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April 2026 – EU Member States have adopted the 20th package of sanctions against Russia. The package has a pronounced anti‑circumvention focus and significantly expands measures affecting financial services and crypto‑assets. It is expressly designed to close existing and emerging circumvention pathways, including those involving third‑country financial institutions and crypto‑based payment rails. The legal acts entered into force on 24 April 2026.
For EU financial institutions and crypto‑asset service providers (CASPs), the new package raises compliance, enforcement, and governance expectations, requiring a review of exposures, internal controls, and escalation frameworks.
Expansion of banking and payment restrictions
Russian and third‑country banks
The package introduces transaction bans on 20 additional Russian banks, bringing the total number of Russian banks excluded from EU transactions to 70, with only narrow humanitarian exceptions.
For the first time, the EU has also targeted banks in third countries, including institutions in the Kyrgyz Republic, Lao People’s Democratic Republic, and the Republic of Azerbaijan. These banks are sanctioned for facilitating sanctions circumvention or for their connection to Russia’s financial messaging alternative to SWIFT, the System for Transfer of Financial Messages (SPFS).
Payment agents and netting structures
As Russia has been progressively isolated from international financial markets, “payment agents” have emerged as a key workaround. These intermediaries, often active in logistics, trade, or import/export, enable Russian entities to pay foreign suppliers while avoiding traditional banking channels.
The new measures prohibit transactions with identified agents in Russia and third countries that facilitate cross‑border payments for Russian entities. The prohibition explicitly covers payment schemes using third‑country companies, “mirror accounts” inside and outside Russia, and settlement via netting or set‑off, where receivables and payables are offset without funds formally crossing the Russian border. This represents a decisive move against non‑bank financial channels used to circumvent sanctions.
Crypto‑assets and decentralised finance
Sector‑wide ban on Russian crypto-asset services
In response to intensified banking restrictions, Russia has increasingly sought alternative financial channels through digital assets. The EU has therefore introduced a sector‑wide ban on transactions with any Russian crypto-asset service provider (CASP) and a ban covering certain decentralised platforms enabling crypto trading when used for circumvention.
The package also bans the use of and support for RUBx, a rouble‑pegged stablecoin developed by Russian actors and the Digital Rouble, a central bank digital currency under development by the Central Bank of Russia and explicitly viewed as a sanctions‑evasion tool. In addition, the ban extends to the Kyrgyzstani exchange TengriCoin (operating as Meer.kg), where substantial volumes of the Russian government‑backed stablecoin A7A5 have been traded.
These listings demonstrate that the EU is no longer focused solely on permissionless networks or self‑hosted wallets but is directly targeting crypto-assets and platforms developed as functional alternatives to SWIFT and the traditional banking system.
The transaction bans apply from 24 May 2026, allowing a one-month wind-down period.
Extension to Belarus
The financial and crypto‑asset prohibitions introduced under the EU’s 20th sanctions package are expressly mirrored under the Belarus sanctions regime through parallel amending acts. As a result, equivalent transaction and participation bans apply to financial institutions and CASPs established in Belarus, reflecting the EU’s objective to prevent sanctions circumvention via Belarusian intermediaries. The Belarus sanctions regime has been extended by the European Council until 28 February 2027.
What this means
Sanctions enforcement has shifted toward financial function rather than underlying technology, with crypto‑assets now explicitly identified by the European Commission as a high‑risk vector for sanctions circumvention. This recalibration aligns EU sanctions practice with FATF guidance and broader global regulatory expectations, marking a clear end to the treatment of crypto-assets as a peripheral or exceptional category. Crypto‑assets are now firmly embedded within the EU’s financial sanctions perimeter. As a consequence, sanctions expectations for CASPs fully mirror those applied to banks: CASPs are required to implement bank‑grade sanctions controls, and senior management accountability for sanctions compliance is no longer optional but increasingly expected as a core regulatory obligation. Governance frameworks must reflect parity between CASPs and traditional financial institutions.
Required actions for financial institutions and CASPs
Financial institutions and CASPs should undertake a comprehensive reassessment of their sanctions risk posture, beginning with the immediate updating of sanctions screening lists and counterparty databases and a thorough review of legacy correspondent banking relationships, including indirect exposure routed through non‑EU intermediaries. Particular attention should be paid to the re‑evaluation of relationships with payment agents, money transmitters, and informal settlement networks, alongside enhanced monitoring of atypical payment flows, routing instructions, and netting or set‑off arrangements that may signal evasion. Institutions and CASPs should also systematically assess exposure to crypto‑assets, stablecoins, and decentralised platforms for indirect Russian and Belarusian links and implement robust geo‑blocking, KYC, and counterparty controls to fully exclude Russian- or Belarusian-established CASPs. This assessment must extend beyond direct counterparties to include indirect exposure via liquidity provision, technology services, and smart‑contract interactions. Finally, firms should strengthen transaction‑monitoring scenarios specifically calibrated to sanctions evasion typologies and ensure that material findings are promptly escalated to senior management and, where appropriate, to the board or relevant risk committees.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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