EU Adopts 20th Sanctions Package Against Russia, Belarus

Steven Farmer Mark Booth Iris Karaman Samson Verebes On April 23, 2026, the EU adopted its 20 th sanctions package targeting Russia and Belarus in connection with the Russia-Ukraine conflict.

**** The latest package significantly expands the EU’s restrictive measures across the energy, finance and crypto, trade, services and maritime and transport sectors, with a core focus on anti-circumvention and energy measures. A summary of the key updates follows.

THE RUSSIA REGIME

Energy and Shipping One of the most closely watched elements of the 20 th package was whether the EU would implement a full maritime services ban on Russian crude oil and petroleum products. The approved package, however, stops short of a full ban, instead introducing a new legal basis for a future prohibition on the transport of Russian oil and petroleum products, to be implemented in coordination with the G7 and the Price Cap Coalition.

In other energy-related measures, the package includes 36 new designations across the Russian energy sector, covering upstream and downstream activities including exploration, extraction, refining and the transportation of oil. These designations target, in particular, emerging players which have recently increased their export market share. The designations include a number of Russian refineries and oil producers, along with UAE-based firms linked to the “shadow fleet” and subsidiaries of Rosneft and Gazprom.

An additional 46 “shadow fleet” vessels have been designated and are now subject to a port access ban and prohibitions on the provision of a broad range of maritime services, bringing the total number of EU-listed shadow fleet vessels to 632. Eleven vessels have also been delisted. In addition to the listings, the package also introduces a new requirement for mandatory due diligence in relation to the sale of tankers, intended to make it more difficult for Russia to acquire vessels for shadow fleet use. This includes a new mandatory “no Russia” clause required in sales contracts.

A new prohibition on the provision of LNG terminal services to Russian entities, or entities owned or controlled by Russian nationals or operators, will take effect from January 2027. The package also introduces a ban on the provision of maintenance and other services for Russian LNG tankers and ice-breakers. Transaction bans have been imposed on the Russian ports of Murmansk and Tuapse, and on the oil terminal of Karimun port in Indonesia.

Financial Measures, Crypto and Asset Freezes Extensive financial measures have been introduced as part of the package. Transaction bans have been imposed on 20 Russian banks, bringing the total to 70, as well as four third-country financial institutions in Kyrgyzstan, Laos and Azerbaijan for facilitating sanctions circumvention or for links to the Russian System for Transfer of Financial Messages (SPFS). Five third-country financial entities have also been delisted following commitments that those entities will not engage in the activities for which they were listed.

In the crypto sphere, the package introduces a new sectoral ban on Russian-established crypto asset service providers and decentralized platforms that enable the transfer and exchange of crypto-assets. It also prohibits transactions involving the ruble-backed cryptocurrency RUBx and the Central Bank of Russia’s digital ruble, and prohibits EU persons from supporting the development of these digital currencies. A Kyrgyz entity operating a crypto exchange on which significant volumes of the Russian government-backed stablecoin A7A5 are traded has also been designated.

Additionally, the package introduces a prohibition on netting transactions with payment agents in Russia and other third-country entities that facilitate international transactions for Russian customers in order to bypass EU sanctions. According to the Commission, this covers schemes using third-country companies and the use of mirror accounts, inside and outside Russia, to settle payments through “netting” or “set-off,” where debts are balanced against credits and no funds actually cross the Russian border.

The package contains 120 new listings overall, described by the Council as the largest package of listings in two years. In addition to the energy sector designations, the listings include 58 companies and associated individuals involved in the Russian military-industrial complex, including parties involved in the development and manufacture of military goods such as drones. They also include 16 third-country entities located in China, the UAE, Uzbekistan, Kazakhstan and Belarus, for supplying dual-use goods or weapons systems to the Russian military-industrial complex. Other targets are described as oligarchs, persons involved in the abduction of children from Ukraine, propagandists and persons responsible for looting cultural heritage.

Trade For the first time, the EU has activated its anti-circumvention tool, initially introduced in the 11 th sanctions package in 2023, prohibiting exports of CNC machines and radios to Kyrgyzstan due to the high risk of re-export to Russia. This marks a significant step in the EU’s willingness to deploy trade restrictions against countries facilitating circumvention.

The existing export ban has been expanded to cover new goods, including laboratory glassware, certain high-performance lubricants and additives, chemicals and explosives, rubber, tools for metal production and industrial tractors, with the Commission valuing the new export restrictions at more than €365 million.

Further import restrictions have been introduced on revenue-generating goods, including certain raw materials, metals, minerals, scrap steel and other metals, chemicals and tanned fur skins, with the Commission valuing these at more than €530 million. The list of goods and technology subject to the prohibition on transit via Russian territory has also been extended to reduce the risk of circumvention, and the EU has introduced an import quota for ammonia.

Sixty new entities have been added to the list of parties supporting Russia’s military and industrial complex, on whom tighter export restrictions are imposed regarding dual-use goods and technology. These include 28 entities in China, Hong Kong, Türkiye, Thailand and the UAE.

Diamond traceability requirements have also been tightened, requiring importers of polished diamonds to provide a due-diligence statement confirming that the diamonds were not mined, processed or produced in Russia.

Other Measures The 20 th package introduces a new prohibition on the provision of cybersecurity services to the Russian government or to legal persons and bodies established in Russia. The existing broadcasting restrictions have been expanded to cover “mirror sites” used to circumvent media sanctions.

Notably, the package introduces new legal protections for EU businesses facing Russian expropriation, abusive litigation and IP misuse. These include new transaction bans targeting Russian entities that benefit from the unlawful takeover or “temporary management” of EU-owned assets in Russia, parties seeking to enforce certain Russian judgements outside the EU, and parties using, without consent, the IP rights or trade secrets of Russian subsidiaries of EU right holders. Strengthened private enforcement tools for EU operators have also been introduced, enabling EU companies to sue for damages in EU courts caused by Russian claims enforced in third-country court.

BELARUS The 20th package includes three new listings related to the Belarusian military-industrial complex and the Lukashenko regime, including a Chinese state-owned entity due to its role in the production of Belarusian military goods. Additional measures have been introduced that are intended to mirror those imposed on Russia, including new export and import prohibitions, extension of the list of goods and technology subject to the prohibition on transit via Belarus, a sectoral ban on Belarusian-established crypto asset service providers and a ban on transactions using the Belarusian digital ruble, restrictions on the provision of cybersecurity services to the Belarusian government and tourism services in Belarus, and legal protections against abusive litigation in the Belarusian courts

Conclusion The EU’s latest sanctions package represents another significant escalation in the bloc’s response to Russia’s war in Ukraine. While the headline measure—a full maritime services ban on Russian oil—was ultimately deferred for coordination with the G7 and the Price Cap Coalition, the package introduces sweeping measures across multiple sectors. The first-ever activation of the anti-circumvention tool against Kyrgyzstan, the expansive crypto restrictions and the new protections for EU businesses facing Russian expropriation are all notable developments. As the regulatory landscape evolves, businesses must remain vigilant, continually refreshing their compliance frameworks and risk management strategies to navigate evolving rules.

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