On 23 October 2025, the Council of the European Union (“the Council”) adopted its 19th package of sanctions against Russia (“the 19th package”) in response to Russia’s war against Ukraine. The 19th package contains numerous economic measures targeting key sectors of the Russian economy including energy, finance and the military industrial complex. As part of the package, the Council also imposed further measures on Belarus to restrict the latter’s support for the Russian war effort.
The Council has adopted Council Decision (CFSP) 2025/2032 which amends Decision 2014/512/CFSP (the “Decision”) and Council Regulation (EU) 2025/2033 which amends Regulation (EU) No 833/2014 (the “Regulation“).
In this article, we have summarised the key points contained in the 19th package and which are particularly relevant to our clients in the financial services industry.
1. E-Money and Payment Services
The 19th package prohibits the issuing of e-money into Russia representing the first restrictions on payment and e-money services. However, the suspension of services to Russia on the SWIFT system enacted via previous sanctions packages had the effect of suspending these services in many cases.
These sanctions target EU e-money services and are aimed at Russian nationals and other natural persons residing in Russia as well as legal persons, entities or bodies established in Russia. The sanctions carve out an exception for EEA / Swiss nationals living in Russia and Russian nationals permitted to live in the EEA / Switzerland.
2. Crypto-Asset Services
The Council has placed particular emphasis on the prohibitions regarding crypto-asset services due to recent activity which has evidenced Russia’s increasing use of crypto-assets in circumventing sanctions[1]. Article 5b of the Regulation is amended to prohibit providing, directly or indirectly, the following services to Russian nationals or natural persons residing in Russia, or to legal persons, entities or bodies established in Russia:
- crypto-asset services (as defined under Regulation (EU) 2023/1114 on markets in crypto-assets (“MiCAR”));
- issuing of payment instruments, acquiring of payment transactions or payment initiation services; or
- issuing of electronic money.
Recital 19 of the Regulation clarifies that the ban does not extend to the execution of payment transactions per se and does not impose transaction-by-transaction nationality/residency checks on payment initiation providers or acquirers. Primary responsibility for compliance lies with the account-servicing payment service provider.
By way of derogation under Article 5c of the Regulation, the competent authorities may authorise the provision of the prohibited services if they determine it is necessary for the exclusive use of persons established in Russia that are owned by, or solely or jointly controlled by, a person which is incorporated in the EU or certain countries. Derogations are not automatic exemptions; individuals and entities must apply for prior authorisation from the relevant national competent authority, e.g. Central Bank of Ireland.
Previous sanctions prohibited the provision of “crypto-asset wallet, account or custody services” to Russian nationals or natural persons residing in Russia, or legal persons, entities or bodies established in Russia. When these previous crypto-assets sanctions were introduced, the European Commission’s frequently asked questions (“FAQs”) on the implementation of such sanctions made clear that it was permissible to convert crypto-assets into “fiat currency or another asset category that is not subject to sanctions.”[2] It remains to be seen what “other assets category” the crypto-asset may be converted into since e-money and payment instruments have now been banned and this was not clarified in the European Commission’s FAQs at the time of writing. At the time these previous sanctions were introduced, “crypto-asset wallet, account or custody services” were not defined terms in EU law as the sanctions pre-dated the application of MiCAR which took effect in December 2024.
The net effect of the crypto-asset sanctions introduced via the 19th package is to create a complete ban on the provision of all regulated crypto-asset services as now defined under MiCAR into Russia. It remains to be seen whether or not there will be an exception to the ban to allow crypto-assets be converted into fiat and returned to the affected customers as the European Commission’s FAQ document has not yet been updated to clarify this point.
3. Banking and other financial sector restrictions
The 19th package adds five further Russian banks to the EU’s transaction ban list under Article 5h of the Regulation from 12 November 2025, namely (i) ‘NPO “Istina” (JSC); (ii) LLC “Zemsky Bank”; (iii) Commercial Bank Absolut Bank (PAO); (iv) PJSC “MTS Bank”; and (v) JSC “ALFA-BANK”. The prohibitions also extend to eight financial institutions and oil traders located in Tajikistan, Kyrgyzstan, the UAE, and Hong Kong, all of which were found by the Council to have facilitated the circumvention of EU sanctions. In addition, four banks in Belarus and Kazakhstan have been designated because of their use of Russian payment infrastructures.
The Council introduced several exemptions allowing transactions with listed banks in Annex XIV, notably when they are necessary for export or transport of pharmaceutical, medical or agricultural products, for humanitarian purposes, for the reception of certain payments due by the entities listed in Part A of Annex XIX, etc..
From 25 January 2026, the EU will prohibit any EU entities from connecting to any systems of the Central Bank of Russia or incorporated under Russian law that have a financial messaging functionality, including Russian National Payment Card System (‘Mir’) or the Fast Payments System (‘SBP’).
In line with the Council’s emphasis on crypto-related sanctions, the 19th package introduces a prohibition on EU persons engaging, directly or indirectly, in any transaction with the crypto-assets listed in Annex LIII (which currently lists A7A5, a rouble-backed stablecoin), from 25 November 2025.
4. Insurance and Re-insurance
The 19th package introduces additional measures prohibiting the provision of financing and financial assistance, including insurance, reinsurance and brokering services to designated vessels.[3]
Article 5u of the Regulation imposes a five-year bar on reinsuring vessels or aircraft that were operated by the Russian Government or Russian-established entities after their sale or lease.
5. Technology
From 25 November 2025, the EU will prohibit the provision of certain software related to artificial intelligence services, high-performance computing and quantum computing services to the Government of Russia as well as legal persons, entities or bodies established in Russia, and the prohibition has now been extended to the government of Belarus or entities established in Belarus.
6. Overall Assessment
The 19th package represents the EU’s continuing efforts to intensify pressure on Russia by disrupting its war capabilities and restricting the Russian economy. By addressing the provision of e-money, payment and crypto-asset services, the EU aims to close loopholes that enable Russia to develop its own financial infrastructure and possibly circumvent sanctions and which reinforce the integrity of the EU’s financial sanctions framework. While EU leaders are optimistic about these measures, practical considerations, such as the borderless and digital nature of crypto-assets, make it difficult to enforce. Speaking at a press conference regarding the 19th package, Kaja Kallas, the High Representative for Foreign Affairs and Security Policy and chair of the Foreign Affairs Council, made it clear that the EU remains steadfast in its commitments to sanction Russia, confirming that the19th package will not be the last.
We are continuing to keep a close eye on developments in this area and will publish further updates as matters progress. For further information on the 19th package and sanctions more generally please contact Joe Beashel, Ian O’Mara, Denise Brady or your usual Matheson contact.
This article is provided for general information purposes only and does not purport to cover every aspect of the themes and subject matter discussed, nor is it intended to provide, and does not constitute or comprise, legal or any other advice on any particular matter.
[1] Reuters: Russian regulator encourages use of crypto to counter sanctions (3 July 2024).
[2] Consolidated version of the frequently asked questions concerning Russian sanctions (29 October 2025).
[3] Annex XLII of the Regulation was updated by the 19th package to include vessels that transport certain crude oil, petroleum or mineral products that originate in Russia or are exported from Russia.