Review of the 20th EU Sanctions Package
On April 23, 2026, the Council of the European Union approved the 20th sanctions package against Russia. The new measures are primarily aimed at the energy, financial, trade and military-industrial sectors, as well as at preventing the circumvention of sanctions through third countries.
As part of the 20th package, the EU activated for the first time the anti-circumvention mechanism by imposing restrictions on the supply of goods to the Kyrgyz Republic that are used for subsequent re-export to Russia. In addition, the package introduces new measures against the “shadow fleet”, Russian banks, crypto-assets, suppliers of dual-use goods, as well as additional procedural safeguards for EU operators.
Blocking sanctions
1. Update of sanctions lists
The list of persons subject to EU blocking sanctions under Regulation 269/2014 has been supplemented by 37 individuals and 80 entities. Standard blocking measures apply to these individuals and entities: asset freezes, a prohibition on making funds and economic resources available to them, and, in relation to individuals, a ban on entry into and transit through the territory of the EU.
The updated sanctions list includes, among others:
Andrey Vladimirovich Polyakov — Director of the Institute for the History of Material Culture of the Russian Academy of Sciences. The ground for listing is related to archaeological excavations carried out in Crimea without Ukraine’s consent.
Aleksey Viktorovich Rtishchev — Head of the Radiation, Chemical and Biological Defence Troops of the Russian Federation.
Olga Mikhailovna Sokolova — General Director of UAMOC LLC, a Russian manufacturer of FPV drones used by the Russian armed forces.
Anton Sergeyevich Anisimov — Deputy Editor-in-Chief of Russia Today, Head of International Broadcasting at Sputnik News Agency and Radio, and Editor-in-Chief of Sputnik News Agency and Radio.
Timur Ildarovich Yunusov, also known as Timati — Russian singer and entrepreneur. The EU refers to his public support for Russia’s policy towards Ukraine.
Among the legal entities included in the sanctions lists are, in particular:
Brightmile Ltd — a company registered in Hong Kong that supplied electronic components to Russian companies associated with the military-industrial complex.
EDM LLC-FZ — a UAE-based company that supplied equipment and dual-use products to Russian counterparties.
SCT Chemicals FZE — a UAE-based company connected with the supply of products for diesel engines used in Russia’s military-industrial sector.
Yangzhou Yangjie Electronic Technology Co., Ltd. — a Chinese manufacturer of semiconductor components that supplied dual-use products to Russia.
Moscow Institute of Physics and Technology — a Russian university which, according to the EU, participates in training specialists for Russia’s military-industrial complex, including in the field of unmanned technologies.
Moran Security Group Ltd — a private maritime security company connected with the protection of vessels transporting Russian oil, LNG and LPG.
PJSC ANK Bashneft, JSC Syzran Oil Refinery, JSC Ryazan Oil Refining Company, JSC Achinsk Refinery VNK — Russian companies in the oil and oil refining sector.
It should be separately noted that the 20th package continues to expand the practice of applying blocking sanctions to persons and companies from third countries where such persons are involved in the supply of critical goods, electronics, UAV components, equipment, dual-use products or other goods used by Russia’s military-industrial complex. The sanctions lists and enhanced export control lists include, among others, companies from China, Hong Kong, the UAE, Turkey, Thailand, Kazakhstan and Uzbekistan.
2. New listing criterion
Regulation 269/2014 has been supplemented by a clarified criterion allowing for the inclusion in sanctions lists of individuals and legal entities that own, control, manage or operate vessels transporting Russian crude oil, petroleum products or mineral products and involved in irregular or high-risk shipping practices. Persons providing material, technical or financial support for the operation of such vessels may also fall under sanctions.
Sectoral sanctions
1. Energy sector
The 20th package provides for 36 listings in relation to representatives of the Russian energy sector, including exploration, production, refining and transportation of oil.
The EU has strengthened restrictions against the “shadow fleet”. A further 46 vessels have been added to the list of vessels prohibited from accessing ports of EU Member States and from receiving a wide range of services. At the same time, 11 vessels have been removed from the list, demonstrating that delisting is possible where sanctions compliance is restored.
Additional requirements are introduced for the sale of tankers from the EU. EU sellers must conduct special due diligence on counterparties and include a mandatory “no Russia” clause in contracts, aimed at preventing the subsequent use of vessels by Russia or in Russia’s interests, including as part of the “shadow fleet”.
Two Russian ports — Murmansk and Tuapse — have been included in the sanctions lists, as well as, for the first time, port infrastructure in a third country: the Karimun Oil Terminal in Indonesia. The ground for listing is connection with the “shadow fleet” and circumvention of the oil price cap mechanism.
A prohibition has been introduced on the provision of maintenance, brokerage services, financing and financial assistance related to Russian icebreakers and LNG tankers. For LNG tankers flying the Russian flag, certified by the Russian Maritime Register of Shipping or owned or operated by Russian persons, the prohibition applies from April 25, 2026. For other LNG tankers operated in Russia or intended for use in Russia, the prohibition will apply from January 1, 2027.
From January 1, 2027, it will be prohibited to provide LNG terminal services to Russian persons, as well as to legal entities in the EU that are more than 50% owned or controlled by Russian citizens or Russian legal entities. After that date, even maintaining contracts for such services will be prohibited.
From January 1, 2027, restrictions on Russian oil and petroleum products will also apply to gas condensate falling under CN subheading 2709 00 10, obtained at LNG production plants.
2. Financial sector
The EU has introduced a prohibition on transactions with 20 additional Russian banks. As a result, the total number of Russian banks excluded from access to the EU internal market has reached 70.
The transaction ban has been extended to four financial institutions from third countries — Kyrgyzstan, Laos and Azerbaijan. The grounds are support for Russia’s military efforts, substantial obstruction of the application of sanctions, or connection to the Russian SPFS system. At the same time, the EU has removed five financial institutions from third countries from the relevant lists after receiving commitments to cease the activities for which they had previously been listed.
A prohibition has been introduced on transactions with Russian crypto-asset service providers, as well as with Russian platforms enabling the exchange or transfer of crypto-assets. The prohibition applies from May 24, 2026, subject to certain exceptions, including transactions necessary for diplomatic and consular missions of the EU and Member States in Russia.
The new measures prohibit transactions involving crypto-assets, including RUBx and the digital rouble, for the purpose of making settlements with sanctioned persons.
Transactions are prohibited with agents and operators in Russia and third countries that help carry out international settlements from Russia in circumvention of EU sanctions, including through netting, set-off, assignment and other settlement schemes without a direct cross-border payment.
3. Military-industrial complex
The 20th package further restricts Russia’s military-industrial complex by listing 58 companies and related individuals involved in the development and production of military goods, including drones.
The sanctions also affect suppliers of critical high-tech goods from third countries, including entities that supplied dual-use goods or weapons to Russia’s military-industrial complex.
Sixty entities providing direct or indirect support to Russia’s military-industrial complex or participating in sanctions circumvention have been added to Annex IV to the sanctions regime. Of these, 32 entities are established in Russia and 28 in third countries, including China, Hong Kong, Turkey, the UAE and Thailand.
4. Trade, export and import
The 20th package introduces new export prohibitions on goods that may contribute to strengthening Russia’s industrial capacities, including chemicals, rubber, vulcanized rubber products, steel products, metalworking tools, industrial tractors and other goods.
Export restrictions have been expanded in relation to goods and technologies used in the interests of Russia’s military efforts, including explosives, laboratory glassware and high-performance lubricants.
New import prohibitions have been introduced for certain goods, including certain raw materials, metals, minerals, scrap steel and other metals, chemicals, vulcanized rubber products and tanned fur skins.
An import quota for ammonia has been introduced in order to limit existing import volumes.
The list of goods and technologies prohibited from transiting through the territory of Russia has been expanded, which is aimed at reducing the risk of circumvention of export restrictions.
5. Information security and research
A new restriction is introduced on the provision of information security management services to Russia. The relevant services have been included in the list of services prohibited from being provided to the Russian government and to legal entities, organizations or bodies established in Russia.
The EU has expanded the prohibition on receiving financing, donations, grants and other economic support from the Russian government in the field of research and innovation. The prohibition applies to research institutes, higher education institutions, enterprises and other participants in research and innovation activities in the EU, as well as to related individuals.
6. Diamonds
Diamond traceability requirements have been clarified. Importers of diamonds must provide confirmation that such diamonds were not mined, processed or produced in Russia.
Other sanctions restrictions
1. Countering sanctions circumvention
The EU has introduced a prohibition on the export of all CNC machine tools and radios to Kyrgyzstan, where there is a high risk that these goods will be re-exported to Russia.
The EU justifies the use of this instrument by noting that, in the first ten months of 2025, imports of common high-priority goods from the EU into Kyrgyzstan were almost 800% above pre-war levels, while exports of such goods from Kyrgyzstan to Russia were 1,200% above pre-war levels.
2. Procedural measures
The 20th package strengthens the legal protection of EU companies against retaliatory actions and abusive litigation in Russia. In particular, courts of EU Member States may issue injunctions ordering that proceedings in Russian courts not be initiated or be discontinued where such proceedings relate to contracts or transactions affected by EU sanctions.
The EU has expanded the possibility for EU companies to recover damages in cases where Russian judicial or administrative decisions are enforced in third countries. This concerns disputes related to contracts affected by sanctions, as well as unlawful expropriation or so-called “temporary management” of assets of foreign companies in Russia.
The Council of the EU has been given the ability to introduce a prohibition on transactions with persons from third countries that facilitate the enforcement of such Russian judicial or administrative decisions.
The possibility has been introduced to restrict transactions with Russian companies that benefit from the de facto unlawful expropriation of assets of EU operators in Russia, including through “temporary management” mechanisms.
The new measures also provide for a prohibition on transactions with Russian persons that use intellectual property rights or trade secrets of EU operators in Russia without their consent.
Practical significance
The 20th package demonstrates a further shift in the focus of EU sanctions regulation from direct restrictions against Russian persons to a broader model of control over supply chains, financial infrastructure, maritime logistics and operations through third countries.
Of particular importance for businesses are measures against sanctions circumvention, including the first activation of the anti-circumvention instrument in relation to the Kyrgyz Republic, the expansion of lists of companies from third countries, the strengthening of due diligence requirements, as well as new prohibitions concerning crypto-assets and payment agents.
