 2025/2033 of 23 October 2025 Amending Regulation 833.

6 In Recital 11 of Council Regulation (EU) 2025/2033 of 23 October 2025 Amending Regulation 833, the Council stated that the designation of a vessel is without prejudice to the payment of payouts from the relevant insurer of the vessel to persons and entities having suffered damage caused by the vessel for claims arising from events before the vessel was designated. 

This memorandum is provided by Skadden, Arps, Slate, Meagher & Flom LLP and its affiliates for educational and informational purposes only and is not intended and should not be construed as legal advice. This memorandum is considered advertising under applicable state laws.

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