EU Adopts 21st Package of Sanctions: What’s New

On 23 July 2026, the Council of the European Union adopted the 21st package of sanctions against Russia. The principal amendments were made to Council Regulation (EU) No 269/2014, which establishes the asset-freezing regime, and Council Regulation (EU) No 833/2014, which imposes sectoral restrictions. The EU sanctions regime concerning Belarus was also amended.

The package comprises 218 new designations: 48 individuals and 170 entities. This represents the largest single expansion of the EU sanctions lists in the past four years. The principal measures concern the financial sector, crypto-assets, the oil industry, maritime transport, the military-industrial complex, external trade and litigation arising in connection with the application of sanctions.

Most amendments apply from 24 July 2026. Specific commencement dates and transitional periods have been established for certain restrictions.

Asset-Freezing Sanctions

1. Expansion of the Sanctions Lists

A total of 48 individuals and 168 entities have been added to Annex I to Regulation (EU) No 269/2014. Two further entities have been designated under the EU sanctions regime concerning Belarus.

Designation under Annex I to Regulation No 269/2014 entails:

the freezing of all funds and economic resources belonging to, owned, held or controlled by the designated person;
a prohibition on making funds or economic resources available, directly or indirectly, to or for the benefit of the designated person;
in the case of individuals, a prohibition on entry into, or transit through, the territory of EU Member States.

The most extensive designations concern the financial sector. Asset-freezing sanctions have been imposed on 94 banks and other major financial institutions. The newly designated entities include:

DOM.RF Bank;
Russian Agricultural Bank;
Ozon Bank;
Yandex Bank;
Post Bank;
Genbank;
Moscow Exchange.

The designated individuals include representatives of the banking sector, public authorities and Russian media organisations, including Sergei Belov, Deputy Governor of the Bank of Russia; Viktor Zhidkov, Chairman of the Executive Board of Moscow Exchange; Alexander Zharov, Chief Executive Officer of Gazprom-Media; Vladimir Tabak, Chief Executive Officer of ANO Dialog; Vladimir Medinsky, Aide to the President of the Russian Federation; and businessman Mikhail Gutseriev.

A significant proportion of the new designations also concerns entities involved in the production of unmanned aerial vehicles, electronic components, communications equipment, electronic warfare systems and other military or dual-use products.

Asset-freezing sanctions have also been imposed on third-country persons and entities which, according to the Council of the EU, participate in supplies to Russian enterprises, trade in Russian oil or support the operation of the so-called shadow fleet. The relevant designations include entities from China, India, the United Arab Emirates, Oman and Singapore.

2. New Derogations from the Asset-Freezing Regime

Regulation (EU) No 269/2014 has been supplemented with additional grounds permitting the competent authorities of EU Member States to authorise certain transactions involving frozen funds and economic resources.

Such authorisations may be granted, in particular:

for the payment of insurance claims relating to risks connected with vessels included in the sanctions lists;
for the performance of certain obligations under put options for shares or equity interests which arose before 28 February 2022;
for certain transactions necessary for the implementation of the Paks II nuclear power plant project in Hungary;
for certain payments involving Russian Railways.

These derogations are not general in nature. They apply subject to the conditions established by Regulation No 269/2014 and, as a rule, require prior authorisation from the relevant national competent authority.

Sectoral Sanctions

1. Financial Sector

The list of entities subject to the transaction ban under Article 5h of Regulation (EU) No 833/2014 has been expanded to include 33 additional Russian credit and financial institutions.

The newly listed institutions include:

Energobank;
Transcapitalbank;
Unistream Bank;
Credit Ural Bank.

The transaction ban applies from 13 August 2026. The Regulation provides limited derogations for transactions strictly necessary to withdraw funds and close accounts held with newly listed institutions.

The transaction ban has also been extended to four financial institutions outside Russia:

CJSC Eco-Islamic Bank, Kyrgyzstan;
Chinggis Khaan Bank, Mongolia;
Sberbank India;
India VTB.

Eco-Islamic Bank was listed due to its connection to the Bank of Russia’s System for Transfer of Financial Messages. According to the Council of the EU, the other three institutions were involved in activities aimed at circumventing sanctions. At the same time, Yelo Bank was removed from the relevant list.

The transaction ban and asset-freezing sanctions constitute separate legal regimes. The prohibition under Article 5h of Regulation No 833/2014 precludes direct or indirect transactions with the listed entity but does not, in itself, require the freezing of all assets belonging to that entity. Asset-freezing sanctions under Regulation No 269/2014 entail both the freezing of assets and a prohibition on making funds or economic resources available.

In relation to a number of Russian banks, asset-freezing sanctions have been imposed in addition to a pre-existing transaction ban.

2. Crypto-Assets and Payment Infrastructure

The 21st package expands restrictions concerning infrastructure used for settlements involving crypto-assets.

Four additional persons and entities connected with the A7 cross-border payment network, including its subsidiaries and partners in Africa, have been designated.

The transaction ban has also been extended to 14 crypto-asset service providers and crypto-asset exchange and transfer platforms registered or operating in Georgia, Panama, the United Arab Emirates, the Marshall Islands, Kyrgyzstan and Belarus. The listed platforms include Rapira, WhiteBird, HTX and EXMO. Depending on the relevant entity, the prohibition applies from either 13 or 23 August 2026.

Regulation (EU) No 833/2014 has also been supplemented with a mechanism permitting restrictions to be imposed on the crypto-asset infrastructure of an entire third country. The Council of the EU may include a country in the new Annex LVII where it determines that entities established in that country are systematically used to circumvent sanctions.

Once a country is included in Annex LVII, EU persons may be prohibited from entering into transactions with crypto-asset service providers and operators of crypto-asset exchange or transfer platforms established in that jurisdiction. As at the date of adoption of the 21st package, Annex LVII does not list any countries. The new mechanism therefore does not yet automatically impose restrictions in relation to any particular jurisdiction.

From 25 August 2026, the prohibition applicable to Russian nationals and natural persons residing in Russia from owning or controlling, or holding management positions in, EU entities providing crypto-asset services will also be expanded. Previously, the restriction primarily covered crypto-wallet, account and custody services. It will now extend to all crypto-asset services within the meaning of Regulation (EU) 2023/1114.

3. Oil Sector and the Oil Price Cap Mechanism

The EU has suspended the automatic adjustment of the price cap on Russian crude oil for the period from 24 July 2026 to 14 July 2027.

The price cap mechanism itself, together with the related restrictions on the maritime transport of Russian oil and the provision of technical assistance, brokering, financial and insurance services, remains in force.

As part of an interim review, the European Commission must, by 15 January 2027, calculate a new price-cap level by reference to the average market price of Russian oil over the prescribed 22-week period and submit the relevant information to the Council of the EU. The automatic adjustment mechanism is due to resume on 15 July 2027.

Asset-freezing sanctions have been imposed on 18 entities and one individual connected with the oil sector. These include:

three Russian oil refineries;
Mozyr Oil Refinery in Belarus;
European Trading Company LLC, established to market Belarusian petroleum products in Russia.

Five oil traders have separately been added to the list of entities subject to a transaction ban due to their involvement in trade in Russian crude oil and petroleum products. These entities are subject to a sectoral transaction ban rather than an asset freeze.

Asset-freezing sanctions have also been imposed on seven major participants in the Russian gold mining and gold trading sectors and one Russian diamond company. Further designations concern entities operating in the mining and metallurgical sectors.

4. Restrictions concerning Oil Refineries

Regulation No 833/2014 has been supplemented with a legal basis for imposing transaction bans on oil refineries in Russia and third countries which:

refine or blend crude oil and petroleum products of Russian origin;
are used to breach or circumvent sanctions or otherwise significantly frustrate their implementation.

Entities subject to this restriction are listed in Part D of Annex XLVII to Regulation No 833/2014.

The first entity included in the new list is Kulevi Oil Refinery in Georgia. The prohibition on entering into direct or indirect transactions with the refinery applies from 25 January 2027.

5. Liquefied Natural Gas

The 21st package clarifies the scope of the prohibition on providing liquefied natural gas terminal services.

From 1 January 2027, such services may not be provided, directly or indirectly, to:

persons and entities established in Russia;
entities more than 50% owned by Russian nationals or entities established in Russia;
entities controlled by such Russian persons.

The prohibition applies to the relevant entities irrespective of their jurisdiction of incorporation, including entities established outside Russia and the EU. From 1 January 2027, it will also be prohibited to maintain existing contracts for the provision of such services.

An obligation has been introduced to notify the competent authorities immediately of any sale or transfer of ownership of LNG carriers to purchasers in third countries.

The Council of the EU has also established a basis for the possible introduction of additional restrictions on the sale of such vessels to Russian nationals or entities, or for use in Russia. By 25 October 2026, the European Commission must submit an assessment of whether such a prohibition should be introduced.

A specific derogation for supplies from the Sakhalin-2 project has been retained. Subject to the applicable conditions, related supplies of crude oil to Japan and LNG to Japan and the Republic of Korea may continue until 31 March 2028.

6. Shadow Fleet and Maritime Transport

A further 41 vessels have been added to Annex XLII to Regulation No 833/2014. The total number of vessels subject to specific EU restrictions has therefore reached 673.

The grounds for listing vessels have also been expanded. Restrictions may now apply not only to tankers transporting Russian oil in breach of the price cap mechanism, but also to auxiliary vessels supporting the operation of already listed vessels, including by providing:

bunkering;
towage;
supplies;
ship-to-ship transfers;
other services supporting the operation of sanctioned vessels.

Asset-freezing sanctions have also been imposed on eight entities and one individual connected with the infrastructure of the shadow fleet. For the first time, the sanctions list includes a crewing agency which supplied crew members to the relevant vessels.

7. Ports and Airports

Two Russian seaports have been added to Annex XLVII to Regulation No 833/2014:

the Port of Olya;
the Port of Vysotsk.

The Port of Olya was listed due to its use for the transport of unmanned aerial vehicles, missiles and related technologies and components. The Port of Vysotsk was listed in connection with the maritime transport of Russian crude oil and petroleum products by vessels engaging in irregular and high-risk shipping practices.

Restrictions have also been extended to four Russian airports:

Sheremetyevo;
Ulyanovsk-Vostochny;
Platov;
Mineralnye Vody.

These facilities have been included in the list of infrastructure with which EU persons are prohibited from entering into direct or indirect transactions.

8. Military-Industrial Complex and Enhanced Export Controls

Asset-freezing sanctions have been imposed on 56 persons and entities associated with the Russian military-industrial complex. Of these, 37 designations are directly connected with the production of long-range unmanned aerial vehicles and the related supply chains.

In addition, 51 entities have been added to Annex IV to Regulation No 833/2014. These entities are subject to enhanced export restrictions concerning dual-use goods and technologies and goods capable of contributing to the development of Russia’s defence and technological capabilities.

Of the 51 entities:

24 are established in Russia;
27 are established in third countries;
14 are established in China, including four companies in Hong Kong.

The other listed entities are established in India, Kazakhstan, Kyrgyzstan, Türkiye and the United Arab Emirates. According to the Council of the EU, their activities include the supply of microelectronics, computer numerical control machine tools and semiconductor manufacturing equipment.

Inclusion in Annex IV does not constitute an asset-freezing measure. It triggers a more stringent export-control regime under which the availability of exemptions and authorisations for supplying controlled goods to the listed entities is significantly restricted.

9. New Export Restrictions

The list of goods and technologies which may not be sold, supplied, transferred or exported, directly or indirectly, to Russia or for use in Russia has been expanded.

The new restrictions cover, in particular:

nickel powders, metals and alloys used to apply corrosion-resistant coatings to aircraft engines;
beryllium powders used in missile propellants and high-strength alloys;
certain self-adhesive sheets, tapes and strips used in the aviation and defence industries;
ground-support equipment for unmanned aerial vehicles;
electronic jamming, interception and signal-spoofing systems;
launching systems;
servomotors;
flight-termination systems for unmanned aerial vehicles and missiles;
related software.

The applicability of the relevant prohibition must be determined by reference to the applicable commodity code and the technical description of the product in the annexes to Regulation No 833/2014.

10. New Import Restrictions

The list of goods originating in Russia or exported from Russia which may not be purchased, imported into the European Union or transferred to the EU, directly or indirectly, has been expanded.

The following products have, in particular, been added to Annex XXI to Regulation No 833/2014:

copper ores and concentrates — CN 2603;
nickel ores and concentrates — CN 2604;
lead ores and concentrates — CN 2607;
precious-metal ores and concentrates — CN 2616;
zinc oxide and zinc peroxide — CN 2817;
chromium oxides and hydroxides — CN 2819;
tall oil — CN 3803;
glass cullet, semi-finished glass and glassware — CN 7001–7020;
unwrought zinc — CN 7901;
bodies for motor vehicles — CN 8707;
parts and accessories of motor vehicles — CN 8708.

According to the Council of the EU, the new import restrictions cover trade flows worth more than EUR 60 million.

A transitional period has been established for the newly listed goods. The prohibitions do not apply until 25 October 2026 to the performance of contracts concluded before 24 July 2026, or of ancillary contracts necessary for the performance of such contracts.

The applicability of the transitional provision must be determined by reference to the relevant commodity code, the date of the underlying contract and the connection between the relevant supply or transaction and the performance of that contract.

11. Protection of EU Persons in Judicial Proceedings

The 21st package expands the mechanisms under Regulations No 269/2014 and No 833/2014 for protecting EU persons against judicial and administrative decisions adopted in Russia in connection with contracts and transactions affected by sanctions.

Injunctions, orders, judgments and other judicial or administrative acts adopted by Russian courts or public authorities in such disputes may not be recognised, enforced or otherwise given legal effect in EU Member States.

Previously, the relevant rule was directly associated primarily with decisions issued under Articles 248.1 and 248.2 of the Arbitrazh Procedure Code of the Russian Federation or equivalent provisions of Russian law. The amended regime applies to a broader range of Russian judicial and administrative acts relating to contracts and transactions affected by sanctions.

The anti-suit injunction mechanism under Article 11ca of Regulation No 833/2014 has also been expanded. An EU person may apply to a court of a Member State for an order requiring the relevant Russian party:

not to commence, or to discontinue, proceedings before a Russian court;
not to seek recognition or enforcement of a Russian judicial act;
not to rely on such an act in any jurisdiction.

Failure to comply with the court order may result in monetary penalties proportionate to the potential losses of the EU person. The relevant amounts are payable to the person seeking judicial protection.

The grounds for recovering losses incurred by EU persons in connection with Russian judicial proceedings or attempts to recognise and enforce Russian judgments in third countries have also been clarified. Claims may include direct and indirect losses and legal costs. Potential defendants may include third-country persons involved in the recognition or enforcement of the relevant decisions.

12. Visa Restrictions concerning Russian Military Personnel

A legal basis has been established for introducing a general prohibition on the issuance of short-stay visas to Russian military personnel, former military personnel and members of formations associated with the Russian armed forces who participated in hostilities against Ukraine.

The 21st package does not itself bring the prohibition into immediate effect. The date on which the restriction will begin to apply must be established by a separate decision of the Council of the EU.

13. Extension of Deadlines for Exiting Russian Projects

The application of a number of derogations permitting EU entities to complete the winding down of their activities and exit from Russian projects has been extended until 31 December 2027.

The derogations concern, in particular:

the winding up of joint ventures and similar legal arrangements established before 16 March 2022;
the sale of equity interests and assets;
the termination of contractual relationships;
certain transactions involving goods, services and equipment necessary for an orderly exit from the Russian market.

The extension does not constitute a general authorisation to continue doing business in Russia. Each derogation remains subject to the conditions established by the relevant Regulation and, where required, prior authorisation from the competent authority of an EU Member State.

How Jingsh Can Help

We advise Chinese companies operating in Russia and Russian companies doing business in China on the application of sanctions legislation to cross-border transactions and ongoing operations.

Our services include:

preparing reviews of applicable sanctions legislation and advising on the application of restrictions in the relevant jurisdictions;
assessing sanctions risks associated with a particular transaction, supply, payment or corporate structure;
screening counterparties, banks, carriers, vessels and other participants in a transaction;
analysing restrictions applicable to specific goods, technologies or services;
reviewing agreements and preparing sanctions clauses;
providing legal support in structuring payment and logistics arrangements in accordance with applicable law;
preparing legal opinions, where necessary in cooperation with foreign legal counsel;
preparing applications and requests to the competent sanctions authorities;
assisting with applications for authorisations and the use of statutory derogations.