Sanctions against Russia:
19th Package of Sanctions by the European Union – Authorization Requirement for Services not prohibited

Image: © Feydzhet ShabanovFeydzhet Shabanov – stock.adobe.com

On 23 October 2025, the Council of the European Union adopted its 19th package of sanctions against Russia.

Amended EU Regulations

  1. Regulation (EU) No. 833/2014 concerning restrictive measures in view of Russia's actions destabilizing the situation in Ukraine (by Regulation (EU) 2025/2033, OJ L 2025/2033, October 23, 2025);
  2. Regulation (EU) No. 269/2014 concerning restrictive measures in view of actions undermining or threatening the territorial integrity, sovereignty, and independence of Ukraine (by Regulation (EU) 2025/2037, OJ L 2025/2037);
  3. Regulation (EC) No. 765/2006 concerning restrictive measures in view of the situation in Belarus and Belarus' participation in Russia's aggression against Ukraine (by Regulation (EU) 2025/2041, OJ L 2025/2041).

Authorization Requirement

The scope of the ban on the provision of WP/vBP services remains unchanged. However, a new requirement is that in future, any provision of services that is not prohibited under the above-mentioned regulations will require prior approval from the competent authority. This is intended to reduce the risk of a service contributing to Russia's military, technological, or industrial capabilities.

This also affects previously permissible WP/vBP services, which may no longer be provided without prior approval (Art. 5n (4) of Regulation (EU) 833/2024, Art. 1jc (5a) of Regulation (EU) 765/2006).

Exception

This does not apply to the performance of contracts concluded before 24 October, 2025, until 1 January, 2026, or to ancillary contracts necessary for their performance (Art. 5n (8c) of Regulation (EU) 833/2014, Art. 1jc (10b) of Regulation (EU) 765/2006).

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