EU update: 20th package of sanctions in reaction to Russia’s invasion of Ukraine

The EU adopted its 20^th package of sanctions against Russia on 23 April 2026, with a strong focus on anti-circumvention and new energy-related measures. Additional financial and trade restrictions have also been adopted:

• Additional listings mainly targeting Russia’s energy, ‘shadow fleet’ ecosystem and defence sectors.
• Ban on natural gas condensate and LNG terminal services allowing termination of long-term contracts with Russian counterparties.
• Anti‑circumvention tool: First use of the tool in response to systematic failure by Kyrgyzstan to prevent the sale, supply, transfer or export to Russia of certain high-risk items, thereby undermining the effectiveness of existing sanctions.
• Further restrictions targeting the Russian ‘shadow fleet’: 46 additional ships listed and banned from EU ports and services (11 vessels delisted, reflecting restored compliance) and designation of ports and locks.
• Financial and crypto sanctions: Ban on the RUBx cryptocurrency and digital rouble; full sectoral ban on dealing with Russian crypto‑asset service providers and decentralised platforms.
• Military sanctions: 58 companies and individuals developing military goods listed, covering third country suppliers of critical items to Russia.
• Trade and export restrictions: New export bans on goods and technologies used in Russia’s military sector; new import bans on commodities not previously covered.
• Protection of EU operators: New rule allowing Russian abusive lawsuits in Russia to be sanctioned and enabling damages claims where such judgments are enforced in third countries; full transaction ban on third country actors assisting in their enforcement.
• Protection of EU research: New rules prohibiting acceptance of R&I funding from the Russian government.

ENERGY MEASURES

With the aim of further reducing Russia’s revenues and constraining its ‘shadow fleet’, the 20^th EU sanctions package expands restrictions on Russia’s energy sector:

• The prohibitions to import crude oil or petroleum products from Russia and to provide related ancillary services, as well as the prohibition to engage in ancillary services related to transactions concerning crude oil and petroleum from Russia to a third country, have been extended to natural gas condensate (CN 2709 00 10) from liquefied natural gas production plants, as of 1 January 2027.
• The 20^th package further enables the Council, upon a joint proposal of the High Representative and the Commission, to decide whether the oil price cap should be applied. The price cap works as an exemption to the ban on services related to trade in Russian petroleum products. The level of the cap is determined jointly by the Price Cap Coalition, composed of G7 members and other participating countries. The modification introduced would allow the removal of the exemption on services provided in relation to volumes purchased below the price cap, effectively enacting a “full ban”.
• From 1 January 2027, EU operators will be prohibited from providing LNG terminal services to Russian persons or entities and to entities established in the EU owned by more than 50% or controlled by Russian persons, entities or bodies. Any contract covering such services must be terminated by then.
  New restrictions include a ban on ancillary services related to Russian-linked LNG tankers and icebreakers. These restrictions significantly limit the capacity of EU operators to service and support these vessels as from 25 April 2026 or 1 January 2027, depending on whether the LNG tankers are Russian‑flagged, certified by the Russian Maritime Register of Shipping, owned or managed by Russian persons, or are others operating in or for use in Russia.
• The 20^th package further targets the Russian ‘shadow fleet’. EU operators, when selling tanker vessels for the transport of crude oil or petroleum products to third country persons or entities, must carry out proportionate due diligence, including screening all parties, and insert a mandatory ‘no-Russia clause’ prohibiting the resale or transfer of the vessel to a person or entity in Russia or for use in Russia. The sales are further to be notified to national authorities. Recitals to the Regulation clarify that, where the EU seller has exercised adequate due diligence and obtained the required contractual commitments, any subsequent breach of the ‘no-Russia clause’ will result in liability resting with the third country buyer in breach of the obligation rather than with the EU seller.
  The Russian ports and locks of Murmansk and Tuapse have been subjected to a full transaction ban because of their use by ‘shadow fleet’ vessels and engagement in circumvention practices. The Indonesian Karimun Oil Terminal has been designated for the same reasons.
• 36 listings related to the Russian energy sector have been added, as have 46 vessels (while 11 entries have been deleted) to the list of vessels that are subject to restrictions, such as being provided access to ports or flag registration.

FINANCIAL MEASURES

The 20^th EU sanctions package further tightens financial restrictions by extending transaction bans to additional banks and financial operators:

• The package introduces a full transaction ban with any crypto-asset service providers and platforms facilitating the transfer or exchange of crypto-assets established in Russia as from 24 May 2026. The ban aims at addressing the transfer of the activities of Garantex, the Russian cryptocurrency exchange platform targeted by financial restrictive measures, to other Russian entities to evade sanctions.
  The prohibition to engage in transactions involving crypto-assets has been amended to extend its coverage to central bank digital currencies and any support to the development of those crypto-assets or central bank digital currencies. As of 24 May 2026, transactions involving the cryptocurrency RUBx or the digital rouble will be prohibited (on top of A7A5, already prohibited).
• The package further expands the financial-sector measures by adding 20 Russian, or Russian-linked, credit and financial institutions to the full transaction ban list. The ban targets key banks for the Russian system including large or important regional banks, institutions handling cross-border payments, banks active in occupied Ukrainian territories, those serving Russian military personnel, and entities already sanctioned.
  The transaction ban further targets third country financial entities established in Azerbaijan, Kyrgyzstan, and Laos which provide financial support to Russia through the use of the Russian SPFS payment system or any system provided by the Central Bank of Russia or any other Russian entity, or by helping to circumvent EU sanctions (e.g. through netting, set-offs or settlement).
• 5 previously listed third country financial entities from China and Tajikistan have been withdrawn from the EU sanctions lists for having closed loopholes and stopped illicit activities.

TRADE MEASURES

The 20^th EU sanctions package significantly tightens trade restrictions on Russia, targeting items supporting Russia’s military sector:

• The package strengthens export restrictions on goods and technology which might contribute to Russia’s military and technological enhancement, such as amatol, nitroglycol and picryl chloride, as well as lubricating materials, fluids and additives thereof, and laboratory, hygienic or pharmaceutical glassware. The scope of export prohibitions concerning goods which could contribute to the enhancement of Russian industrial capacities has also been expanded, thus including goods such as safety fuses, hard rubber, wire, rods, tubes, plates, electrodes and similar products of base metal, or certain types of tractors.
• The newly adopted measures also extend export prohibitions concerning dual-use goods and technology, and other specified goods and technology, such as electronics, to 60 additional entities. These include 32 Russian entities and 28 third country entities established in China (including Hong Kong), Thailand, Türkiye and in the UAE, that indirectly support Russia’s military-industrial complex.
• The sanctions’ anti‑circumvention tool is used for the first time. In response to sharp increases in Kyrgyzstan in imports of EU common high priority items and their subsequent re-export to Russia, the sanctions designate 2 sensitive items (namely machining centres for working metal and machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus) the export of which to Kyrgyzstan is now prohibited.
• New import restrictions have been introduced on goods generating significant revenues for Russia, namely chemicals (like sulphates and sodium hydroxide), minerals (including salt and magnesium), specified forms (like powders and flakes or waste and scrap) of certain metals (such as aluminium, copper, nickel, molybdenum) and other goods such as articles of vulcanised rubber and tanned fur skins.
  By way of exception, imports of ammonia into the EU are permitted, together with the necessary purchase, transport and related technical or financial assistance, up to an annual volume of 688 000 metric tonnes for each period running from 24 April of one year to 23 April of the following year.
• “Managed security services” are now included among the services that EU operators are prohibited from providing to Russia as of 25 May 2026.

ADDITIONAL LISTINGS AND ASSET FREEZE MEASURES

The new sanctions package extends the scope of asset freeze.

• 120 natural persons and entities have been added as subject to an asset freeze and a travel ban (only as it concerns individuals). All newly listed individuals are Russian nationals, while listed entities are registered all around the world (China, including Hong Kong, Russia, Kazakhstan, Kyrgyzstan, Seychelles, UAE, Uzbekistan).
• The Package also provides for an exceptional release of frozen assets to enable the payment of the arbitral proceeding costs, whenever (i) these costs are awarded to a non-listed or non-Russian entity, (ii) the proceedings have been initiated by the listed person or entity, and (iii) the decision was rendered after its inclusion in the asset freeze list.

LEGAL PROTECTION OF EU OPERATORS

The 20^th EU sanctions package further enhances EU operators’ legal protection:  

• The ‘no-claims clause’^[1] has been reinforced, foreseeing additional categories of entities, whose claims shall not be satisfied:
• For claims related to contracts the performance of which has been affected by Regulation (EU) 833/2014: Non-Russian third country persons or entities, who export goods, technology and services to listed entities, to Russian persons or entities, or to entities acting on their behalf, or for use in Russia, where the export is prohibited.
• For claims related to contracts the performance of which has been affected by Regulation (EU) 269/2014: Third country persons or entities, who make funds or economic resources available to listed persons or entities or to any person or entity acting on their behalf.
• The newly adopted measures aim at protecting EU operators from proceedings in Russia and other third countries.
• In addition to the existing right for EU operators to claim recovery for the damages resulting from claims lodged in third countries concerning contracts or transactions affected by the sanctions, EU operators are entitled to seek recovery of damages resulting from third country judgments upholding such claims. Recovery can also be pursued for damages resulting from third country decisions enforcing Russian expropriation of EU operators (so-called ‘temporary management‘).
• The package introduces further protection for EU operators in the context of proceedings initiated in Russia by a listed entity or on its behalf which should have been brought before non-Russian courts or an arbitral tribunal and related to any contract or transaction the execution of which has been affected by the sanctions. Whenever the proceedings are in breach of an exclusive jurisdiction or of an arbitration clause, the EU operator has a right to obtain a court order within the jurisdiction of a Member State upholding the exclusive jurisdiction or arbitration clause. If the targeted entity does not observe the order to abandon the legal proceedings, it can be subject to financial penalties proportionate to the potential loss which could be incurred. This provision targets the extensive use by Russian courts of Articles 248-1 and 248-2 of the Russian Arbitrazh Procedure Code, which were adopted in June 2020, since the invasion of Ukraine.
• For better effectiveness, where no court is competent, the Package allows these damage recovery claims to be brought before a Member State’s court, provided there is a sufficient connection between the relevant Member State and the case.
• Additional full transaction bans have been introduced, namely towards:
• Russian entities that benefit from the expropriation of EU operators pursuant to Russian legislation,
• Entities who seek, or cooperate in, the enforcement outside the EU of the Russian expropriation legislation or of third country judgments satisfying claims related to any contract or transaction, the execution of which has been affected by the sanctions, and
• Russian entities that violate IP rights or trade secrets of an EU operator.

OTHER MEASURES

Further existing measures are reinforced to strengthen the effectiveness of sanctions:

• The package extends the broadcasting prohibition to so-called “mirror entities”, which have a significant link to specified banned operators (e.g. identical content, branding, ownership, users or technical infrastructure).
• The prohibition for political parties within the EU, EU NGOs and EU media service providers to accept funds, directly or indirectly, from the Russian government is extended to the R&I sector, notably to research institutions, universities and companies.

BELARUS

The 20^th EU sanctions package extends measures to Belarus, largely aligning them with the Russia sanctions regime:

• The EU extends the asset freeze list to further entities tied to the Belarusian military-industrial complex and the Lukashenko regime. The package also foresees a set of measures mirroring those imposed on Russia in the areas of trade, legal protection, crypto-assets and restriction of cybersecurity services.
• The provision of services directly related to tourism in Belarus is prohibited, as it already is the case for Russia with the 19^th sanctions package.

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Gide’s International Trade & EU Regulatory teams in Brussels will provide further updates and guidance as matters continue to unfold.

Our Teams will gladly assist in case of any questions or need for legal assistance in ensuring compliance when dealing under the newly adopted sanctions.

[1] The ‘no-claims clause’ prohibits the satisfaction of any claim related to any contract or transaction whose execution has been affected by the EU’s sanctions.