On 23 October 2025, the Council of the European Union adopted the 19th sanctions package against Russia, while simultaneously updating and tightening measures for Belarus. These additional restrictions are notable for their scale and focus – targeting the energy, transport, finance, and technology sectors, directly impacting the business environment in both Europe and Lithuania.
Key new measures and areas
The 19th sanctions package covers several strategic areas – from energy and transport to finance and technology. One of the most significant changes is the cessation of liquefied natural gas (LNG) imports from Russia to the EU. Transitional periods are provided for short-term contracts – the ban on Russian LNG imports into the EU will take effect on 25 April 2026.
Requirements for maritime transport have also been tightened to curb the so-called shadow fleet – vessels used to circumvent sanctions, re-registered in third countries, or linked to sanctioned operators. The new rules provide for stricter limits on insurance and port access for these vessels.
Perhaps the most interesting restrictions are found in the financial sector. This sanctions package introduces additional measures against intermediary banks in third countries and financial facilitators that help circumvent EU restrictions. The ban on transactions has been extended and applies to several banks and oil trading companies from the Republic of Tajikistan, the Kyrgyz Republic, the United Arab Emirates, and Hong Kong, as well as four banks from the Republic of Belarus and the Republic of Kazakhstan with links to Russia’s Financial Services Messaging System (SPFS) or other alternative payment infrastructures, such as “Mir” or the Faster Payments System (SBP). These restrictions will take effect from 25 January 2026, with a transitional period until 25 April 2026 for previously concluded transactions. For business, this means stricter control over settlements and credit risks, as well as the necessity to review cross-border payment chains.
Another important area involves crypto-asset service providers and electronic money operations. It is prohibited to provide crypto-asset and payment services, as well as to issue electronic money to Russian natural and legal persons, with payment service providers managing (servicing) the accounts being held responsible for compliance. The restrictions also apply to non-EU registered operators if their activities assist sanctioned entities. This forces the FINTECH sector to implement even stricter KYC (Know Your Customer) and transaction monitoring mechanisms to avoid indirect sanctions violations.
Entry into force and strengthening compliance in business practice
While most measures of the 19th sanctions package enter into force immediately upon publication, transitional periods have been set for some – particularly in the energy, transport, and trade sectors. These deadlines allow businesses time to renegotiate supply terms, assess risks of contractual obligations, and prepare updated compliance plans.
Under Lithuanian law, transactions that conflict with international sanctions are null and void, and if contracts were concluded before the sanctions took effect, their execution must be suspended or terminated. Therefore, companies should not limit themselves to a formal review of contracts – it is essential to evaluate the entire risk management system. This includes updating internal policies and control procedures related to customer and beneficial owner identification and verification, Money Laundering and Terrorist Financing (AML/CTF) risk assessment, international sanctions implementation, transaction monitoring, and data storage. Such actions are becoming necessary to ensure that business models remain compatible with the new EU sanctions regime.
In practice, such cases pose both reputational and financial risks. Consequently, companies are increasingly including sanctions compliance clauses in their contracts, which grant the right to suspend performance if one of the parties becomes subject to sanctions. This practice is becoming a new business standard, allowing for the reduction of legal uncertainty, protection of reputation, and avoidance of financial liability.
The era of sanctions – a new legal and business reality
The 19th EU sanctions package reinforces long-term elements of economic pressure on Russia. In addition to new personal asset freezes and trade restrictions, financial limitations are being expanded and additional measures are being introduced in the field of crypto-asset services. This practically changes the supply, settlement, and compliance practices of companies across the EU, while the measures adopted against Belarus further align the restrictive frameworks.
For Lithuania, as an EU member, this package signifies a further increase in responsibility – state institutions are tasked not only with ensuring compliance with sanctions but also with actively informing businesses about new requirements. Accordingly, businesses have a duty to review their risk management: update sanctions policies, strengthen partner vetting processes, and ensure that responsibility within the organisation is clearly allocated.
Prepared by Karolis Grižas and Arnas Sabalys, lawyers at the law firm Glimstedt.
