EU 19th package : a severe reinforcement of the sanctions

On 23 October 2025, the EU adopted its 19th package of sanctions against Russia and Belarus which deepens the existing framework and extends its enforcement beyond the Union’s borders, targeting third-country operators, crypto platforms, and service providers facilitating Russia’s war economy.

Announced by President von der Leyen in Copenhagen in September 2025, this new package confirms a shift towards a more extraterritorial application of EU restrictive measures, bringing under the scope of enforcement non-EU actors contributing, directly or indirectly, to Russia’s war of aggression against Ukraine.

With 69 new listings, 117 additional vessels, and expanded enforcement powers over third-country networks, the 19th package represents one of the EU’s most comprehensive sanctions updates to date .

Key regulations include: Regulation (EU) 2025/2037, Regulation (EU) 2025/2033 and Implementing regulation (EU) 2025/2035.

For more information, please contact:

Bruno Lebrun – Partner – b.lebrun@janson.be

Cédric Alter – Partner – c.alter@janson.be