On October 23, 2025, the European Union (“EU”) adopted its 19th Russia Sanctions Package,[1] targeting both Russian and non-Russian entities across the energy, finance, and military sectors. Significantly, the new measures provide greater legal certainty to operators by defining “ownership” and “control” under EU Regulation 269/2014.[2] The definitions confirm the position that was previously set out in EU non-binding guidance.[3]
On October 15, 2025, the UK designated 90 additional entities, including major Russian oil companies Lukoil and Rosneft and Chinese state-owned Beihai LNG terminal.[4] The UK Office of Financial Sanctions Implementation also issued a number of general licences (exemptions) that permit dealings with certain designated persons subject to certain conditions, including Rosneft’s German subsidiary (Rosneft Deutschland GmbH).[5]
Sanctions apply to designated persons, and extend to any entity “owned or controlled” (under EU or UK law, as applicable) by such persons.
Below are the key takeaways from the EU’s 19th Sanctions package and recent developments in the Court of Justice of the EU (“CJEU”):
- Imports of Russian LNG into the EU will be prohibited from January 1, 2027 for long-term contracts, and for short-term contracts six months after the sanctions enter into force (April 2026).
- Transaction ban on (i) five additional Russian banks (Istina, Zemsky Bank, Commercial Bank Absolut Bank, MTS Bank and Alfa-Bank); (ii) major Russian oil and gas companies (including Rosneft and Gazprom Neft); (iii) and Lukoil’s UAE subsidiary, Litasco Middle East DMCC.
- Transaction ban and related measures on entities that facilitate circumvention or provide substantial revenues to Russia, including entities in the energy and financial sectors based in China (including two refineries), Hong Kong, India, Thailand, the United States, and the UK.
- Prohibition on the use of the Russian National Payment Card System (Mir) and the Fast Payments System (SBP).
- Amendments to EU Regulation 269/2014 designed to provide greater legal certainty to operators by defining the notions of “owning”[6] and “controlling”[7] a legal person or entity, which were previously only set out in non-binding guidance.
- On September 25, 2025, Advocate General Richard de la Tour of the CJEU delivered a non-binding opinion in case C-465/24, SBK Art, on the interpretation of the notion of “freezing of funds” under EU Regulation 269/2014. He advised the CJEU to interpret that concept broadly, and, specifically, that the “freezing of funds” entails the freezing of voting rights and rights of participation at meetings of depository-receipt holders. A judgment is expected in early 2026.
In case C-802/24, Reibel, pending in the Grand Chamber of the CJEU, the court will interpret the scope of the so-called “no-claims” clause set out in Article 11 of EU Regulation 833/2014,[8] which protects EU operators against claims by sanctioned counterparties for non-performance of contracts affected by EU Regulation 833/2014, in particular (i) whether the settlement of disputes arising from such claims can be subject to arbitration proceedings; and; (ii) if so, whether national courts may review the substance of an arbitral award in light of EU Regulation 833/2014. The Advocate General will deliver its non-binding opinion on February 26, 2026, after which the CJEU is expected to deliver its judgment in mid- to late-2026.
[6] “Owning” a legal person, entity or body means being in possession of 50% or more of the proprietary rights of a legal person, entity or body, or having a majority interest therein.
[7] “Controlling” a legal person, entity or body means, but is not limited to: (i) having the right or exercising the power to appoint or remove a majority of the members of the administrative, management or supervisory body of a legal person, entity or body; (ii) having appointed solely as a result of the exercise of one’s voting rights a majority of the members of the administrative, management or supervisory bodies of a legal person, entity or body who have held office during the present and previous financial year; (iii) controlling alone, pursuant to an agreement with other shareholders in or members of a legal person, entity or body, a majority of shareholders’ or members’ voting rights in that legal person, entity or body; (iv) having the right to exercise a dominant influence over a legal person, entity or body, pursuant to an agreement entered into with that legal person, entity or body or to a provision in its memorandum or articles of association, where the law governing that legal person, entity or body permits its being subject to such agreement or provision; (v) having the power to, de facto, exercise the right to exercise a dominant influence referred to in point (iv), without being the holder of that right; (vi) having the right to use all or part of the assets of a legal person, entity or body; (vii) managing the business of a legal person, entity or body on a unified basis, while publishing consolidated accounts; or (viii) sharing jointly and severally the financial liabilities of a legal person, entity or body, or guaranteeing them.