Taking Stock of the EU Sanctions on Russia

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Jan Dunin-Wasowicz is a member of the Paris and New York Bars. He is co-founder of Bennink Dunin-Wasowicz, a law firm based in Paris and Amsterdam specialising in economic sanctions and export controls. A lecturer at the Sciences Po Law School, he hosts the podcast dedicated to EU sanctions ‘This Month in EU Sanctions’.

On 23 October 2025, the Council of the EU adopted a 19th package of sanctions against Russia and similar measures against Belarus. What are the main lessons to be learned from this package almost four years after the start of Russia’s war of aggression against Ukraine?

A Wide-Ranging Sanctions Package

Announced in August 2025, the 19th package aims to increase the pressure on the Russian war economy. It targets the key sectors fuelling this war, notably energy and finance, as well as the military industrial base. The 19th package includes the following measures:

• Energy: a ban on imports of Russian liquefied natural gas (LNG) into the EU, tighter restrictions on Rosneft and Gazprom Neft, the shadow oil fleet and energy revenue providers.
• Finance: addition of five new Russian banks to the list of entities covered by the transaction ban, ban on the use of Russian payment card and rapid payment systems (Mir and SBP), restrictions on cryptoassets, in particular the A7A5 stablecoin, and entities operating in Russia’s creatinespecial economic zones.
• Military-industrial complex: designation of persons and entities forming part of the Russian military-industrial complex, as well as operators producing military and dual-use goods or supplying them to Russia, new goods subject to the export ban.

An essential part of the war economy and the strategy for circumventing sanctions, the Russian shadow fleet now poses risks for the EU in terms of hybrid warfare.

Since the last two sanctions packages in particular, the emphasis has been on cracking down on this fleet and associated services. With the 19th package, 117 additional ships are banned from accessing ports and maritime transport services.

The package also targets the phantom fleet’s value chain, designating a subsidiary of Lukoil, based in the United Arab Emirates, as an essential component of its phantom fleet, as well as false flag shipping registers registered in Texas and the United Kingdom attributed to vessels in this fleet.

Impact On Third Countries

The 19th package includes several individuals and entities targeted by the sanctions and based outside Russia, including Chinese refineries, Belarusian banks, Hong Kong and UAE oil traders, a stablecoin issuer based in Kyrgyzstan, and Chinese, Thai and Indian companies that support the Russian military-industrial complex. The Council now also has the option of targeting ports in third countries.

Coordination With The United States Is Uncertain

The Trump administration has been extremely unpredictable when it comes to sanctions against Russia.

Having sometimes suggested that the measures introduced by the Biden presidency would remain in place, it has also announced that they could be relaxed or lifted before resorting to customs duties, particularly against India, to encourage it to reduce its purchases of Russian hydrocarbons.

On the eve of the adoption of the 19th package, the OFAC (Office of Foreign Assets Control) announced US sanctions against Rosneft and Lukoil and other associated companies, noting a lack of serious commitment to a peace process aimed at ending the war in Ukraine. The EU will have adopted three sets of sanctions by 2025 (16th-18th) before seeing joint action with the US.

At the end of November, much to the surprise of the Europeans, the United States presented a peace plan providing for a reduction in sanctions and a distribution of frozen Russian assets in funds earmarked for the reconstruction of Ukraine, with part of the profits going to the United States.

The impression of renewed coordination around the 19th package could only be an exception. However, a joint statement by the G7 foreign ministers on 12 November 2025 underlines a commitment to strengthening G7 coordination on sanctions.

Long Term Policy & Short Term Goals

As noted in the Council’s decision of 21 May 2024, the measures relating to the management of the assets and reserves of the Central Bank of Russia should remain in force “until Russia puts an end to its war of aggression against Ukraine and compensates Ukraine for the damage caused by that war”.

Discussions on the reparations loan, which would be financed by Russian assets tied up in the EU, have not yet been concluded. The European Council on 18 and 19 December 2025 will return to the issue, especially as the American proposal could weaken the leverage that these assets represent for the EU.

However, with Russia’s attacks continuing unabated, the EU will no doubt continue to step up the pressure on Russia. This was confirmed by the High Representative on 26 November in the margins of an informal meeting of EU foreign ministers. In parallel with the discussions on the reparations loan, as the Danish Presidency of the Council of the EU enters its final weeks, a 20th set of sanctions is said to be in the pipeline.

If it is adopted before the end of the year, it would be the 5th of a singular year. In addition, the fight against the circumvention of EU sanctions and the financing and facilitation of the Russian war effort by third parties will remain a priority

FROZEN ASSETS • Belgium is still saying no to the plan for a Ukraine reparations loan backed by frozen Russian assets.

210 billion euros of Russian assets are currently frozen in the EU, including roughly 185 billion euros held at Euroclear in Brussels. These assets could serve as collateral for a planned 140 billion euros loan to help keep Ukraine’s finances afloat for the next two years — a plan supported by the European Commission and most Member States, but that has garnered strong opposition from Belgium.

In a letter to Ursula von der Leyen seen by the FT, Prime Minister Bart De Wever argues that moving too quickly on this scheme could make it harder to reach a future peace agreement with Russia.

He makes Belgian support conditional on “legally binding, unconditional, irrevocable, on-demand, joint and several guarantees” for Euroclear’s exposure. He wants other Member States to share any legal and financial risks and for frozen Russian assets located elsewhere in the EU to be used.

This stance clashes with von der Leyen’s message to the European Parliament that the Commission is ready to present a legal text for the loan soon.

According to a separate letter also seen by the FT, Euroclear has separately warned the Commission that the plan could be viewed abroad as confiscation, harming Europe’s investment climate and pushing up sovereign borrowing costs.​

European heads of state or government hope to finalize a deal during this year’s last European Council which will take place on December 18.

NON TARIFF BARRIERS • The IMF’s estimate that the EU’s non-tariff internal barriers are equivalent to a 45% tariff on goods — which has been quoted by none other than Mario Draghi and Ursula von der Leyen — might be greatly overestimated, the Center for Economic Policy and Research (CEPR) argues in a recent column.

The author’s reanalysis shows that the number is highly sensitive to dataset choice, sectoral aggregation, distance metrics, and econometric specification, and can vary substantially across plausible methods.

Crucially, when non-policy factors such as social networks, cultural preferences, and consumer tastes are accounted for, much of the apparent trade barrier disappears, the authors argue.

Many of the remaining frictions are structural rather than regulatory, meaning they cannot realistically be removed through policy.

SAME SEX MARRIAGE • On 25 November 2025, the European Court of Justice ruled that Member States must recognize same sex marriage lawfully concluded in other Member States.

Not doing so would result in a breach of the freedom to move and reside: two persons who “create a family life in a host Member State, in particular by virtue of marriage (...) must have the certainty to be able to pursue that family life upon returning to their Member State of origin”, the Court ruled.

It would also infringe the fundamental right to respect for private and family life.

However, the ruling “does not undermine the national identity or pose a threat to the public policy of the spouses’ Member State of origin”, as it only establishes an obligation to recognize same sex marriage lawfully concluded in other Member States, not to provide for same sex marriage.

OMNIBUS • The European Ombudsman issued a non-binding recommendation criticizing how the Commission applied its own rules (under the Better Regulation guidelines) when preparing several “urgent” legislative proposals, including Omnibus I, which amends the CSRD and CS3D.

The recommendation identifies a series of procedural shortcomings that could amount to maladministration, notably the Commission’s broad reading of “urgency” to sidestep impact assessments and public consultations.

Earlier last month, around 100 law professors and lawyers sent a letter to the European Parliament warning that Omnibus I may infringe fundamental principles of EU law.

EU-UK RELATIONS • Talks between the EU and the UK on British association to the SAFE defence loans scheme have ended without agreement, after negotiations launched in September alongside Canada failed to close a gap over London’s financial contribution.

The European Commission had asked the UK to pay several billions of euros, with initial figures between roughly 4 and 6.7 billion euros and an additional administrative fee linked to expected benefits, while the UK’s offers remained far lower.​

In the absence of a deal, UK defence firms retain third‑country status and are limited to providing up to 35% of the component cost of SAFE‑funded equipment.

British EU minister Nick Thomas‑Symonds called the outcome “disappointing” but insisted that the UK will only sign agreements that meet national‑interest and value‑for‑money tests, while the Commission stresses that SAFE remains structurally open and that negotiations could resume in future rounds.

• The FT describes how red tape is hampering the EU’s effort to support the multibillion Innovation Fund, with average administrative costs of 85,000 euros to apply for grants.