NOTICE: EU Sanctions on Russia – 23 October 2025

On 23rd October 2025, the Council of the European Union adopted Council Decision (CFSP) 2025/2032, introducing fresh sanctions primarily targeting Russian LNG, as well as some new measures against Russian oil and oil products. This latest sanctions package does not have an immediate effect on the trade of Russian LNG, but the existing regime targeting Russian shipping remains in place with new vessels added to the list of restricted entities.

Key Measures:

  • Article 4wa introduces a comprehensive ban on Russian LNG covering the purchase, import, or transfer of LNG which originates in or was exported from Russia, effective 25th April 2026.
  • The prohibitions under Article 4wa are delayed until 1st January 2027 for transactions under long-term contracts concluded before 17th June 2025, provided they are not substantively amended thereafter (See Article 4wa Paragraph 2 for permitted amendments).
  • 117 vessels were added to the designated sanction list, which now totals 558, meaning all related services—including insurance and reinsurance, brokering, financing, and technical assistance—are prohibited to said vessels. The majority of the newly targeted vessels were designated for their involvement in the transport of oil and oil products of Russian origin.

Key Considerations Across LNG Market Segments:

LNG Spot / Short-term (<1 yr) Transactions Existing and future transactions for Russian LNG permitted only until 24th April 2026 to get through winter period. Thereafter, the purchase, transfer or import of Russian LNG is prohibited.
LNG Long-term (>1 yr) Transactions The purchase, transfer or import of Russian LNG is permitted only until 31st December 2026 provided that such activity is pursuant to a contract with a duration exceeding 1 year and which was concluded before 17th June 2025. Thereafter, the purchase, transfer or import of Russian LNG is prohibited.
LNG Transportation While not expressly stated in Article 4wa, transportation of Russian LNG, even with no EU touchpoint, likely to be prohibited as a “transfer” under existing EU guidance.[1]

 

For any inquiries, contact Damon Thompson ([email protected]) and Mitchell Beebe ([email protected]).

[1] Commission Consolidated FAQs General Questions #16. “transfer is a broad concept covering a wide range of operations: not only the movement of goods through customs controls, but also the transport of goods, including (but not exhaustively) their loading and trans-shipment. The transfer prohibition applies not only in relation to an actual import or export (e.g. with the goods entering or exiting the EU customs territory), but also when those products do not enter the EU, but are transferred between Russia and a third country (and vice-versa).“