Overview of the EU's 20th sanctions package

On 23 April 2026, the EU adopted its 20th sanctions package against Russia. The package further targets sanctions circumvention activity and tightens restrictions on Russia's energy and financial sectors.

What you need to know

• The EU has used its third-country "anti-circumvention tool" for the first time and banned certain exports to Kyrgyz Republic.
• The package added 60 new entities as subject to dual-use export bans and designated 120 new persons (37 individuals and 83 entities) resulting in asset freezes.
• The EU has ramped up sanctions on alternative payment channels: it has banned all transactions with crypto-asset service providers established in Russia and prohibited the use of Russian digital currencies, including the digital rouble and the rouble-backed stablecoin RUBx.
• The EU has strengthened protections for EU persons against expropriation risks in Russia, litigation relating to sanctions-affected transactions or Russian countermeasures in third countries, and the enforcement of claims linked to sanctioned transactions.
• The package enacts a legal basis to replace, in future, the oil price cap mechanism with a full ban on maritime and transportation services related to Russian crude oil and petroleum products.

Background

On 23 April 2026, the EU adopted its 20th sanctions package against Russia. The package targets sanctions circumvention activity and tightens restrictions on Russia's energy and financial sectors. Certain measures are also reflected in the sanctions regime against Belarus.

Activation of the third-country "anti-circumvention tool"

The EU has designated the Kyrgyz Republic as the first third country directly subject to an export ban on certain listed sensitive dual-use goods. The designation follows the EU's finding that the Kyrgyz Republic poses a systematic and persistent risk of sanctions circumvention. The ban covers a narrow set of items: machining centres for working metal, and equipment for the transmission of voice.

New trade restrictions in the energy and related maritime transport sector

Energy import bans and service restrictions

The package expands existing energy-related import bans and maritime services restrictions from 1 January 2027:

• the existing import ban on Russian crude oil and petroleum products will apply to Russian natural gas condensate.
• EU persons may not provide liquefied natural gas (LNG) terminal services to Russian entities or to entities owned or controlled by Russian nationals or entities. Relevant contracts for LNG terminal services must be terminated by 1 January 2027.
• EU persons are prohibited from providing technical assistance, brokering services, financing or financial assistance to ice-breaker vessels and LNG tankers operating in Russia or for use in Russia. This prohibition applies immediately (as of 25 April 2026) to LNG tankers registered under the Russian flag, certified by the Russian Maritime Register of Shipping, or owned or managed by any Russian nationals.

In addition, the package creates the legal basis for a future, full ban on providing maritime services for the transport of Russian crude oil and petroleum products, terminating the oil price cap exemption. Currently, EU providers may supply these services if the transported oil was purchased at or below the price cap. A full ban will require consultation with G7 partners and the price cap coalition. The EU has not published a timeline for enactment of the ban, but EU persons should prepare for the exemption to end.

Tanker sales

The package tightens the rules on selling tankers to third countries. Previously, sellers only had to notify the sale to competent authorities of the relevant Member State; now they must meet specific due diligence obligations:

• Sale contracts must include a written clause that bans resale or transfer to Russia. The clause must be implemented through the entire chain of ownership: each subsequent purchaser must include it in their onward transactions and ensure that all future buyers are subject to the same obligation.
• Sellers must document a risk assessment of retransfer to Russia and apply proportionate controls to mitigate that risk.
• Sellers must notify the competent authority of the relevant Member State immediately after any sale and provide the seller’s and purchaser’s identities, incorporation documents, and the vessel’s IMO number and call sign.
• The recitals signal that EU persons who undertake proper due diligence and obtain the required contractual commitments will not be liable for a later breach by the buyer, provided they acted in good faith and had no reasonable grounds to suspect sanctions circumvention. The recitals explicitly state that, in such cases, liability would fall on the non-compliant third-country counterparty, suggesting that the EU may consider taking measures against such counterparty.

Port infrastructure bans

The EU added three ports to the restricted ports list, which are subject to a transaction ban: the Russian ports of Murmansk and Tuapse and (for the first time) a third-country port, the Karimun Oil Terminal in Indonesia. The prohibition came into force on 24 April 2026.

Russia's "shadow fleet"

The EU added 46 vessels to its list of Russian "shadow fleet” vessels, bringing the total to 632. Listed vessels cannot enter EU ports and face a ban on a broad range of maritime transport services. The package also delisted 11 vessels following engagement with their owners who gave commitments addressing the EU’s concerns.

New trade restrictions in the finance sector

The EU has also tightened restrictions on Russia's financial sector, focusing on alternative payment channels, by prohibiting any direct or indirect transaction with listed entities:

• Transaction bans on Russian banks: 20 Russian banks were added to the existing transaction ban on Russian credit and financial institutions, effective from 14 May 2026. This brings the total number of Russian banks subject to transaction bans to 70.
• Transaction bans on third-country banks connecting to alternative Russian financial messaging services: the EU has extended the transaction ban to four third-country banks for connecting to the Russian System for Transfer of Financial Messages (SPFS) or equivalent specialised financial messaging services. The four banks are: Keremet Bank and OJSC Capital Bank of Central Asia (Kyrgyz Republic), Joint Development Bank (Laos), and Yelo Bank (Azerbaijan).
• Transaction bans on entities deemed to be frustrating EU sanctions: the EU has also designated four non-financial entities (Arneis, Asia Import Group, GPAgent and Platejka) that enable the performance of international transactions which frustrate EU sanctions, and delisted five third-country financial entities after they committed to stop the activities for which they had been targeted.
• Transaction ban on Russian crypto asset services: EU persons are now banned from transacting with any crypto-asset service provider established in Russia and any platforms established in Russia enabling the exchange or transfer of crypto-assets.
• Transaction ban on Russian digital currencies: from 24 May 2026, EU persons must not use or support the rouble-backed stablecoin RUBx or the digital rouble (a digital currency under development by the Central Bank of Russia). The previous package had already designated the rouble-backed stablecoin A7A5.
• Transaction ban on Russian and third-country netting or set-off service providers: the package also prohibits EU persons from transacting with agents in Russia or in third countries that facilitate the circumvention of Russia’s exclusion from the international payment system. This means that EU persons must not engage with operators that enable international transactions through netting, set-off, reconciliation or settlement where this undermines EU sanctions.

Other trade restrictions

• Import bans: the EU has banned the import of certain raw materials and metals, certain minerals, scrap of steel and other metals, chemicals, articles of vulcanised rubber, and tanned furskins. It has also capped imports of ammonia to an annual quota of 688,000 metric tonnes.

• Import due diligence: importers of polished diamonds must now provide a due diligence statement confirming that the diamonds were not mined, processed, or produced in Russia.

• Export bans and restrictions: the EU has listed additional items subject to export bans or restrictions, including laboratory glassware, certain high-performance lubricants and their additives, energetic materials, chemicals, rubber and articles of vulcanised rubber, articles of steel, tools for metal production, and industrial tractors.

• New listing of entities subject to enhanced export controls. 60 entities have been added to the list of those subject to export bans on listed dual-use and advanced technology items, of which 28 are established in third countries, including China and Hong Kong, Türkiye, Thailand, and the United Arab Emirates.

• Service bans: the list of services which are not to be provided to the Russian Government and Russian entities has been expanded to include "managed security services".

Asset freezing sanctions

The package adds 120 persons (37 individuals and 83 entities) to the asset freeze list. The new listings target Russian energy companies and oil actors (including the producers Bashneft (a Rosneft subsidiary) and Slavneft (jointly owned by Rosneft and Gazprom Neft), and the Afipsky oil refinery) and military companies and their supply chains in third countries (notably Kazakhstan, Uzbekistan, China and Hong Kong, and the United Arab Emirates).

Protection of EU persons

The package adds legal safeguards for EU persons against retaliatory actions by the Russian Government:

• The EU introduced a further anti-suit injunction mechanism that protects EU persons where a Russian court asserts jurisdiction in breach of an exclusive jurisdiction or arbitration clause pursuant to Russian countermeasures (in particular Article 248.1 or 248.2 of the Arbitration Procedure Code of the Russian Federation). Affected EU persons may seek orders from EU courts to uphold the exclusive jurisdiction or arbitration clause and to require Russian counterparties not to initiate, or to discontinue, those proceedings.
• EU persons may also claim damages before Member State courts where third-country courts attempt to enforce judgments based on Russian countermeasures or claims lodged by Russian persons or listed third-country operators connected with the performance of contracts or transactions affected by EU sanctions.
• The package extends the existing prohibition on satisfying claims connected with the performance of contracts or transactions affected by EU sanctions. The prohibition now also applies to claims that third-country persons or entities bring against EU persons where those claims relate to transactions impacted by EU sanctions.

The EU also imposed a framework for further transaction bans (direct and indirect) on listed persons that:

• benefit from "temporary management" or expropriation decisions by the Russian Government; or
• use, pursuant to Russian countermeasures, EU persons' intellectual property rights or trade secrets in Russia without consent.

So far, no designations have been made.

Extension of broadcasting prohibition

The EU has expanded the existing ban on broadcasting certain listed Russian media channels to also cover the broadcasting in the EU of content from entities that mirror or replicate the output of these already prohibited outlets.

Clarification on scope of reporting obligations

The package’s recitals (which are not legally binding) clarify that existing reporting obligations include a duty to report persons who attempt circumvention schemes or carry out transactions which are deemed to be "suspicious".

Other author: Nina Schwartz, Associate