EU Adds 250+ Entries in Coordinated Russia-Ukraine-Belarus-Iran Sanctions Package

The European Union enacted seven regulatory actions on April 23-24, adding over 250 entries across Russia, Ukraine, Belarus, and Iran sanctions lists. The coordinated package represents a significant diplomatic signal, expanding export controls, listing criteria for vessels, and individual designations in response to ongoing regional conflicts.

EU Amends Ukraine Sanctions: New Derogations, Vessel Criteria
The Council of the European Union adopted Decision (CFSP) 2026/504 on 23 April 2026, amending Decision 2014/145/CFSP on restrictive measures in respect of actions undermining Ukraine's territorial integrity, sovereignty and independence. The decision modifies listing criteria for vessels and entities involved in sanctionable activities, adds new derogations for state-funded cultural intermediators in Russia, introduces a derogation for arbitration costs against listed parties, extends a derogation to a newly listed insurance company, and adds a derogation for entities reducing Russian crude oil imports.

EU Council Regulation 2026/511 Amends Ukraine Sanctions
Council Regulation (EU) 2026/511 amends Regulation (EU) No 269/2014 (the core Ukraine sanctions regulation) to implement Decision (CFSP) 2026/504. Key amendments include: (1) expanded listing criteria for vessels and entities managing or supporting vessels engaged in sanctionable activities; (2) a new derogation from asset freeze for a listed insurance company relating to indemnities and benefits; (3) new derogations for state-funded cultural intermediators operating Russian foreign cultural policy in Russia (cultural institutions, schools, minority organizations); (4) clarification that listed persons' arbitration claims related to restricted contracts cannot be satisfied, with a conditional carve-out for arbitral costs; (5) a new derogation enabling frozen funds release to facilitate reduction of Russian crude oil imports; and (6) extension of an existing derogation for goods and services needed for the Sofia metro system. These amendments take effect across all EU Member States upon publication.

EU Adds 60 Entities to Russia Sanctions List
Council Regulation (EU) 2026/506 of 23 April 2026 amends Regulation (EU) No 833/2014 by adding 60 new entities to the list in Annex IV to Decision 2014/512/CFSP, targeting persons and entities supporting Russia's military and industrial complex. The amendment tightens export restrictions on dual-use goods and technology, microelectronics, components for unmanned aerial vehicles, maritime equipment, and components for vehicles and machinery. Additionally, the regulation imposes new import restrictions on raw materials, metals, minerals, steel scrap, chemicals, rubber articles, and tanned furskins, extends the prohibition on transit via Russia, and expands the broadcasting prohibition to cover entities mirroring content of already-prohibited entities.

EU Adds 117 Entries to Ukraine Sanctions List
The Council of the European Union adopted Implementing Regulation (EU) 2026/509 on 23 April 2026, adding 37 natural persons and 80 legal entities to the sanctions list under Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining Ukraine's territorial integrity, sovereignty, and independence. The amendments target individuals and entities responsible for actions related to Russia's war of aggression against Ukraine, including those involved in archaeological excavations on Russian-occupied Crimean territory. The regulation entered into force on the date of its publication in the Official Journal and is directly applicable in all EU Member States.

EU Expands Belarus Sanctions Over Ukraine Role
Council Regulation (EU) 2026/513 of 23 April 2026 significantly expands EU restrictive measures against Belarus in response to Belarus's involvement in Russian aggression against Ukraine. The regulation extends export controls to include items used by Russia in its war (laboratory glassware, high-performance lubricants and additives), expands goods subject to export restrictions (chemicals, rubber articles, steel articles, metal-production tools, industrial tractors), and extends transit prohibitions. New service restrictions cover managed security services and tourism-related services (CPC classes 7471 and 7472). Import bans are extended to raw materials, metals, minerals, and scrap steel. An exemption is provided for essential diplomatic and consular representation services.

EU Corrigendum 2026/759 Correcting Iran Dual-Use Controls
The Council of the European Union issued a corrigendum on 23 April 2026 to Council Regulation (EU) 2026/759 of 30 March 2026, which amended Regulation (EU) No 267/2012 concerning restrictive measures against Iran and repealed Regulation (EU) No 961/2010. The corrigendum corrects Article 2(2) and (3) of the amended regulation, updating the reference for dual-use goods and technology from the repealed Regulation (EC) No 428/2009 to Regulation (EU) 2021/821, while introducing exceptions for certain goods listed in Part A of Annex I. Additionally, the corrigendum adds a new procedural obligation requiring Member States to inform other Member States and the Commission within four weeks of any authorisations granted. The corrigendum re-affirms the re-imposition of EU nuclear-related sanctions on Iran following UN Security Council Resolution 2231 (2015).

EU Adds Parties to Ukraine Sanctions List
The Council of the European Union has published a notice in the Official Journal (C/2026/2460) informing newly designated persons, entities, and bodies that they have been added to the EU sanctions list under Council Decision 2014/145/CFSP (amended by Decision 2026/504) and Council Regulation (EU) No 269/2014 (implemented by Regulation 2026/509), concerning restrictive measures in respect of actions undermining Ukraine's territorial integrity, sovereignty and independence. Designated parties have until 2 June 2026 to submit a request for reconsideration to the Council's General Secretariat, and may also challenge the designation before the General Court of the European Union pursuant to Article 275 and Article 263 TFEU.

EU Lists Belarus Entities Under Sanctions
The Council of the European Union has published a notice (C/2026/2468) bringing to the attention of listed entities that they have been included in the restrictive measures under Council Decision 2012/642/CFSP and Council Regulation (EC) No 765/2006, as implemented by Council Implementing Decision (CFSP) 2026/503 and Council Implementing Regulation (EU) 2026/505 respectively. These measures target Belarus in light of its involvement in Russian aggression against Ukraine. Listed entities have until 27 November 2026 to submit a request for reconsideration to the Council's General Secretariat at RELEX.1, and may also challenge the decision before the General Court of the European Union.