EU to expand dual-use goods export control and sanctions regimes – update on Russian sanctions packages and emerging technologies

The EU tightens Russian measures and extends export controls to new technologies, increasing immediate risks for trade, finance and supply chains.

Why this matters now

The EU has prolonged Russia-related individual sanctions until 15 March 2026. The 18th package has been in force since 18 July 2025, introducing a lower oil price cap, a shadow-fleet crackdown and expanded transaction bans. On 19 September 2025, the Commission presented a 19th package for Member State approval, proposing an LMG import ban, additional bank and crypto restrictions and further shadow fleet listings. In parallel, the dual-use list now captures emerging technologies following an Annex I update adopted on 8 September 2025. Screening, documentation and product classification must reflect the current rule set.

In this article, you will learn:

• What the 18th Russia package changed across energy, banking, shipping and trade (recap and implications);
• What the 19th package proposes and how it is likely to change the baseline once adopted;
• What the dual-use update adds under emerging technologies and the immediate compliance impacts; and
• What happens in case of violations (sanctions and export-control breaches).

Brief recap of the 14th-17th sanctions packages

• 14th package (24 June 2024): Robust anti-circumvention tools; LNG restrictions (including, post-transition, a ban on trans-shipment of Russian LNG at EU ports); new investment/service bans; targeted vessel measures.
• 15th package (16 December 2024): Focus on the shadow fleet; expanded listings; additional anti-circumvention measures; ban on the recognition and enforcement in the EU of Russian court rulings based on the Russian Arbitration Procedure Code.
• 16th package (24 February 2025): Further finance and trade restrictions, including actions related to the Russian SPFS; additional listings.
• 17th package (20 May 2025): Escalated measures targeting shadow fleet logistics and energy revenues; further listings; tightened export controls.

18th package (18 July 2025): Recap and implications

Energy and shipping: The crude oil price cap was lowered to USD 47.6/bbl and linked to a dynamic adjustment mechanism with automatic revisions. Shadow fleet listings expanded to approximately 444 in total and extended into the surrounding services ecosystem (fleet managers and traders, a Rosneft-linked Indian refinery, a ship’s captain and a private flag registry operator). To close the “back-door”, the EU banned imports of refined products made from Russian crude in third countries (with limited partner-country carve-outs). Nord Stream 1 and 2 are now ring-fenced by a full transaction ban and the Czechia oil exemption has been terminated.

Banking and finance: The EU escalated from message-level limits to full transaction bans on 22 additional Russian banks. The scope has been extended to non-EU financial institutions and crypto-asset service providers involved in sanctions circumvention or linked to Russian SPFS. Transactions with the Russian Direct Investment Fund (RDIF) are prohibited, with a mechanism to capture investees and service providers. Certain financial sector management software has been restricted.

Trade and listings: 26 new entities (in Russia, China/Hong Kong and Türkiye) are subject to tighter export restrictions, notably UAV-related. Additional export bans apply, covering approximately EUR 2.5 billion worth of goods (including CNC machines and propellant chemicals). Transit bans via Russia have been widened for economically critical goods. Additional sanctions against Belarus have also been implemented.

Practical effect: Due diligence must start earlier and run deeper: counterparties, vessels and intermediaries require role-based screening (owners, managers, brokers, insurers, registries). Trade finance files need granular origin and price cap evidence, along with full routing transparency.

19th package (presented 19 September 2025): proposed measures

The Commission has presented the 19th package and invited the Council to adopt it swiftly. The measures will apply once adopted and published in the Official Journal.

Energy & shipping: The proposal prohibits the import of Russian LNG into EU markets. It also adds 118 further shadow fleet vessels to the listings (bringing the total to more than 560) and imposes a full transaction ban on Rosneft and Gazpromneft. In addition, the Commission proposes asset freezes for refineries, oil traders and petrochemical companies in third countries (including China) that purchase sanctioned Russian oil.

Banking & finance (including crypto): The package introduces transaction bans on additional Russian banks and banks in third countries that facilitate circumvention. It also targets crypto platforms for the first time and prohibits crypto transactions used to evade sanctions. Foreign banks connected to Russian alternative payment systems would be listed and transactions with companies in special economic zones would be restricted.

Trade and listings: The Commission proposes direct export restrictions on goods and technologies used on the battlefield and the listing of 45 additional companies in Russia and in third countries for supporting Russia’s military-industrial complex, with a particular focus on drones.

If adopted as proposed, package 19 closes LNG access, expands the shadow fleet perimeter and tightens crypto and third-country banking channels – reinforcing the same levers as package 18: energy, logistics and finance.

Practical effect (upon adoption): If adopted, the package will prohibit imports of Russian LNG into the EU and expand the maritime screening perimeter to a larger cohort of vessels and related service providers. It will also close crypto-based evasion routes and restrict third-country financial intermediaries that facilitate circumvention. New listings and sectoral measures will broaden export control exposure across affected supply chains. Companies should prepare by re-screening counterparties and vessels, re-papering energy-trade and trade finance documentation and conducting route audits for LNG and petroleum movements.

Status and next steps: The package is awaiting Council adoption. Content may adjust during negotiations. Until then, treat these measures as prospective, but pre-draft clauses and set decision gates so files can be updated on day one of publication.

Dual-use update: Emerging technologies added to Annex I

On 8 September 2025, the Commission adopted a Delegated Regulation updating Annex I to Regulation (EU) 2021/821 (the “Dual-Use Regulation”), which expands the list of items requiring a licence for export to non-EU countries. This update aligns the EU list with the 2024 decisions of key multilateral export control regimes, including the Wassenaar Arrangement, MTCR, Australia Group and Nuclear Suppliers Group. Additionally, it introduces EU-level controls for technologies that have moved from research into deployable capability (emerging technologies). Entry into force follows the standard two-month scrutiny period (expected November 2025, in the absence of objections).

Selected examples for emerging technologies:

• Quantum (quantum computers, cryogenic-rated electronics, parametric amplifiers, cryogenic cooling systems, cryogenic wafer probers);
• Semiconductor manufacturing and testing (ALD, epitaxy equipment and materials, lithography including EUV pellicles, masks and reticles, SEM, etch tools);
• Advanced computing ICs (FPGAs, programmable logic and assemblies); and
• Manufacturing and materials (additive manufacturing machines, high-temperature coatings).

Bringing quantum and chip-tooling into Annex I shifts questions from R&D to compliance: classify early, obtain a license where required and gate releases at design freeze.

Operational Impact: Update classification data and license screening and align ERP/customs teams. In the case of technology, knowledge transfer may already trigger license requirements. Both end-user diligence and tech transfer controls should therefore be tightened.

What happens in case of a violation?

Export control breaches (e.g. under the Dual-Use Regulation or export restrictions imposed by EU sanctions law): Penalties are set at a national level but must be effective, proportionate and dissuasive. They typically include administrative fines, criminal liability, seizure or forfeiture, license revocation or loss of access to Union General Export Authorisations. Enforcement is increasingly coordinated (customs, FIUs, prosecutors), enabling chain-wide investigations. Under Austrian law, export control breaches are punishable by high administrative fines or prison sentences of up to five years, as well as criminal fines of up to EUR 3 million for legal entities.

Sanctions breaches (e.g. under EU sanctions law other than export restrictions): Directive (EU) 2024/1226 harmonises offences (including attempt, aiding and abetting and circumvention) and sets minimum penalty standards for legal and natural persons. Member States were required to transpose the Directive into national law by 20 May 2025. More consistent criminal enforcement should therefore be expected. Under Austrian law, sanctions law breaches may face essentially the same consequences as export control breaches.

On-the-ground reality: Transactions can be frozen (banks and insurers decline, bills of lading withheld), goods can be stopped at the border and payments can be blocked by screening. Contractually, there is a risk of terminations and damages claims.

Conclusion: The baseline has shifted

Bottom line: The EU framework is no longer episodic; it is continuous and cumulative. The 18th package represents the current operative environment, while the Annex I emerging technologies update widens the controlled perimeter. The 19th package – when adopted – will increase pressure rather than redefine the baseline.

What this means for you: Your policies, screening and documentation should already include the 18th package and the Annex I update. Where uncertainty remains (e.g, the final Council text on the 19th package), draft forward-looking policies and establish decision gates rather than waiting for formal adoption.