Posted: 19/11/2025
The European Union’s 19th sanctions package against Russia, adopted on 23 October 2025, represents a significant escalation in its efforts to disrupt Russia’s ability to finance and sustain its war against Ukraine. This package introduces targeted restrictions across energy, finance, trade, and services, with a particular emphasis on maritime enforcement and energy-related compliance. The measures aim to close existing loopholes, target circumvention strategies, and reinforce the EU’s commitment to sanctions enforcement.
The 19th package introduces several key provisions affecting the shipping industry, particularly those involved in transporting Russian oil and petroleum products. These include expanded vessel designations, reinsurance bans, and sanctions on maritime enablers.
Shadow fleet designations: the EU added 117 vessels to its list of designated ships suspected of circumventing sanctions, bringing the total to 557. These vessels are involved in deceptive shipping practices such as AIS manipulation and ship-to-ship transfers of Russian oil.
Reinsurance ban: vessels listed in annex XLII are now subject to a reinsurance ban, cutting off access to coverage from EU-based insurers and reinsurers. This impacts vessels entered with International Group P&I Clubs, which must comply with EU sanctions.
Maritime registries and enablers: the EU sanctioned maritime registries providing false flags to shadow fleet vessels, as well as Litasco Middle East DMCC, a key enabler of Lukoil’s shadow fleet operations based in the UAE.
Port container operators and shipbuilders: sanctions were imposed on the largest port container operator in the Russian Far East and a leading shipbuilder for Sovcomflot, further targeting Russia’s maritime logistics infrastructure.
The 19th package introduces sweeping measures targeting Russia’s energy exports, particularly liquefied natural gas and petroleum products. These measures are designed to reduce EU dependency on Russian energy and limit Russia’s revenue streams.
LNG ban: a full ban on imports of Russian LNG into the EU will take effect from 1 January 2027 for long-term contracts and within six months for short-term arrangements. This marks a strategic shift in EU energy policy and aligns with broader efforts to diversify energy sources.
Acyclic hydrocarbons: added to annex XXI, these are now prohibited due to their role in generating revenue for Russia.
Rosneft and Gazprom Neft: the EU eliminated exemptions for these major state-owned oil producers, tightening the transaction ban and restricting their ability to operate within the EU.
Third-country enablers: the EU sanctioned Chinese entities, including two refineries and an oil trader, for purchasing Russian crude oil and enabling revenue flows. This reflects a broader effort to target circumvention through third countries.
Owners, charterers, and financiers must conduct enhanced due diligence on counterparties and voyage routes. Particular attention should be paid to vessels engaging in ship-to-ship transfers or operating under flags of convenience. Insurers must verify that coverage does not extend to designated vessels or activities prohibited under EU law.
Operators should also be aware of the broader implications of ownership and control rules. Entities owned or controlled 50% or more by designated persons are considered sanctioned under EU law. This includes indirect control through corporate structures or beneficial ownership.
One must also consider the recent English High Court decision in EuroChem NW2 & Anor v Société Générale S.A. & Ors [2025] EWHC 1938 (Comm), which confirmed that EU sanctions may apply even in the absence of a direct listing, where control by a sanctioned individual is established. This precedent underscores the importance of a purposive interpretation of 'control' and highlights the need for rigorous legal review in sanctions compliance. Our detailed analysis of this case is available here.
How the EU will respond to this decision remains to be seen. As of now, the 19th sanctions package does not expand or amend the EU’s formal position vis-à-vis EuroChem.
The EU’s 19th sanctions package introduces robust measures aimed at disrupting Russia’s maritime logistics and energy exports. The designation of additional vessels, reinsurance bans, LNG import restrictions, and tighter controls on energy entities signal a tightening of enforcement and a shift toward targeting circumvention practices. Shipping and energy industry stakeholders must adapt to these changes by enhancing compliance protocols, reviewing contractual arrangements, and engaging with legal counsel to navigate the evolving regulatory landscape.
Further sanctions packages are anticipated, and operators should remain vigilant to updates in EU, UK, and US sanctions regimes. Proactive compliance and transparent engagement with regulators will be essential to mitigate legal and reputational risks.
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