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The EU’s 19th Sanctions Package: A Strategic Offensive Against the Kremlin’s War Machine

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Ukrainian President Volodymyr Zelenskyy is seen on a giant screen as he speaks during the European Political Community summit, in Copenhagen, Thursday, Oct. 2, 2025. Source: AP.
Ukrainian President Volodymyr Zelenskyy is seen on a giant screen as he speaks during the European Political Community summit, in Copenhagen, Thursday, Oct. 2, 2025. Source: AP.

The EU’s new, 19th sanctions package marks a decisive evolution in the West’s strategy — from broad economic pressure to surgical strikes against the arteries sustaining Russia’s war machine. This is no longer diplomacy by other means, but a full-fledged economic offensive.

Energy Sanctions: From Cutting Revenues to Strategic Strangulation of Russia’s War Economy

Brussels is shifting from broad pressure to surgical attrition, targeting the Kremlin’s energy superprofits, financial loopholes, and technological gaps.

The energy sector remains the primary source of funding for Russia’s war machine, and the 19th sanctions package is aimed at systematically cutting off these financial flows, moving from simple restrictions to strategic blocking of key channels.

The centerpiece of the new package is a proposal for a complete ban on imports of Russian liquefied natural gas (LNG) to EU markets, with a full phase-out accelerated to January 1, 2027, a year earlier than initially planned. This move is a direct response to Russia’s ongoing aggression, including violations of EU airspace by Russian drones in Poland and Romania. European Commission President Ursula von der Leyen called this moment a time to “turn off the tap.” The European Union assures that it is prepared for this step, having diversified its supplies and invested in alternative energy sources. Although in 2024 Russia still supplied 19% of the EU’s gas (compared to 45% before the full-scale invasion), this measure targets one of the key revenue streams still available. The main importers of Russian LNG in the EU are Spain, Belgium, the Netherlands, and France.

The package includes lowering the G7-imposed price cap on crude oil from the previous $60 to a more aggressive level of $47.60 per barrel. This figure is significant, as it aligns with the level set in the EU’s 18th sanctions package, signaling a tougher G7 stance aimed at keeping the price cap significantly below market prices and closer to Russia’s estimated production cost (approximately $15 per barrel). The goal of this measure is to directly reduce the Kremlin’s profit from every barrel sold.

To enforce the price cap and oil embargo, the EU is imposing sanctions on an additional 118 vessels from Russia’s so-called “shadow fleet.” As a result, the total number of vessels under EU sanctions exceeds 560. This is a direct attempt to paralyze the logistics of sanctions evasion, as these outdated, poorly insured tankers are Russia’s primary tool for selling oil outside the price cap regime.

The package introduces a complete ban on transactions with Russian energy giants Rosneft and Gazpromneft, eliminating previous exemptions. This intensifies pressure, moving beyond earlier measures like disconnection from SWIFT to a comprehensive ban on any operations, aiming to fully isolate them from Western financial systems.

For the first time with such explicit focus, the package targets entities in third countries that facilitate sanctions evasion. This includes oil refineries, oil traders, and petrochemical companies in countries like China that purchase Russian oil in violation of the price cap. This signals a shift toward applying secondary sanctions to deter non-Western actors from supporting Russia’s war economy.

Closing Financial Loopholes: A New Front in Sanctions Enforcement

The 19th package marks a strategic pivot toward combating the innovative methods Russia uses to bypass financial restrictions.

In a landmark move, the 19th package introduces the EU’s first-ever restrictive measures targeting cryptocurrency platforms. The sanctions ban cryptocurrency transactions, aiming to cut off a key channel Russia uses for sanctions evasion, money laundering, and funding its military-industrial complex.

The sanctions extend beyond SWIFT and target Russia’s alternative, the Financial Messaging System (SPFS). The package includes measures against foreign banks in third countries connected to SPFS. This is a critical step to prevent Russia from creating a resilient, non-Western financial architecture for sanctions evasion.

The package imposes a complete ban on transactions with additional Russian banks and financial institutions in third countries that facilitate sanctions evasion. This deepens the financial isolation of the Russian economy.

The measures include restrictions on transactions with legal entities in Russian special economic zones (SEZs), which have been identified as loopholes for importing dual-use goods for military purposes.

How to Accelerate the Degradation the Military-Industrial Complex: A Technological and Logistical Offensive

The restrictions target not only financing but also Russia’s technological capacity to produce modern weaponry.

New direct restrictions are introduced on the export of goods and technologies used on the battlefield. This includes limiting Russia’s access to technologies such as artificial intelligence (AI) and geospatial data, which are critical for modern warfare and weapons production. Particular attention is given to technologies related to drones.

The package adds 45 new companies in Russia and third countries, including China and India, to sanctions lists for providing direct or indirect support to Russia’s military-industrial complex. This expands the application of secondary sanctions to entities actively supporting Russia’s war machine.

The “Reparative Loan” Initiative Could Strengthen Ukraine’s Defense

While not a sanction against Russia per se, the package is presented alongside a new G7-led initiative to use profits (“extraordinary revenues”) from frozen Russian sovereign assets to provide Ukraine with a “Reparative Loan.” This loan will support Ukraine’s defense, with Ukraine obligated to repay it only after Russia pays reparations. This move aims to make Russia pay for the war without touching the principal of frozen assets, bypassing complex legal issues while providing tangible support to Kyiv.

The West’s sanctions regime demonstrates clear evolution. If earlier packages aimed to create broad economic shock and punishment, the 19th package is far more targeted and operational. It focuses on specific mechanisms of resilience and evasion that Russia developed in response to previous restrictions. Initial sanctions were largely reactive. In response, Russia adapted, creating infrastructure for evasion: a “shadow fleet” for oil exports, an alternative to SWIFT in the form of SPFS, and using new financial tools like cryptocurrencies. The 19th package targets not new sectors but these very adaptation mechanisms, representing a counter-adaptation by the West. This indicates that Western policymakers now view sanctions not as a diplomatic tool to coerce behavioral change but as a direct instrument of economic warfare designed to degrade the adversary’s ability to wage war over the long term. The language used by von der Leyen and Kaja Kallas – “weaken Russia’s war economy,” “hit where Russia makes money,” “make its aggressive war unsustainable” – confirms this military logic.

Moreover, the focus on LNG is not just about gas revenues; it is a direct attack on Russia’s flagship strategic projects, such as Arctic LNG 2 and Murmansk LNG, which are symbols of its pivot to the East and critically depend on Western and allied technologies. Russia’s future energy strategy heavily relies on Arctic LNG projects. These projects require highly specialized Arc7 ice-class LNG tankers for economic viability. Russia has extremely limited domestic capacity to build such vessels at its Zvezda shipbuilding complex, which itself relies on foreign technologies and components (e.g., French GTT membranes). The world’s dominant builders of these complex vessels are South Korean companies (Hanwha Ocean, Samsung Heavy Industries). By banning LNG imports, the EU creates market uncertainty. More importantly, by sanctioning the projects themselves and related companies, the West makes it impossible for South Korean shipyards to deliver contracted vessels without risking secondary sanctions. Thus, the LNG ban is a key element that disrupts Russia’s entire Arctic strategy, turning multibillion-dollar investments into stranded assets and demonstrating that Russia cannot technologically decouple from the West, even while attempting to do so economically.

Impact Assessment: How to Measure the “Pain” for the Russian Federation

The combination of a lower oil price cap ($47.60 per barrel) and the impending LNG ban will directly strike at Russia’s primary revenue source. EU officials state that existing sanctions have already reduced Russia’s oil revenues in Europe by 90% over three years. This package aims to close the remaining gaps. The resilience of Russia’s federal budget, which has shifted to massive military spending (projected at 6.2% of GDP in 2025), is under direct threat.

While Russia has shown resilience by relying on its National Wealth Fund and transitioning to a war economy, the erosion of its core revenue base will become increasingly unsustainable. The fiscal deficit is already growing, and this package will accelerate this trend, forcing difficult choices between military spending, social stability, and macroeconomic control.

The sanctions are designed to “kill” projects like Arctic LNG 2. The lack of specialized Arc7 ice-class tankers due to canceled contracts with South Korean shipyards and the inability of Russia’s domestic Zvezda shipbuilding complex to meet demand effectively leaves gas “locked” in the Arctic. This not only deprives Russia of future revenues but also undermines its entire strategy to become a leading global LNG exporter.

Sanctions against third-country banks using SPFS create a compliance crisis for institutions in Turkey, the UAE, and Central Asia. These banks face a stark choice: do business with Russia and risk being cut off from the U.S. dollar and the entire Western financial system, or mitigate risks and sever ties with Russian counterparties. This extends Russia’s financial isolation far beyond its borders.

While sanctions on an additional 118 tankers will cause short-term disruptions, Russia is likely to continue purchasing old vessels and creating new shell companies to manage them. The effectiveness of these sanctions depends on sustained, aggressive enforcement and targeting of related services, such as insurance and vessel registration, which remains a challenge. Sanctions against Russia’s main reinsurer (RNPC) are a key step in this direction.

EU officials openly state that sanctions are working, pointing to Russia’s high interest rate (17%) and persistent inflation as signs that its “overheated war economy is reaching its limits.” The new measures will intensify this pressure, limiting access to foreign currency and increasing the cost of imports.

The impact of the sanctions will be phased, allowing for projections of developments in the short, medium, and long term:

Short-term (3-6 months): Expect financial market volatility, immediate disruptions in oil logistics due to the identification of newly sanctioned tankers, and increased compliance costs for third-country banks working with Russia.

Medium-term (6-18 months): A noticeable reduction in oil and gas revenues is projected due to stricter enforcement of the lowered price cap and the gradual phasing out of LNG contracts. Pressure on the federal budget will increase, forcing the government to seek additional funding sources or cut spending.

Long-term (18+ months, up to 2027): The full effect of the LNG ban will become evident, potentially leading to the permanent closure of new Arctic production lines. Structural damage to Russia’s energy sector and its long-term economic growth potential will be undeniable.

The new sanctions force Russia’s partners, particularly China, to make strategic choices. Directly targeting third-country entities (in China and India) and banks using SPFS is designed to dismantle the “evasion axis.” Russia has survived under sanctions largely due to its pivot to China and India, which have become markets for its energy and sources of dual-use goods. The 19th package directly targets Chinese refineries and companies supporting Russia’s military, moving from general warnings to specific restrictions. Simultaneously, the U.S. is threatening secondary tariffs on China for purchasing Russian oil. This creates a “pincer” effect. Chinese banks are already becoming more cautious in dealing with Russia due to U.S. pressure. Thus, Beijing faces a choice: is the benefit of supporting a weakened Russia worth the risk of secondary sanctions that could harm access to the far more valuable U.S. and EU markets? While “limitless partnership” is ideologically valuable, China consistently prioritizes its own economic interests. The West is now systematically raising the economic cost of this partnership, potentially forcing China to limit its support for Russia to avoid threats to its own stability, thereby weakening the Kremlin’s most critical lifeline.

Furthermore, the focus on AI, geospatial data, and advanced components goes beyond merely stopping the flow of goods for current battlefield needs. It is a long-term strategy aimed at preventing Russia’s military from developing and deploying next-generation weapons systems, ensuring a growing technological gap between Russia and NATO. The war in Ukraine, as noted by the European Commission, is an “innovation-driven war,” where drones, precision targeting, and battlefield data processing are key. 

Russia’s domestic technological base is weak, and it relies on imported components and technologies. The sanctions specifically target AI and geospatial data, which are foundational for autonomous systems, advanced targeting, and modern command and control. By cutting off these supplies now, the West seeks to ensure that even if Russia can sustain production of current-generation tanks and artillery shells, it will increasingly lag technologically. This is a critical element of long-term attrition, designed to make any future Russian aggression against NATO even less likely.

The World Returns to a Geopolitical Triangle: EU, U.S., and Russia’s Response

The timing and content of the 19th sanctions package are directly linked to pressure from U.S. President Donald Trump. Multiple sources confirm that the package’s presentation was delayed and then strengthened after Trump demanded that the EU take tougher measures – specifically, to stop purchasing Russian oil and gas – as a prerequisite for the U.S. implementing its own “major sanctions.”

In response, Ursula von der Leyen confirmed that she spoke with Trump and that the Commission would propose “accelerating the phase-out of Russian fossil fuel imports,” which directly led to the accelerated LNG ban. This demonstrates a significant instance of U.S. influence on EU policy-making.

This dynamic creates a complex political situation within the EU. Hungary and Slovakia, which still import Russian pipeline oil through the Druzhba pipeline under an existing exemption, are outspoken supporters of Trump. U.S. pressure on the EU as a whole, ironically, hits Trump’s own allies within the bloc the hardest.

The Trump administration is actively pushing G7 partners to impose secondary tariffs of 50-100% on countries like China and India for their continued purchases of Russian oil. This is a highly escalatory proposal, which the EU has so far been reluctant to adopt due to its reliance on export markets in these countries.

The EU’s 19th package is likely the “tougher measures” Trump demanded. Its adoption will likely unlock a new wave of U.S. sanctions. These are expected to focus on areas where U.S. authority is strongest: secondary sanctions against financial institutions (which rely on the U.S. dollar) and more aggressive targeting of the “shadow fleet,” where U.S. sanctions are considered more effective than EU/UK sanctions.

Both China and India have strongly opposed the threat of secondary tariffs, calling it “unilateral bullying” and a matter of national sovereignty. They are likely to continue purchasing Russian oil, but their financial institutions and shipping companies will become increasingly cautious to avoid direct inclusion on U.S. Treasury lists.

The Kremlin’s public response is likely to be dismissive, with statements that these measures will not affect its stance or change its course. However, EU officials note that in private diplomatic contacts, Russia’s first request is consistently for sanctions relief, indicating their effectiveness.

Russia will be forced to accelerate its pivot to Asia, but it faces significant logistical and infrastructural constraints. It cannot easily redirect LNG without the necessary ice-class tankers and port infrastructure. Pipeline projects to China, such as Power of Siberia 2, are long-term and face complex negotiations.

The sanctions will make Russia even more dependent on China as a market of last resort and a source of technology. This deepens already asymmetric relations, in which China holds most of the leverage.

By agreeing to Trump’s demands, the EU is not only punishing Russia but also making a strategic investment in transatlantic unity. This is a calculated move to ensure continued U.S. engagement and support for Ukraine by demonstrating European burden-sharing. The Trump administration has been skeptical of European defense spending and commitments, viewing the war in Ukraine primarily as a European problem. Trump’s demand – “you stop buying Russian oil, then I’ll act” – is a clear test of this commitment. The EU’s decision to accelerate the LNG ban, a politically challenging move, is a direct response to this test. It strengthens the position of pro-Atlanticist leaders in Europe. They can argue domestically that these painful economic measures are necessary to keep the U.S. “in the game,” which is seen as vital for Ukraine’s survival. This prevents potential U.S. accusations of European “free-riding” and aims to solidify a unified Western front.

Moreover, the cumulative effect of the EU targeting SPFS and third-country entities, combined with U.S. threats of secondary sanctions, is to make any Russia-related transaction toxic to the global financial system. This goes beyond mere compliance and forces strategic de-risking. A bank in Turkey or the UAE may find a way to process a payment for non-sanctioned goods to Russia that technically complies. However, the new EU sanctions against SPFS users and the U.S. Treasury’s clear warning that it will “more aggressively target foreign financial institutions” joining or using SPFS shift the risk calculation. The risk is no longer that a specific transaction is non-compliant, but that the entire institution could be listed for providing services to the Russian economy. This forces bank risk and compliance departments to view any interaction with Russia as a potential existential threat. The result is widespread, voluntary cessation of services to Russian entities, even for trade not directly under sanctions. This creates a de facto financial blockade that is far more comprehensive than the letter of the sanctions.

What Is the Strategic Outlook and How Is It Affected by Unresolved Challenges?

Russia’s nuclear sector, particularly Rosatom, remains a notable exception from EU sanctions due to the high dependence of several member states (especially Hungary and Slovakia) on Russian nuclear fuel and services. While there are calls to sanction Rosatom, a full ban is unlikely before 2030, leaving Moscow with a significant revenue source and geopolitical leverage.

The ultimate escalation would be the U.S. imposing comprehensive secondary sanctions on all countries trading with Russia, following the Iran model. This remains a high-risk option due to the potential for massive disruptions to the global economy and backlash from key partners like India. The 19th package and the U.S. response will be a test case of how far the West is willing to go down this path.

The package still requires unanimous approval by all 27 EU member states. Hungary and Slovakia remain potential obstacles, particularly regarding any measures that could indirectly affect their continued pipeline energy imports, although the current package is carefully designed to focus on LNG and seaborne oil to bypass their core concerns.

Enforcing sanctions on decentralized crypto platforms and non-custodial wallets poses a massive technical and legal challenge. While the EU’s Markets in Crypto-Assets Regulation (MiCA) provides a framework for licensed providers, tracking and blocking illicit P2P transfers will require an unprecedented level of international cooperation and technological capabilities.

The success of the sanctions regime hinges on maintaining the G7+ coalition. Any divergences, particularly between the U.S. and EU, will be exploited by Russia. The conditional nature of U.S.-European dynamics introduces a new element of fragility to this coalition.

G7 statements clearly indicate that sanctions will remain in place until Russia ends the war, fully withdraws troops from Ukraine’s territory, and pays reparations for the damage caused. The “Reparative Loan” concept further entrenches the idea that sanctions relief is tied to financial restitution, not merely a ceasefire. Given Russia’s current strategic goals, these conditions are unlikely to be met in the near term, suggesting that the sanctions regime will become a long-term feature of the geopolitical landscape.

The long-term consequence of this sanctions war escalation is the acceleration of a split in the global financial and trade system. Russia, with China’s help, is forced to build a parallel, non-Western infrastructure (SPFS, yuan-based trade). While currently inefficient and risky for participants, this creates a long-term structural challenge to U.S. dollar dominance and Western-led institutions.

Western sanctions are designed to leverage the central role of the U.S . dollar and SWIFT. Russia’s response is to create alternatives like SPFS and promote trade in national currencies with partners like China. The 19th package attacks these alternatives by threatening punishment for third parties using them. This forces countries to choose: operate within the Western system or a new Russia-China-led alternative. While most will choose the West, the very existence of this choice and the infrastructure to support it fundamentally alters the global economic landscape. Over a decade, this could lead to a more fragmented world with competing economic blocs, reducing the future effectiveness of sanctions as a foreign policy tool.

Ultimately, the definitive success of sanctions depends on a factor beyond the sanctions themselves: the EU’s energy transition. The EU’s ability to fully phase out Russian energy without triggering a self-destructive economic crisis hinges on the success and speed of its REPowerEU plan and green transition. The EU claims it is “ready” for the LNG ban, having diversified supplies (to the U.S. and Qatar) and invested in renewables. However, this has led to a new dependence on U.S. LNG, which carries its own political risks.

The only way to achieve true strategic autonomy and make sanctions sustainably effective is to reduce overall fossil fuel demand through efficiency and renewables. Thus, the long-term “pain” for Russia is directly proportional to the EU’s success in its domestic energy policy. If the transition stalls, the EU’s resolve on sanctions may weaken due to high energy prices and economic pressure. If the transition accelerates, the EU can intensify pressure on Russia with minimal harm to itself, making the sanctions regime far more potent and durable.

Thus, the EU’s 19th sanctions package against the Russian Federation is not merely a quantitative escalation of pressure but a qualitative leap in the strategy of economic containment. It marks a shift from broad restrictive measures to precision strikes on the adaptation and evasion mechanisms the Kremlin has built to sustain its war economy. Targeting the “shadow fleet,” the alternative SPFS financial system, and cryptocurrency channels demonstrates a deep understanding of how the Russian economy functions under sanctions and the West’s determination to play a long-term game of attrition.

The 19th sanctions package will have a cascading effect. In the short term, it will complicate logistics and financial operations for Russia. In the medium term, it will significantly reduce its budget revenues. In the long term, it will undermine its future economic development and deepen its asymmetric dependence on China. While Russia will undoubtedly seek new ways to adapt, this package significantly raises the cost and complexity of such efforts, accelerating the depletion of its economic and technological resources needed to wage a prolonged aggressive war. The success of this regime, however, will depend on unwavering Western unity, aggressive enforcement, and, ultimately, the success of Europe’s own energy transition.

Ihor Petrenko, founder of the “United Ukraine” Think Tank, Doctor of Political Sciences


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