Do EU sanctions also apply to business trips to Russia?

The EU's 19th sanctions package against Russia casts a wider net, impacting not only the usual suspects of energy, finance, and transport, but also tourism, according to the VDR, DRV, and fvw magazine. Specifically, Article 5n, paragraph 2 of Regulation (EU) 2025/2033 now outright prohibits providing services "directly related to tourism activities in Russia."
So, what could this mean for business travel, you might ask? Well, the regulation's language is fairly broad. Article 1(1)(j) defines "tourist activities" as including things like travel information, planning, advice, and the actual booking of travel—encompassing transportation (flights included) and lodging. The regulation doesn't really differentiate between leisure and business, meaning business trips to Russia, generally speaking, *could* potentially be caught in the ban.

Martin (United Kingdom)