EU Adopts 20th Sanctions Package Against Russia

On April 23, 2026, the EU adopted the 20th sanctions package against Russia. The package includes 120 new listings of individuals and companies and tightens the sanctions regime in several areas of particular practical relevance. In addition to the energy and shipping sectors, the focus is also on cryptocurrencies and the "anti-circumvention tool." At the same time, the Council laid the legal groundwork for a future ban on maritime services for Russian oil. Below, we provide an overview of the key changes.

Key elements of the 20th sanctions package in detail

Energy sector: port bans, LNG services, and shadow fleet

In the energy sector, the new sanctions package addresses several issues at once.

• New port transaction bans: The package extends the transaction ban under Article 5ae to two additional Russian ports: Murmansk and Tuapse are added to Part A of Annex XLVII of the Regulation. Furthermore, the package lists a third-country port for the first time: the Karimun Oil Terminal in Indonesia, which is used to circumvent the oil price cap (Part C of Annex XLVII). EU operators are prohibited to engage in transactions with ports and locks as well as airports in Russia as listed in the corresponding Parts A and B of Annex XLVII and of ports and locks in third countries other than Russia as listed in Part C of Annex XLVII. The ban covers, for example, the provision of services, the supply of goods or the delivery of software to the listed airports and ports
   
• LNG service bans: The sanctions package further restricts services for Russian LNG tankers and icebreakers: The provision of maintenance and other services for these types of vessels is prohibited upon the package’s entry into force. Starting in January 2027, EU companies will also be prohibited from providing LNG terminal services to Russian companies or companies controlled by Russian nationals.
   
• Basis for a future maritime services ban: The new sanctions package does not (yet) include a complete ban on maritime services for Russian crude oil and petroleum products. However, the Council has for the first time established the legal basis to implement this ban at a later date and in coordination with the G7. In the future, the EU intends to prohibit the transport of Russian oil as well as related services such as financing and insurance for such vessels.
   
• Shadow fleet: 46 additional ships have been added to the sanctions list, bringing the total number of listed “shadow fleet” vessels (ships used to circumvent sanctions) to 632. In addition, the package introduces mandatory contractual obligations for the sale of tankers: EU sellers must include contractual “no-Russia” clauses that exclude resale to Russian entities or for use in Russia.

Financial Sanctions: Banking Transaction Bans and Cryptocurrencies

• Banks:The package imposes a complete transaction ban on 20 additional Russian banks. For the first time, this also applies to four financial institutions in third countries (Kyrgyzstan, Laos and Azerbaijan), as they are supporting Russia’s war efforts by circumventing sanctions.
   
• First-ever sectoral crypto ban: The 20th sanctions package prohibits EU persons from conducting any transactions with Russian cryptocurrency service providers (CASPs) as well as with decentralized platforms that are based in Russia or enable crypto transfers for Russian users. Unlike previous packages, which listed individual providers (e.g., Garantex), the ban covers the entire Russian CASP ecosystem. Additionally, RUBx (a ruble-backed stablecoin) and the digital ruble (Russia’s CBDC) are included in Annex LIII. 

Combating Circumvention Measures

• First-time activation of the anti-circumvention mechanism: This mechanism, which is set forth in Article 12f and was already introduced with the 11th sanctions package to combat attempts at circumvention, enables the EU to restrict the sale, supply, transfer, or export of certain sanctioned goods and technologies to specific third countries where there remains a particularly high risk of circumvention within their territory. The EU is now imposing export bans on Kyrgyzstan for certain telecommunications equipment for drones and missiles, as well as machine tools for metalworking, which are widely used in the defense industry.
   
• Sanctions against third countries: The EU is also targeting third countries on which the Russian defense industry depends. It is now sanctioning 16 companies from China, the United Arab Emirates, Uzbekistan, Kazakhstan, and Belarus that have supplied dual-use goods or weapons systems to Russia.
   
• Expansion of the prohibition on contract performance: The prohibition in Article 11(1) on fulfilling certain contractual obligations is being expanded. In the future, companies and individuals from third countries (with the exception of EU partner countries listed in Annex VIII ) will also be covered by the prohibition if they sell, supply, transfer, or export, directly or indirectly, goods, technologies, and services whose sale, supply, transfer, or export is prohibited under the Regulation to sanctioned entities or for use in Russia. Accordingly, a payment to a non-EU (and non-Russian) contractual partner would not only be restricted if the partner is controlled by a Russian entity but also if the partner provides sanctioned goods eventually to Russia.

Protection of EU Companies Against Russian Expropriation and Lawsuits

• Strengthening the legal position of European companies: The EU has amended Articles 11a and 11b, thereby specifically strengthening the position of European companies. EU companies can now claim damages before the courts of the Member States where they are sued in third countries other than Russia on claims that could not be performed due to EU sanctions, or where corresponding judgments are enforced against them in those jurisdictions. In such cases, EU companies may bring claims against persons, entities or bodies in those third countries that seek to enforce or support the enforcement of such judgments.
   
• Exceptional release of frozen funds in arbitration proceedings: Frozen funds or economic resources may be released on an exceptional basis to cover the costs of arbitration proceedings initiated by listed persons, provided that the award is in favor of a party that is not listed, not Russian, not established in Russia, and not subject to the relevant EU sanctions regimes.

Practical implications and recommendations

• Immediate screening of the updated sanctions lists for all business relationships, particularly in the energy, shipping, and financial sectors.
   
• Review of all existing LNG service contracts with Russian counterparties and initiation of appropriate termination or restructuring measures.
   
• Conduct a compliance review of crypto and payment services for potential conflicts with the new sectoral CASP ban.
   
• Maritime service ban: Companies in the shipping and logistics sectors should closely monitor this development.
   
• Be aware of third-country risks for shipments to Central Asian countries and other potential sanctions-evasion countries. The activation of the anti-circumvention instrument marks a significant escalation in EU sanctions policy: it demonstrates that the EU is prepared to impose trade restrictions on third countries that become platforms for sanctions evasion. Companies that export to typical sanction-evasion countries (China, Turkey, the United Arab Emirates, and the “CIS states”: Armenia, Azerbaijan, Belarus, Kazakhstan, Kyrgyzstan, Moldova, Tajikistan, Uzbekistan) should closely monitor these developments and identify relevant risks in their supply chains at an early stage.

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