The EU officially approved the 19th sanctions package, targeting the Russian energy and financial sectors and tightening control to prevent sanctions circumvention through third countries.
European Commission President Ursula von der Leyen stated, "For the first time, we are targeting the Russian natural gas sector, the heart of its war economy."
The EU agreed to a phased ban on Russian LNG imports, aiming to terminate all gas transactions with Russia by January 1, 2027. In 2024, Europe bought record amounts of Russian LNG, following a drastic reduction in pipeline supplies—a trade that, according to Brussels, financially bolstered Moscow and weakened European support for Ukraine.
In parallel, 117 more vessels of the "shadow fleet" were added to the European sanctions, bringing the total to 558. These ships are considered suspicious of illegally transporting Russian oil and are now excluded from European ports and insurance services.
The United Kingdom had already imposed sanctions on 90 entities, including Rosneft, Lukoil, and the Chinese LNG terminal Beihai, stating that it "is imposing the strictest sanctions against Russia, directly hitting its energy core."
The "silent" advisory notice from Sullivan & Cromwell
Amidst the wave of sanctions, a seemingly insignificant "client advisory" from the American firm Sullivan & Cromwell on October 29, 2025, went almost unnoticed. However, its content functions as an unofficial directive to the US's European allies.
Sullivan & Cromwell—historically connected with the Rockefeller network, Standard Oil, ExxonMobil, and JPMorgan Chase—has played pivotal roles in international political and economic developments, from IG Farben and the 1954 Guatemalan coup, to recent cases such as FTX and the legal defense of Donald Trump.
The "client advisory" analyzes the amendments to the European Regulation 269/2014. For the first time, the concepts of "ownership" and "control" acquire binding legal content, allowing authorities to consider an asset to be "under Russian control" even with an indirect or implied connection.
The opinion of the Advocate General of the EU Court of Justice, Richard de la Tour, proposes a "broad interpretation" of the freezing of funds: not only economic exclusion, but also deprivation of voting rights, participation in assemblies, and the receipt of dividends.
Essentially, the sanctions can turn an owner into a legal "ghost": a formal shareholder, but without the possibility of managing or accessing their assets.
This model paves the way for a new form of de facto confiscation without official change of ownership—a method of discreet business takeover through "temporary administrators," meaning financial actors from Wall Street and the City.
Behind the scenes, Sullivan & Cromwell appears to be operating in harmony with BlackRock, which is feeding the firm with high-level executives.
The 19th sanctions package is no longer just about energy or trade rights. It is about a new strategy of economic warfare: seizing control of the opponent's economy. Russia is only the beginning.
With a "broader interpretation of control" and any suspicion of connection with Russia, any company could become the next target—with account freezes, loss of votes, weakening of management, and economic neutralization.
The Anglo-Saxon financial empire no longer hides its intentions.
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