On 23 January 2026, the European Commission released new FAQ guidance providing clarifications for operators navigating the EU’s expanding Russia sanctions framework. Notably, the European Commission updated their Consolidated FAQs on Sanctions against Russia and Belarus (the “FAQs“, accessible here) with guidance on the Nord Stream transaction ban and the EU’s 19th sanctions package, summarized below.
I. Clarifications on the Nord Stream Transaction Ban (Article 5af, Regulation 833/2014)
The EU has published dedicated FAQs interpreting Article 5af (see page 297 of the FAQs), which imposes a broad prohibition on all direct and indirect transactions related to the completion, operation, maintenance, or use of the Nord Stream and Nord Stream 2 pipelines. In summary, the FAQs confirm:
a. The scope of the ban
The FAQs confirm that Article 5af operates as a wide-ranging transaction ban, capturing:
- Any transaction connected to financing, completion, operation, maintenance or use of the pipelines;
- The provision of services, goods or software contributing to those activities.
b. Activities that remain permissible
Certain limited activities may fall outside the ban:
- Mere surveillance or monitoring of the pipelines’ status when not connected to restoring or preserving functional condition;
- Activities falling within Article 5af(2) exceptions or conducted under a Member State licence pursuant to Article 5af(3).
c. Licensing
Licences for permitted maintenance related work for both EU and non-EU operators may be granted by the Member State on whose territory the work is conducted.
II. New FAQs on service prohibitions amended under Article 5n
Following the implementation of the 19th Russia sanctions package (October 2025), the Commission has substantially expanded its guidance on the services prohibitions in Article 5n of Regulation 833/2014. The new FAQs (nos. 37–49, starting on page 393 of the FAQs) clarify the scope of prohibited services and the newly introduced prior authorisation requirement for services to the Russian government.
By way of summary of the updated FAQS:
FAQs 37 – 39 – Prohibited activities covered by Article 5(n)(1)
FAQ 37 – Clarifies the scope of Space-based commercial services
The Commission delineates which Earth observation and satellite navigation services fall within scope, including examples of:
- In-scope services (e.g., targeted geospatial data for Russian state entities);
- Out-of-scope services (e.g., general non customised publicly available satellite imagery).
FAQ 38 – Clarifies the scope of Artificial intelligence services
The updated guidance distinguishes between:
- Access to hosted AI models; and
- Access to platforms enabling training, fine-tuning and inference, clarifying the types of AI-enabled or AI-supporting services that may constitute prohibited assistance when supplied to Russian entities.
FAQ 39 – Clarifies the scope of High-performance and quantum computing
FAQ 39 provides further detail on the two main categories of computational power covered by the Article 5n(1)(h) prohibition: High-performance Computing services and quantum computing services.
FAQs 40 – 47 – Tourism-related services ban
The 19th package introduced a new prohibition on services directly related to tourism activities in Russia, defined by reference to the relevant CPC (Central Product Classification) framework.
Scope and examples: The FAQs explain that the ban covers:
- Travel agency and tour operator services relating to travel in Russia;
- Visa facilitation services when directly linked to tourism in Russia;
- The sale or brokering of transportation tickets to Russia;
- Services offered by booking platforms or travel search apps when connected to Russia based tourism.
Limits of the prohibition: The Commission emphasises that the prohibition does not extend to:
- Travel information for the general public in the form of websites or books;
- Travel relating to private visits, business visits, or travel by Russian citizens to the EU.
FAQs 48 – 49 – Mandatory prior authorisation for services to the Russian Government under Article 5n(4)
The FAQs expand on the mandatory prior authorisation requirement, introduced in Article 5n(4), for all services provided to the Russian government, including:
- Services to Russian embassies in the EU (e.g., essential services required for their functioning);
- Services enabling the operation of Russian consular and diplomatic representations in Member States.
These FAQs explain the applicable exceptions and derogations and clarify the administrative steps operators must take to secure approval.
Conclusion
The new and amended FAQs provide welcome clarity for EU and non-EU businesses engaged in relevant activities with a Russian nexus. The breadth of the 19th package’s new service prohibitions – and the introduction of a generalised prior authorisation regime for services to the Russian government – represent a significant tightening of the EU’s approach.
Operators should update internal controls, ensure robust cross functional compliance checks, and assess whether existing contracts or service offerings may require new authorisations.
For more information, please see our previous blog posts on the EU’s adoption of the 18th EU Sanctions Package Against Russia and the 19th EU Sanctions Package Against Russia.
