EU adopts 19th sanctions package; UK and US target oil majors Lukoil and Rosneft

In this sanctions alert, we provide you with the key takeaways of the new measures imposed in the EU, UK and the US.

UK announces 90 additional asset freeze targets 

On 15 October 2025, the UK announced its "strongest sanctions yet" against Russia, announcing an additional 90 asset freeze targets. The new measures target energy revenues funding Russia's war of aggression. Notable designations include two of the worlds largest oil companies – Lukoil and Rosneft. According to the press release, Rosneft alone is responsible for nearly half of Russia's oil production. 

In addition to oil majors Rosneft and Lukoil, the new designations include other energy companies, such as four Chinese oil terminals and Indian Nayara Energy Limited, 51 tankers and LNG carriers, five Russian financial institutions and individuals and entities involved in the defence sector. OFSI published two general licenses in connection with the new designations, allowing among other things for wind down transactions involving Rosneft and Lukoil until 28 November 2025 (INT/2025/7538856 and INT/2025/753956).

Additionally, on 22 October 2025, OFSI published a General License (INT/2025/7598960) authorising business operations involving the Rosneft subsidiaries Rosneft Deutschland GmbH and RN Refining and Marketing GmbH. According to the OFSI's updated FAQs (no. 169) published at the same time, UK sanctions are not intended to negatively affect the operations of these entities, who have been under trusteeship by the German government since 2022. 

1. UK moving to a single list for sanctions designations 

As of 28 January 2026, the UK will move to a single list for sanctions designations, which could cause some practical adjustments for frequent users of the sanctions lists. Updates today published in the two existing platforms operated by the Foreign, Commonwealth and Development and OFSI will, as of 28 January 2026, only be published in the UK Sanctions List, meaning that the OFSI Consolidated List and its search tool will no longer be updated. 

More information on this change can be found here.

The US targets oil majors Lukoil and Rosneft 

Due to "Russia's lack of serious commitment to a peace process to end the war in Ukraine", the US increased pressure on Russia's energy sector by designating oil majors Lukoil and Rosneft on the US SDN list on 22 October. Several subsidiaries were also named on the SDN list, but all entities owned 50% or more by either Lukoil or Rosneft are blocked as a result of the new measures, even if not specifically designated on the list. 

OFAC simultaneously published four general licenses, among other things authorising wind-down transactions involving Lukoil and Rosneft into a blocked account until 21 November 2025. 

EU adopts the 19th package of sanctions 

Today, the EU published its 19th package of sanctions against Russia, introducing an additional 69 individual listings and numerous economic measures targeting key sectors fuelling Russia's illegal invasion of Ukraine, including energy, finance and the military industrial complex. Key measures include: 

Energy sector:

• Ban on Russian LNG imports into the EU from 1 January 2027 for long-term contracts and from 25 April 2026 for short-term contracts
• Tightened transaction ban on Rosneft and Gazprom Neft, and sanctions on Chinese entities including two refineries and an oil trader purchasing Russian crude oil
• 117 additional vessels subject to the port access ban, bringing the total to 557 designated shadow fleet vessels
• Ban on reinsuring shadow fleet vessels 

Financial measures: 

• Sanctions on Russian state-backed stablecoin A7A5, including its developer, with transactions prohibited across the EU
• Transaction bans on eight third country banks and oil traders and five Russian banks
• Prohibition on EU operators engaging with Russia's Mir payment card system and Fast Payments System

Other measures:

• Russian diplomats must inform relevant EU member states in advance when travelling across the Schengen area beyond their country of accreditation
• 11 additional individuals listed for involvement in the deportation and forced transfer of nearly 20,000 Ukrainian children
• Mandatory prior authorisation for services to the Russian government, restrictions on AI and high-performance computing services, and prohibition on tourism-related services in Russia
• Five new listings related to Belarus' military-industrial complex and Lukashenka regime

High Representative Kaja Kallas stated: 'It is becoming increasingly difficult for Putin to finance his war. Every euro we deny Russia is one it cannot spend on war. The 19th package will not be the last'.

EU Commission published updated FAQs 

In its continuous efforts to curb the Russia's oil revenues, the EU introduced a prohibition in article 3ma of Council Regulation 833/2014as part of the 18th sanctions package adopted earlier this year. Under article 3ma, it is prohibited, as of 21 January 2026, to import refined petroleum products obtained in a third country (except select partner countries) from Russian-origin crude oil. 

On 16 October, the EU Commission published interpretive guidance on the upcoming prohibition, including in particular due diligence expectations such as contractual clauses. The guidance also includes a list of countries that were net exporters of crude oil the previous calendar year, which benefit from a presumption that petroleum products have been obtained from domestic crude oil rather than Russian-origin crude oil.