EU tightens sanctions against Russia: LNG import ban from 2027

The EU Member States have agreed – in some respects more quickly than initially expected – on a new sanctions package against Russia. The corresponding amending regulations to Regulation (EU) No. 833/2014 and Regulation (EU) No. 269/2014 were adopted on October 23, 2025 and came into effect on October 24, 2025. In the following, we summarize the most important changes. Information on the 18th sanctions package is available here.

19th sanctions package against Russia: Measures targeting the energy sector

This sanctions package also targets the import of energy resources from the Russian Federation. From January 2027 onwards, no Russian LNG will be allowed to supply the EU. Additional legislative changes also affect the energy sector: the sanctioning of Russia’s so-called shadow fleet has been expanded to include additional vessels.

Furthermore, Russia’s revenues are to be restricted through sales bans on used Russian aircraft and ships.

Prohibition of investments in companies in special economic zones

Investments in companies located in listed Russian special economic zones are now prohibited. In these areas, it is also no longer permitted to establish or maintain joint ventures, new branches, or representative offices. In addition, no financial resources may be provided to companies established in these zones.

Additional restrictions in the services sector

Service bans relating to Russian companies and the Russian government have also been significantly expanded. Affected services include, among others, tourism services, as well as services related to high-performance and quantum computing, space-based services (e.g., satellite imagery), and artificial intelligence. Services that are not yet prohibited but are provided to the Russian government have, since the entry into force of the amending regulations, become subject to prior authorization.

Expansion of the lists of restricted goods

Finally, the lists of restricted goods, including Annexes VII and XXIII to Regulation (EU) No. 833/2014, have also been expanded. Export prohibitions under the relevant provisions now also apply to acyclic hydrocarbons and certain refractory ceramic products (HS codes 6902 and 6903). In addition, further individuals, organizations and entities – particularly banks – have been added to the sanctions lists.

Clarifications of terminology in Regulation (EU) No. 269/2014

With regard to the amendments to Regulation (EU) No. 269/2014, particular attention should be paid to the clarification of certain definitions. The definitions section of the Regulation specifies when a legal person, entity, or organization is owned by another, namely when at least 50 % of the ownership rights or a majority stake in it is held.  

In addition, the regulation clarifies when control over a legal person, entity or organization exists. Such control may exist, among other things, through:

• rights to appoint or remove members of an administrative, management or supervisory body;
• a controlling influence based on a contract, founding document, or articles of association;
• control over the majority of voting rights;
• rights to use all or part of the assets of the legal person, entity or organization;
• management on a unified basis with the preparation of consolidated financial statements; or
• joint and several liability for obligations or the provision of guarantees for the legal person, entity or organization. 

Regulation (EU) No. 269/2014 also contains so-called best-efforts obligations. According to these provisions, legal entities within the EU must ensure that third-country legal persons, entities or organizations owned or controlled by them do not participate in activities that undermine the Regulation’s restrictive measures. Similar obligations also exist in Regulation (EU) No. 833/2014 and Regulation (EU) No. 765/2006. However, these regulations do not contain explicit provisions defining when “control” within the meaning of these requirements exists.

EU companies should implement these requirements and closely monitor further developments, including potential short-term amendments.