Recent developments in the sanctions against Russia

Adopted on 23 October 2025, the EU's 19th sanctions package introduces 69 new designations and significantly strengthens measures across Russia's energy infrastructure, financial systems, and military-industrial complex. The package also targets individuals responsible for the forced deportation of Ukrainian children. The measures are set out in several regulations and decisions accessible in the Official Journal here.

Norway is expected to implement these sanctions into Norwegian law, consistent with its adoption of all previous EU sanctions packages. Below are some of the main measures adopted:

Energy measures

• An import ban on Russian liquefied natural gas (LNG) has been introduced meaning that it is prohibited to purchase, import, or transfer LNG that originates in Russia or is exported from Russia. The ban will be effective January 2027 (long-term contracts) and within six months (short-term contracts).

• Strengthened restrictions on state-owned oil producers Rosneft and Gazprom Neft.

• Sanctions imposed on Chinese entities: two refineries and one oil trader purchasing Russian crude oil.

• 117 additional vessels banned from EU ports and related maritime services, bringing the total to 557 vessels.

• New listings include Litasco Middle East DMCC (a prominent Lukoil shadow fleet enabler in the UAE) and maritime registries supporting shadow fleet vessels.

• Ban on reinsuring shadow fleet vessels to further disrupt Russia's oil transport networks.

Financial measures

• EU targets Russian state-backed stablecoin A7A5, reportedly used to finance the war in Ukraine. A7A5 operates as a digital currency pegged to stable assets, enabling cross-border transactions that bypass traditional banking systems and sanctions controls. Sanctioned entities include the A7A5 developer, Kyrgyz issuer, and trading platform. All EU transactions involving A7A5 are now banned.

• Transaction bans on 8 banks and oil traders from Tajikistan, Kyrgyzstan, UAE, and Hong Kong for facilitating sanctions evasion.

• Transaction bans on 5 additional Russian banks.

• Prohibition on engaging with Russia's Mir payment card system and Fast Payments System.

• Restrictions on economic relationships with entities in 9 Russian special economic zones.

Trade measures

• 45 new entities added to the sanctions list for enabling circumvention of export controls on technologies such as CNC machine tools, microelectronics, and UAV components. These entities will be subject to tighter export restrictions on dual-use goods and items that might contribute to the technological enhancement of Russia's defence sector. 17 entities are based outside Russia: 12 in China (and Hong Kong), 3 in India, and 2 in Thailand.

• Expanded export ban covering a wider range of materials.

• Ban on purchase, import, or transfer of all acyclic hydrocarbons, a key revenue source for Russia.

• Designation of Russia's largest gold producer, further constraining Moscow's access to foreign income.

Services

• Prior authorisation required for all services provided to the Russian government.

• New restrictions on AI services, high-performance computing, and space-based services offered to Russian entities, including the Russian government.

• Complete ban on EU operators providing services directly related to tourism activities in Russia.

Other measures

• Russian diplomats must inform relevant EU member states in advance when travelling across the Schengen area beyond their country of accreditation.

• Designations targeting businesspersons and entities forming part of the Russian military-industrial complex, and operators from UAE and China producing or supplying military and dual-use goods to Russia. Designations include a senior DPRK military commander deployed to Russia in support of the latter's invasion of Ukraine, and an individual responsible for inhumane treatment of Ukrainian prisoners of war.

• 11 additional individuals listed for involvement in deportation and forced transfer of nearly 20,000 Ukrainian children.

• Further restrictions imposed on Belarus as part of the package.

Russian frozen assets

Discussions continue regarding the proposed use of frozen Russian assets to secure sustainable funding for Ukraine. The EU has postponed the proposed €140 billion loan backed by frozen Russian assets, with several member states, in particular Belgium, warning of legal and financial risks. Commission President Ursula von der Leyen noted that whilst the EU has agreed on what to do, it still has to work on how to do it.

These legal complexities were examined in the master's thesis of Gad El-Brouch, an associate at Schjødt, written earlier this spring whilst holding the Schjødt scholarship. His thesis examined the legality of freezing and confiscating Russian central bank assets in order to support Ukraine. He argued that whilst state immunity remains a significant barrier, limited confiscation could be legally justified under international law – though not without potential risks to financial stability. With Danish Prime Minister Mette Frederiksen stating that a solution must be found before Christmas, this shows to remain a highly pressing issue for European policymakers.

On 15 October 2025, the UK Government announced its "strongest sanctions yet" against Russia to increase pressure over the war with Ukraine. The measures target not only Russian entities but also companies in third countries, including India and China, that continue to facilitate Russian oil reaching global markets. Below are some of the main measures announced:

Asset freeze

• 90 new designations targeting major Russian and foreign energy firms. Notable designations include state-owned Rosneft and Lukoil.

• Designations also target four Chinese oil terminals, 44 tankers in the shadow fleet transporting Russian oil, and Nayara Energy Limited – a Russian-owned refinery in India which imported $5 billion of Russian crude in 2024.

• OFSI published two general licences in connection with the new designations, allowing, among other things, wind-down transactions involving Rosneft and Lukoil until 28 November 2025.
  

Suppliers of electronics used in Russian drones and missiles

• UK is targeting suppliers of electronics used in Russian drones and missiles spanning Thailand, Singapore, Turkey, and China, tightening the net on Russia's military supply chains.

Moving towards a single UK sanctions list

• From January 2026, all UK sanctions designations will be merged into a single consolidated list to improve clarity and enforcement.

• The OFSI Consolidated List and its search tool will no longer be updated.

On October 22, 2025, the US increased pressure on Russia's energy sector by designating two major Russian state-owned oil companies – Rosneft and Lukoil – on the US SDN list. Oil and gas are Russia's biggest exports, and the two Russian oil firms export 3.1 million barrels of oil per day, according to UK Government estimates.

Additionally, all entities owned 50% or more by either Lukoil or Rosneft are blocked as a result of the new measures, even if not individually designated on the list. This significantly expands the scope of the designations to include numerous subsidiaries and affiliated entities worldwide.

Schjødt's corporate compliance team is experienced in all aspects of sanctions and export control-related matters, including risk assessments and associated review of projects, business partners and M&A-activities that may entail an increased sanctions risk. We have an extensive global network consisting of leading compliance and white-collar crime specialists and can efficiently include relevant local knowledge in our assistance.

Please note that these updates do not constitute legal advice, nor do they provide an exhaustive description of all sanctions in place and the exemptions. Any person or entity involved, directly or indirectly, in business activities in any way directly or indirectly related to Russia, Belarus or Ukraine should carefully assess how they are affected by the sanctions. Schjødt's team is ready to assist in this regard.