Towards the 19th Sanctions Package – EU sanctions update for Summer 2025

Insights|October 6, 2025

In a continued effort to confront Russia’s ongoing aggression against Ukraine, the EU adopted its 17th and 18th sanctions packages in quick succession in summer 2025. These packages expanded the scope and intensity of restrictive measures across the military, energy and financial sectors. The 19th package was just announced on 19 September 2025, with the details to follow.

The EU adopted its 17th sanctions package on 20 May 2025. This package aimed primarily at cutting Russia’s access to advanced military technologies critical for its war efforts, while also further restricting its energy revenues – one of Russia’s main financial lifelines. It included tighter export controls on dual-use goods and technology, as well as restrictions on key sectors supplying Russia’s defense industry.

On 18 July 2025, less than two months after the 17th package was introduced, the EU adopted its 18th sanctions package. The new measures focused on five building blocks: cutting Russia’s energy revenues, hitting Russia’s banking sector, further weakening Russia’s military-industrial complex, strengthening anti-circumvention measures, and holding Russia accountable for its crimes against Ukrainian children and cultural heritage.

The 19th sanctions package was announced on 19 September. It is expected to focus on energy, additional financial transaction bans and new export restrictions for items and technologies used on the battlefield.

In addition, the EU is expected to continue its efforts to target third-country actors – both companies and individuals – who facilitate the circumvention of sanctions through trade, logistics, or financial channels. This reflects a growing emphasis on cutting off global enablers of Russia’s war economy.

EU Commission targets 18 Member States over delays in implementing Sanctions Crimes Directive

In July 2025, the Commission also initiated infringement proceedings and sent formal letters of notice to a total of 18 Member States that had either failed to provide sufficient information on the transposition of the EU Sanctions Crime Directive or had not yet applied the directive’s requirements to their national legislation.

This wave of infringement proceedings highlights the EU’s increasing focus on the uniform enforcement of sanctions, particularly in response to circumvention relating to Russia. The delayed transposition by major Member States like Germany, France and Italy raises concerns about fragmented legal approaches that could weaken the overall effectiveness of the EU’s restrictive measures.

Russian developments

In Russia, the Murmansk Regional Court refused to recognize an ICC arbitration award, stating that the tribunal’s decision was based on EU sanctions against Russian entities and was rendered by arbitrators from “unfriendly states.” The court held that reference to EU sanctions alone was sufficient grounds for refusal.

This sets a precedent and, going forward, Russian courts may refuse to recognize any foreign arbitration awards or judgments that mention sanctions against Russian parties. The case also reflects a broader trend in Russian law: growing interference by the Prosecutor’s Office in private arbitration disputes related to sanctions, even when Russia’s interests are only indirectly involved.

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The list below summarizes the key changes introduced by the 17th and 18th sanctions packages.

Energy measures

  • Lowering the Oil Price Cap for crude oil from USD 60 to 47.6, and introducing an automatic and dynamic mechanism for its review in the future. The new system will ensure that the cap is always 15% lower than the average market price for Urals crude in the previous six-month period.
  • Complementing this effort, the EU has imposed individual sanctions targeting those enabling the operation of the shadow fleet and those engaging in dangerous practices at sea while transporting Russian oil. These individual sanctions cover both Russian and third-country shipping companies, including those from the United Arab Emirates, Turkey and Hong Kong.
  • Transaction ban for Nord Stream 1 and 2: This means that no EU operator can engage in any transactions relating to the Nord Stream pipelines.
  • Import ban on refined oil products derived from Russian crude oil. This means a clampdown on refined product imports made from Russian crude that are processed abroad and delivered to the EU.
  • A total of 444 vessels in Russia’s shadow fleet are now listed by the EU.
  • Comprehensive listings, including asset freezes and travel bans, have been imposed across the entire shadow fleet value chain. These measures target Russian and international individuals and entities managing shadow fleet vessels and trading Russian crude oil, as well as one key buyer: an Indian refinery majority-owned by Rosneft.

Financial measures

  • Transforming the ban on providing specialized financial messaging services to certain Russian banks into a full transaction ban. This means that EU firms are banned from doing any business with the listed entities, including providing specialized messaging services.
  • Adding another 22 Russian banksto this transaction and messaging ban, bringing the total to 45.
  • Broadening the transaction ban to include third-country financial operators, including crypto-asset providers who help circumvent sanctions, support Russia’s war of aggression against Ukraine, or are connected to Russia’s financial messaging service. EU operators are banned from carrying out transactions with any of these financial operators.
  • New transaction ban targeting the Russian Direct Investment Fund (RDIF), its subsidiaries, its investments and the financial institutions supporting them. The new measures prohibit any engagement with legal persons, entities or bodies in which the RDIF holds any ownership or investments.
  • Ban on the provision of certain banking software.The prohibition on providing services and software to the Russian government and Russian companies will now include key types of banking software.

Trade measures

  • The 17th and 18th packages included an additional 57 companies which provide direct or indirect support to Russia’s military-industrial complex. These companies are subject to tighter export restrictions concerning dual use goods and technologies. They include both Russian and third-country actors, encompassing entities in China / Hong Kong, Uzbekistan, the United Arab Emirates, Serbia, Vietnam and Turkey.
  • The 18th package expands export restrictions to further disrupt and weaken Russia’s military-industrial complex. These included restrictions on additional advanced technologies and further export bans corresponding to almost EUR 2.1 billion of exports in 2024 terms.

Targeting Russia’s military capabilities and supply chains

  • The 17th and 18th packages contain 130 additional asset freeze listings. These listings target the military-industrial complex with a view to curbing Russia’s military capabilities.

Measures to protect Member States from arbitration

  • Introduction of protective restrictions concerning investor-to-state dispute settlement (ISDS). These new measures address the risk of economic damage from investment arbitrations launched by listed individuals in relation to EU sanctions. The measures provide further protection for Member States from sanctions-related claims under their bilateral investment treaties (BITs). This includes the possibility for Member States to recover any damages incurred as a consequence of investor-to-state dispute settlement proceedings brought against them.