EU Council Adopts 20th Sanctions Package Against Russia

On April 23, 2026, the Council of the European Union (EU) adopted its 20th sanctions package against Russia. The package contains a broad range of restrictive measures across Russia’s energy, extractive, trade, finance, and military sectors, and further targets entities in several non-EU countries for supporting Russia’s military and industrial complex and enabling the circumvention of EU sanctions. For the first time, the package activates the EU anti-circumvention tool by extending certain trade restrictions to Kyrgyzstan due to a systematic and persistent risk of circumvention of EU restrictive measures.

Alongside the Russia measures, the EU has revised the Belarus sanctions regime to mirror certain restrictive measures targeting Russia.

The latest package of EU restrictive measures is set out in nine legal instruments:

• Council Decision (CFSP) 2026/508;
• Council Decision (CFSP) 2026/504;
• Council Decision (CFSP) 2026/512;
• Council Regulation (EU) 2026/506;
• Council Regulation (EU) 2026/511;
• Council Regulation (EU) 2026/513;
• Council Implementing Decision (CFSP) 2026/503;
• Council Implementing Regulation (EU) 2026/509;
• Council Implementing Regulation (EU) 2026/505.

Individual designations

As part of the 20th sanctions package, 117 individuals and entities are designated under the EU asset freeze sanctions against Russia.¹ The new designations include 36 entities and individuals operating in the upstream and downstream segments of the Russian energy sector, and 58 companies and associated individuals involved in the Russian military-industrial complex. The EU has also designated six entities based in China, eight entities based in the United Arab Emirates, and four entities based Central Asian countries.

In addition, the 20th package includes three new designations under the Belarus sanctions regime.² For the first time, a Chinese state-owned entity is targeted under the Belarus sanctions regime, due to its role in the production of Belarusian military goods.

Restrictive measures on the energy sector 

The energy sector is among the most significantly impacted by the 20th sanctions package. A full prohibition on providing liquefied natural gas (LNG) terminal services to Russian individuals or entities, or to EU-based entities which are owned or controlled by Russian nationals or entities, will take effect on January 1, 2027.³

It is also prohibited to provide technical assistance, brokering services, financing, or financial assistance related to icebreakers that are Russian flagged, owned or managed, or that operate in Russia. The same prohibition applies to LNG tanker vessels that are Russian flagged, owned, or managed as of April 25, 2026, and to all other LNG tankers operating in Russia as of January 1, 2027.⁴

The 20th package lays the groundwork for a future full prohibition on maritime services related to the transport of Russian crude oil and petroleum products, subject to agreement by the G7 and the Price Cap Coalition, and a subsequent Council decision.⁵

Further key changes include:

• The listing of 46 additional shadow fleet vessels that are subject to a port access ban and a ban on the provision of a broad range of services related to maritime transport, bringing the total number of listed vessels to 632.
• The introduction of enhanced safeguards on the sale or transfer of ownership of tanker vessels, requiring EU operators to carry out mandatory due diligence⁶ and to include contractual clauses prohibiting any resale or transfer of such vessels to Russia or for use in Russia.⁷
• From January 1, 2027, the prohibitions on the purchase, import, or transfer of Russian crude oil or petroleum products, and on the provision of related technical assistance, financing, or financial assistance, will apply to natural gas condensate.⁸ 
• Liechtenstein has been added to the list of partner countries not required to provide evidence of the country of origin of crude oil used for the refining of the product.⁹
• Extension of the port infrastructure ban to two additional Russian ports of Murmansk and Tuapse, and, for the first time, a third-country port (the Karimun Oil Terminal in Indonesia), due to their involvement in the circumvention of the Oil Price Cap.
• The designation of entities involved in the Russian energy sector and shipping sectors, including companies within the Rosneft group, notably PJSC Bashneft Oil Company, JSC Angarsk Petrochemical Company, and the Ryazan, Syzran, and Tuapse oil refineries; oil production and refining entities within the Slavneft group; refining and upstream subsidiaries of Lukoil, including Lukoil Nizhnevolzhskneft and LLC LUKOIL-Permnefteorgsintez; as well as energy‑related shipping and logistics companies such as Rosnefteflot and Gazprom Flot.¹⁰

Trade restrictions

The new sanctions package further restricts trade with Russia by imposing the following additional restrictive measures:

• Extension of export restrictions to additional goods which might contribute to the enhancement of Russian industrial capacities, such as certain chemicals, rubber, and articles of vulcanized rubber, industrial fasteners including screws, bolts, wire, and rods, and high-power tractors.¹¹
• The list of items, which are subject to export restrictions due to their ability to contribute to Russia’s military and technological enhancement or to the development of its defense and security sector, has been expanded to include laboratory, hygienic, or pharmaceutical glassware; lubricant materials, fluids, and additives; energetic materials and explosives such as amatol, nitroglycol, and picryl chloride; as well toluene diisocyanate in all isomeric forms.¹²
• Extension of import restrictions to additional goods which generate significant revenues for Russia, such as salts, sodium chloride, ammonia, pebbles, gravel, articles of vulcanized rubber, quicklime, tanned or dressed fur skins, and various metals and metal scrap, including copper, nickel, and aluminum.¹³
• Activation of the anti‑circumvention tool to address systematic and persistent sanction circumvention risk, by prohibiting exports of machining centers for working metal and certain telecommunications equipment to Kyrgyzstan.¹⁴
• An obligation for EU operators importing polished diamonds into the EU to provide traceability evidence, such as due diligence statements confirming that the diamonds were not mined, processed, or produced in Russia.¹⁵

Further key changes include:

• Listing an additional 60 Russian and third‑country entities (including entities based in China (Hong Kong), Türkiye, the United Arab Emirates, and Thailand) that are subject to tighter export restrictions in relation to dual-use goods and goods which contribute to the technological enhancement of Russia’s defense and security sector.¹⁶
• Introduction of a yearly quantitative import quota on Russian ammonia.¹⁷

Lastly, the 20th sanctions package amends or introduces certain derogations, including regarding export of dual-use goods,¹⁸ import of certain restricted goods which generate significant revenue for Russia and related services until April 25, 2031,¹⁹ and export of certain restricted goods which could contribute to the enhancement of Russian industrial capacities.²⁰

Restrictions on access to finance and financial services 

To further constrain Russia’s financial capacity and restrict access to alternative payment channels and financial technologies used to evade EU sanctions, the 20th sanctions package introduces the following measures:

• From May 24, 2026, a prohibition on engaging in any transaction with Russian crypto-asset services providers and platforms enabling the exchange or transfer of crypto-assets.²¹
• A prohibition on engaging in any transaction involving the rouble‑backed stablecoin RUBx and the digital currency under development by the Central Bank of Russia, known as the digital rouble.²²
• A ban on transactions with entities that are neither credit nor financial institutions, nor providers of crypto‑asset or payment services, but that provide services enabling the execution of international transactions which frustrate the purpose of EU sanctions.²³ These include the Russian companies Arneis, GPAgent, and Platejka.²⁴
• Extension of the existing prohibition on accepting financing, donations, or other economic benefits or support from Russia.²⁵
• The designation of CJSC TengriCoin, a Kyrgyzstani company operating the Meer platform, which is widely used for trading the stablecoin A7A5.
• Listing additional financial institutions which are subject to a full transaction ban, namely: 20 Russian banks and entities owned by them;²⁶ three third-country banks based in Laos and Kyrgyzstan that significantly frustrate sanctions or support Russia’s war of aggression against Ukraine;²⁷ and one third-country bank established in Azerbaijan, as a result of its connection to the Russian System for Transfer of Financial Messages (SPFS).²⁸

The EU has also delisted five third-country banks established in China and Tajikistan, following commitments that they will no longer engage in activities that significantly frustrate EU sanctions.²⁹

Restrictive measures on services 

Specific measures are introduced in relation to the provision of certain services, including:

• From May 25, 2026, a prohibition to provide management security services to the Government of Russia or to legal persons or entities established in Russia.³⁰
• A ban on the provision of services directly related to tourism activities in Belarus.³¹

Additional restrictive measures and other amendments

The 20th sanctions package introduces additional restrictive measures, including:

• New bans on transactions with:
  • Entities that benefit from Russian ‘temporary management’ (expropriation) decisions pursuant to Russian legislation;³²
  • Individuals and entities that seek to enforce/cooperate in the enforcement outside the EU of Russian judgements and administrative decisions which relate to contracts impacted by EU Russia sanctions, illegal expropriations, or so-called ‘temporary management’,³³ including entities that are owned or controlled by such individuals and entities;³⁴
  • Entities that, pursuant to Russian countermeasures, legislation, or court orders, have used or are using intellectual property rights or trade secrets without the consent of the EU right holder.³⁵
• An expansion of the broadcasting ban to include online content from entities that mirror the content of broadcasters already targeted by EU sanctions, in order to prevent circumvention attempts.³⁶
• A requirement for EU intellectual property right holders to notify national competent authorities of any use of their intellectual property rights or trade secrets without their consent.³⁷

The package reinforces legal safeguards for EU operators, particularly in response to Russian countermeasures and related judicial proceedings. EU operators are entitled to seek compensation before Member States’ courts for (indirect) damages arising from judicial or administrative decisions rendered in third countries other than Russia, which seek to enforce third-country judgments upholding claims in connection with contracts or transactions affected by EU sanctions, or the Russian countermeasures.³⁸

Where Russian courts unjustifiably assert jurisdiction over disputes against EU operators concerning contracts affected by EU sanctions, EU operators are also entitled to obtain court orders from Member State courts, which uphold the agreed arbitration or exclusive jurisdiction clauses and order the relevant persons to not initiate or discontinue legal proceedings in Russia. Where such court orders are not complied with, Member State courts may impose proportionate financial penalties, payable to the affected EU operator.³⁹

Impact on business

EU operators should assess how the new restrictions affect their transactions, including whether any exemptions or derogations may apply. Several measures introduced by the 20th sanctions package provide for deferred application dates, while others allow for limited transitional periods to complete the performance of ongoing contracts.

Furthermore, EU operators should also take proactive steps to strengthen their sanctions compliance processes through updated due diligence, counterparty screening, and monitoring of ownership and control structures. Businesses with direct or indirect exposure to Russia, Belarus, or certain third countries should accordingly review their supply chains, contractual arrangements, financing structures, and broader risk‑management strategies.

At the same time, the further legal safeguards introduced by the package provide EU operators with additional tools to mitigate the impact of Russian countermeasures and might enable EU operators to reduce the financial impact of sanctions-related disputes.

Footnotes

1. Annex to Council Implementing Regulation (EU) 2026/509.

2. Annex to Council Implementing Regulation (EU) 2026/505.

3. Article 3rb of Regulation (EU) 833/2014.

4. Article 3sa of Regulation (EU) 833/2014.

5. Article 3n of Regulation (EU) 833/2014.

6. Including transaction screening and implementation of appropriate policies, controls, and procedures.

7. Article 3q of Regulation (EU) 833/2014.

8. Articles 3n of Regulation (EU) 833/2014.

9. Annex LI to Regulation (EU) 833/2014.

10. Annex I to Regulation (EU) 269/2014. 

11. Annex XXIII to Regulation (EU) 833/2014. 

12. Annex VII to Regulation (EU) 833/2014. 

13. Annex XXI to Regulation (EU) 833/2014. 

14. Annex XXXIII to Regulation (EU) 833/2014.

15. Article 3p of Regulation (EU) 833/2014.

16. Annex IV to Regulation (EU) 833/2014. 

17. Article 3i of Regulation (EU) 833/2014. 

18. Articles 2 and 2a of Regulation (EU) 833/2014.

19. For items falling under CN codes 7007, 7019, 8424 10 00, 8479, 8481, 8483, 8487, 8504, 8516 29 91, 8517, 8525, 8531, 8536, 8537, 8538, 8539, 8542, 8543, and 8603, as referred to in Article 3i of Regulation (EU) 833/2014.

20. Article 4 of Regulation (EU) 833/2014.

21. Article 5bb of Regulation (EU) 833/2014

22. Article 5ba of Regulation (EU) 833/2014.

23. Article 5ad of Regulation (EU) 833/2014.

24. Part D of Annex XLV to Regulation (EU) 833/2014.

25. Article 5t of Regulation (EU) 833/2014.

26. Annex XIV to Regulation (EU) 833/2014.

27. Part A and B of Annex XLV to Regulation (EU) 833/2014.

28. Annex XLIV to Regulation (EU) 833/2014.

29. Part A of Annex XLV to Regulation (EU) 833/2014.

30. Article 5n of Regulation (EU) 833/2014.

31. Article 1jc of Regulation (EU) 765/2006.

32. Article 5ai and Annex LIV of Regulation (EU) 833/2014.

33. As determined in Article 11a of Regulation (EU) 833/2014.

34. Article 5aj and Annex LV of Regulation (EU) 833/2014.

35. Article 5sa and Annex LVI of Regulation (EU) 833/2014.

36. Article 2f of Regulation (EU) 833/2014.

37. Article 5sa of Regulation (EU) 833/2014.

38. Articles 11a and 11b of Regulation (EU) 833/2014.

39. Article 11ca of Regulation (EU) 833/2014.

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