This Client Alert is published in the context of ongoing developments and should be read in conjunction with Latham’s previous sanctions updates. This Client Alert is not intended to take the form of official legal advice. Given the frequency with which different jurisdictions impose new sanctions, and the detailed and nuanced nature of the sanctions updates, businesses exposed to sanctions-related developments should obtain up-to-date legal advice before taking any steps that may have legal consequences.
On 23 October 2025, the EU unveiled the 19th “package” of sanctions launched against Russia since its invasion of Ukraine in February 2022. Among these measures, the EU: (i) imposed a ban on importing Russian liquefied natural gas (LNG), which will take effect on 25 April 2026; (ii) placed so-called “asset freeze” sanctions on several major Russian companies (including Evraz and AvtoVAZ); and (iii) expanded the range of crypto services which are generally barred from being provided to Russian nationals or persons located in Russia.
On 15 October 2025, the UK placed asset-freeze sanctions on two major Russian oil companies — Rosneft and Lukoil.
This Client Alert summarises the key measures of the EU’s 19th package and provides additional details regarding the UK’s actions against Rosneft and Lukoil.
The EU’s 19th Package — Key Updates
The EU’s 19th package amends the EU’s two major sanctions regulations relating to Russia: Regulation 269/2014, which lists persons and entities associated with actions undermining the sovereignty of Ukraine that have been designated under the EU’s asset-freeze sanctions (Regulation 269); and Regulation 833/2014, which contains the EU’s financial- and trade-related restrictions on Russia (Regulation 833).
Regulation 269
The EU updated Regulation 269 by adopting two new regulations.
- The first, Council Implementing Regulation (EU) 2025/2035, designates a large number of individuals and entities as targets for asset-freeze sanctions. These sanctions require freezing the designated person’s funds or economic resources and prohibit making funds or economic resources available to or for the benefit of the designated person. Recently designated entities include the UK-based Evraz, historically associated with a number of sanctioned individuals, including Roman Abramovich. (The UK sanctioned Evraz on 5 May 2022.) The designations also include: Litasco Middle East DMCC, a Dubai-based subsidiary of PJSC Lukoil; Russian car manufacturer AvtoVAZ; Russian gold-mining company PJSC “Polyus”; and Liayang Petrochemical Company, described as one of China’s leading processors of Russian-sourced crude oil.
- The second, Council Regulation (EU) 2025/2037, amends parts of the substantive provisions of Regulation 269. The additional text includes language defining when a legal person is “owned” or “controlled” by a designated person for purposes of EU asset-freeze sanctions. “Owning” is clarified as being in possession of “50% or more” of the proprietary rights of a legal person, or otherwise “having a majority interest therein”. “Controlling” is defined in non-exhaustive terms, including “having the right” to appoint or remove “a majority of the administrative, management, or supervisory body”, and “having the right”, or de facto “power” to “exercise a dominant influence” over the legal person. This language, which now has direct legal effect as a matter of EU law, was previously reflected in guidance, including that issued by the Council of the European Union in its “EU Best Practices” document.
Regulation 833
The EU updated Regulation 833 through the adoption of Council Regulation 2025/2033. A number of amendments to existing measures, including import and export restrictions, are detailed and need to be considered carefully. Significant new measures include the following.
- The new Article 3ra prohibits, as of 25 April 2026, the import of LNG (falling under CN Code 2711 11 00) “if it originates in Russia or is exported from Russia”, along with associated technical assistance, brokering services, financing or financial assistance, or other services. There is a limited grandfathering provision (scheduled to expire on 1 January 2027) relating to certain types of contracts concluded before 17 June 2025.
- Updates to Article 5aa(3) include the removal of certain exemptions from the pre-existing “transaction ban” relating to Rosneft and Gazprom Neft. Neither entity can now benefit from the exemption where the transaction is strictly necessary for the direct or indirect purchase, import, or transport of oil, including refined petroleum products, from or through Russia, unless the transaction relates to the transit of oil loaded in, departing from, or transiting through Russia and the origin and owner of the goods are not Russian. Further, transactions with Gazprom Neft are no longer permitted where they relate to “energy projects outside Russia” in which Gazprom Neft “is a minority shareholder”. That exception continues, however, in respect of Rosneft. Unlike the US or the UK (discussed below), the EU has yet to impose more comprehensive asset-freeze sanctions on Rosneft.
- Article 5ac is amended to make it prohibited, as of 25 January 2026, for legal persons established in the EU and operating outside of Russia to “connect to any systems of the Central Bank of Russia or to systems provided by any other legal person, entity or body incorporated or constituted under the law of Russia that include a financial messaging functionality, including the Fast Payment System (SBP) and Mir”.
- Article 5ad amends the prohibition on the provision of cryptoasset services by the adoption of measures that appear to be aimed at preventing the use of cryptoassets to circumvent existing EU sanctions. For example, the amendments include a ban on engaging in transactions with listed non-EU persons that provide cryptoasset services or payment services to designated persons or which otherwise “support” “Russia’s war of aggression against Ukraine” or “significantly frustrat[e]” the EU’s oil-related sanctions on Russia.
- The new Article 5ah prohibits acquiring a new or extending an existing participation in ownership or control of any entity established in any of the special economic, innovation, or preferential zones of the Russian Federation listed in Part A or B of Annex LII to the regulation.
- Updates to Article 5b amend previous language which prohibited the provision of “crypto-asset wallet, account or custody services” to Russian nationals or natural/legal persons in Russia. Article 5b now bans the provision of a broad range of crypto and electronic money-related services to such persons. Notably, Article 5b now prohibits providing such persons with “crypto-asset services, as defined in Regulation (EU) 2023/114”, which includes “providing custody and administration of crypto-assets on behalf of clients”, which is defined as “the safekeeping or controlling, on behalf of clients, of crypto-assets or of the means of access to such crypto-assets, where applicable in the form of private cryptographic keys”.
- The new Article 5ba gives the EU the ability to identify certain cryptoassets as prohibited. Currently, the EU has only listed a cryptoasset called “A7A5”, which an EU press release describes as a “stablecoin” that was “created with Russian state support”.
- The EU has imposed “transaction bans” on various entities, including entities alleged to be providing cryptoasset services in ways that undermine EU sanctions. Targeted entities include Payeer and several Tajikistan-based banks. The EU has also placed transaction bans on other entities including Russian banks JSC Alfa-Bank and PJSC MTS Bank.
- The EU has updated Article 5n to expand the range of “professional services” that EU persons are prohibited from providing to the Russian government or Russian legal persons. These are: (a) “artificial intelligence services consisting of access to models or to platforms for their training, fine-tuning and inference”; (b) “high-performance computing, including access to graphic processing unit -accelerated computing, or quantum computing services”; and (c) “services directly related to tourism activities in Russia”. Importantly, the EU now requires that, subject to a limited grandfathering provision, EU persons seeking to provide the Russian government with any services not already banned by Article 5n must obtain “prior authorisation” from the competent authorities of the relevant EU Member State.
- The new Article 5u prohibits the provision of insurance coverage to any vessels or aircraft purchased or leased from the Russian government or by a Russian legal person for up to five years following the purchasing or leasing. An EU press release describes this as intended to ban “reinsuring vessels belonging to the shadow fleet [of vessels that Russia allegedly uses to circumvent EU and other Western powers’ oil sanctions], further constraining their ability to operate”.
- The new Article 5v places travel restrictions on certain Russian nationals, including diplomatic and consular personnel, wishing to travel to other EU Member States.
- With respect to trade-related sanctions, the EU has continued to wind back certain CN Codes in prohibited lists from 6 digits to 4 digits or even 2 digits, consequently making wider categories of goods banned for export to Russia. For instance, the range of codes beginning with CN 26 formerly listed for export bans under Annex XXIII have been amended so as to capture all products beginning with CN 26 (covering all “ores, slag and ash”).
- The new Annex XXIIIG contains a range of industrial-related goods which are now banned for export to Russia, subject to a grandfathering provision lasting until 25 January 2026 for contracts concluded before 24 October 2025.
- Several items have been added to Annex VII, which prohibits the export to Russia of certain advanced technologies.
- The EU has extended the time period for seeking licences under Article 12b to take steps, including the sale of items affected by trade sanctions, in aid of divesting or wind-down from Russia. The deadline for obtaining such licences has been reset to 31 December 2026. However, language in the new regulation’s preamble warns: “Russia is a country where the rule of law is no longer applied [and this] could lead to Union assets being stranded in Russia without the possibility for orderly withdrawal”. The EU accordingly “strongly advise[s]” EU operators “to wind-down businesses in Russia and not to start new businesses there”.
The 19th package also updates the EU’s sanctions on Belarus, as contained in Regulation 2006/765 (Regulation 765). Council Implementing Regulation (EU) 2025/2039 designates several new persons as asset-freeze targets, including the Chairman of the Belarusian State Concern for Oil and Chemistry. Council Regulation (EU) 2025/2041 generally updates Regulation 765 so as to align the sanctions against Belarus with those already imposed on Russia.
Recent UK Measures
On 15 October 2025, the UK placed asset-freeze sanctions on two major Russian oil companies — Rosneft and Lukoil — as well as several Chinese and Russian handlers of Russian oil. Similar to EU asset freezes, these sanctions affect any legal persons that these companies “own” (by more than 50%) or otherwise “control”. The UK concurrently released two “General Licences” relating to the Chinese/Indian entities and Rosneft and Lukoil, which broadly permit wind-down activities within a limited time period. On 22 October 2025, the UK released a General Licence permitting the “continuation of business” with certain German subsidiaries of Rosneft currently held in German trusteeship. All UK General Licences only apply subject to adherence with their conditions and typically contain expiration dates.
Separately, on 16 October 2025, the UK extended the time period for a general trade licence relating to certain “sectoral software and technology” banned for provision to persons connected with Russia earlier in 2025. As described in this Latham Client Alert, the general trade licence permits the continued provision of such software to “multinational clients headquartered outside of Russia”, where that software is provided pursuant to a contract “concluded for 23rd April 2025” and is “only for non-predominant use by a subsidiary established in Russia”. As with the licences above, multiple conditions must be met in order to rely on the licence. The licence now lasts until 17 April 2026.
What’s Next?
Latham & Watkins actively tracks sanctions developments across all regions closely and is well positioned to advise on the legal and practical impacts of these measures.
