- The package bans imports of Russian liquefied natural gas, in stages up to 2027.
- It adds 117 more vessels to the shadow-fleet list and removes exemptions for two Russian oil companies.
- Companies with energy business or dealings with third countries should strengthen compliance.
On 23 October 2025 the European Union formally adopted its 19th package of sanctions against Russia, after the Twenty-Seven gave their approval, which came once Slovakia lifted its block. European sanctions require unanimity, so a single member state can delay approval. The package includes a ban on imports of Russian liquefied natural gas (LNG), one of the most anticipated measures.
The LNG ban will apply in two phases: short-term contracts will end after six months, from 25 April 2026, and supply contracts of more than one year signed before 17 June 2025 will be banned from 1 January 2027. That date brings forward by a year the Commission’s roadmap for leaving Russian fossil fuels behind.
What the package includes
Besides LNG, the package removes the remaining exemptions for the oil companies Rosneft and Gazprom Neft and extends the lists of the so-called shadow fleet, the tankers that carry Russian crude while evading controls: 117 vessels are added, for a total of 558. It also includes travel restrictions for Russian diplomats, which reinforces the political side of the measure. These measures aim to cut the income Russia obtains from energy and to hinder the routes used to evade earlier sanctions.
European sanctions take the form of regulations that apply directly to companies and persons in the Union. They prohibit dealing with the listed entities, freeze their assets and limit certain exports, services and financing. Their effects also reach anyone dealing with third countries that serve as a bridge for sanctioned goods or services. Breaching them can have consequences for the company and for its directors, so internal control is a matter of corporate governance.
What it means for energy
The LNG measure affects a specific but relevant market: European countries that buy Russian liquefied gas under term contracts, and companies that depend on that supply or on its prices. The same week, the United States announced sanctions on the Russian oil companies Rosneft and Lukoil, which adds pressure on Russian energy trade and may move oil and gas prices. The effects on Spanish companies will depend on how much Russian gas they buy, directly or indirectly, and on how they replace that supply.
For industry and families, the consequence is indirect: decisions on the origin of gas and diversification of suppliers influence energy prices and cost planning. The staged calendar gives markets time to adapt, but it is worth remembering that diversification has a cost and that not every contract can be replaced equally fast.
What to review
Companies should check that their sanctions controls are up to date: screen customers, suppliers, intermediaries and beneficial owners against the lists, and make sure contracts include compliance and sanctions-termination clauses. This is especially important in operations with third countries and in energy, financial and logistics supply chains.
Sanctions change often and the consequences of breaching them can be criminal and reputational. This note is general information and does not replace the analysis of specific operations: if in doubt, consult your legal adviser before closing a deal with a third party that may have links to Russia. A good starting point is to appoint someone responsible for following developments and for periodically checking the sanctions lists.
In sanctions, the risk lies not in the rule that is known, but in the operation that has not been reviewed.
This article is general information. It is not legal, tax or investment advice, and it does not take anyone’s particular circumstances into account.
