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