Europe’s trade and regulatory landscape continue to evolve under the pressure of geopolitical fragmentation. Since 2022, the EU has implemented a sequence of sanctions in response to Russia’s full-scale invasion of Ukraine, reshaping energy markets, financial operations, and industrial supply chains. The latest development came on 23rd of October 2025, with the release of the 19th EU sanctions package. 

The package represents one of the most comprehensive sets of measures since the beginning of the war. The package also steps up pressure on circumvention networks by sanctioning, energy exports, elements of Russia’s “shadow fleet,” third-country banks and crypto intermediaries, underscoring that sanctions are evolving technically to close loopholes rather than disappearing. The adaptability of mixing sectoral embargoes, targeted listings and measures against enablers demonstrates sanctions remain a live, policy-shaping tool capable of constraining revenue flows and reshaping market behaviour over the long term.

Below, we analyse the 19th package through a business lens, examining how its main components affect energy, financial services, manufacturing, logistics, and technology sectors. We also consider how European firms are adjusting their Russia-related operations, the emerging patterns of withdrawal and reorientation, and the broader lessons for corporate strategy under conditions of continuing geopolitical risk.

This article was written by Marius Ungureanu ([email protected]) and Kaan Bostanci ([email protected]).  Marius and Kaan are consultants with RSM Netherlands Business Consulting with a focus on supply chain management.

Core components of the 19th sanctions package

The current presence of European companies in Russia

These operational changes arise in a landscape that has already been transformed by the war. Trade flows between the EU and Russia have collapsed since 2022. Eurostat data shows that Russia’s share in extra-EU imports has dropped from close to 10% before the invasion to around 1–2% in 2025, largely due to the oil embargo and the diversification of European energy supplies. Exports have also declined to historically low levels, reflecting both regulatory pressure and reduced demand.

Corporate presence, however, has not declined at the same pace. Data from the Kyiv School of Economics shows that roughly one in eight international companies tracked in its database had fully exited Russia by mid-2025. Around a third had suspended or scaled back activity, while more than half continued operations in some form, ranging from limited local production to essential-goods distribution. Yale’s dataset confirms this broad pattern: many firms that reduced activity have not completed full divestment and continue to manage workforces, assets, or inventories inside Russia. These situations often involve contractual obstacles, local regulatory requirements, or concerns about asset seizures and forced sales.

The gap between reduced trade flows and continued corporate presence reflects the practical difficulty of withdrawing from a complex market. Exit processes are often slow, capital controls restrict return, and negotiations with local buyers can be delayed. At the same time, residual operations expose companies to rising compliance burdens and reputational risk. With each sanctions package, the pressure on these remaining firms increases. Screening requirements deepen, payment options narrow, and public attention to tax contributions and operational linkages becomes more pronounced.

How the new measures reshape business operations

The combined effect of these restrictions forces companies to revisit their operational assumptions. Energy procurement strategies must be redesigned with the LNG timeline in mind. Firms with long-term supply agreements face decisions about renegotiation, substitution, and hedging, while shipping and procurement teams must prepare for more stringent vessel, routing, and insurance requirements. The maritime dimension of the 19th Package is central to continuity planning; exposure to any designated vessel now represents a legal and financial risk that must be screened against on a transaction-by-transaction basis.

Financial operations must also be restructured. Treasury functions need to evaluate whether any direct or indirect business partner rely on Mir, SBP, or high-risk correspondent banks. The addition of third-country banks to the sanctions list means that even payments routed through “neutral” hubs can become non-compliant overnight. Internal controls must reflect the possibility that payment corridors may close abruptly, requiring contingency routing and pre-approved alternatives. The crypto-related prohibitions require firms to update internal rules to ensure that no business unit or intermediary uses listed platforms or instruments to settle cross-border obligations.

Supply chains are now subject to deeper scrutiny, and companies will need to conduct extended supplier mapping. Because many of the newly restricted entities operate in third countries, traditional first-tier screening is no longer sufficient. Firms dealing in electronics, machinery, chemicals, and specialised materials must confirm not only the identity of direct suppliers but also the origin of components and the involvement of subcontractors. Documentation requirements for end-use and end-user assurances will increase, and distributors in higher-risk regions will require revised contractual obligations, including audit rights and termination clauses triggered by sanctions developments.

Implications for corporate strategy and governance

The trajectory set by 19th Package and earlier measures suggests that companies should prepare for further tightening of the EU sanctions regime. To remain compliant and strategically resilient, firms will need to enhance governance structures that oversee sanctions risk and integrate this oversight into procurement, sales, finance, and logistics functions. Clear internal processes for identifying exposure, evaluating counterparties, and terminating relationships when necessary are now essential. Boards should insist on regular exposure mapping covering suppliers, distributors, financial intermediaries, and service providers across all relevant jurisdictions.

Companies with any Russia-related operations face decisions that increasingly require clarity rather than incremental adjustment. Those that choose to remain will need to demonstrate robust due-diligence frameworks, reliable documentation, and clearly defined boundaries around permissible activities. Those preparing to withdraw should establish structured timelines and contingency plans that reflect the accelerated pace of regulatory change. In many cases, the practical question is whether the commercial return justifies the operational, legal, and reputational demands of continued presence.

Forward thinking  

The shape of future EU sanctions is already visible. Regulatory attention is shifting steadily toward enforcement, circumvention networks, maritime logistics, and technological enablers. Each new package has expanded the EU’s reach into supply chains, payment systems, and service models. Further measures can be expected, including additional entity listings and restrictions in fields such as advanced manufacturing, digital infrastructure, and shipping services.

Companies that anticipate these movements will be better positioned than those that respond only once new rules take effect. Detailed exposure maps, re-papered contracts, revised payment channels, and strengthened compliance functions offer advantages in both stability and reputation. Clear internal decision frameworks also help executives determine when operations must cease or pivot to protect longer-term interests. In a sanctions environment that is progressively narrowing, the ability to decide decisively will distinguish firms that adapt from those that are overtaken by events.

RSM is a thought leader in the field of Supply Chain Management consulting including strategy and trade matters. We provide frequent insights through training and the sharing of thought leadership, based on our detailed knowledge of industry developments and practical applications gained from working with our customers. To discuss a strategy for building structural resilience and navigating the new trade regulatory landscape, please contact one of our consultants.   

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