The EU's 20th Sanctions Package Against Russia

On 23 April 2026, the Council of the European Union adopted its 20^th package of sanctions against Russia. The package represents a material expansion of the EU's sanctions framework, expanding existing prohibitions across the energy, financial services, and trade sectors, as well as activating the new anti-circumvention tool for the first time. 

Anti-circumvention tool

The EU has activated its anti-circumvention tool for the first time and targeted Kyrgyzstan, by prohibiting the export of any computer numerical control machines or radios to Kyrgyzstan. While the anti-circumvention tool has been in existence since the 11^th Russia sanctions package was adopted in June 2023, this is the first time the EU has deployed it in practice.

This activation carries broader significance, as the measure aims to assess diversion risk via the destination country, rather than specific counterparties involved in a transaction. For businesses, this activation certainly expands the perimeter of risk and will demand greater counterparty due diligence, end-use controls, and monitoring of exports.

Energy restrictions

• New designations: The EU added 120 new listings overall, including among others, (1) a further 36 entities across the Russian energy sector and (2) additional 46 shadow fleet vessels. 58 designations specifically target actors associated with Russia’s military‑industrial complex, including 16 entities established in third countries, notably China, UAE, Belarus, and states in Central Asia. Notably, the EU also de-listed 11 vessels, signalling that a pathway back to compliance remains available.

• Tanker sales: The EU introduced new safeguards on tanker sales from the EU to prevent Russian end-use. EU sellers must now conduct dedicated due diligence, and incorporate a mandatory “no Russia” clause into sales contracts. The sanctions package also introduces a shadow fleet scrapping clause to facilitate the decommissioning of vessels.

• Port infrastructure ban: Port listings now include two additional Russian ports (Murmansk and Tuapse), and, for the first time, a third country port (Karimun Oil Terminal in Indonesia). This reflects the EU's increasing willingness to target infrastructure outside Russia where there is evidence of connections with the shadow fleet and/or circumvention of the oil price cap.

• Future maritime services ban: The EU established a legal basis for a future comprehensive maritime services ban on the transport of Russian crude oil and petroleum products, following coordination and discussion with the G7 and the Price Cap Coalition. The EU is yet to decide when the maritime services ban is to enter into force.

• LNG bans: A new prohibition was established on maintenance and other services for Russian LNG tankers and icebreakers. Additionally, there is now a ban on LNG terminal services to allow EU operators to terminate long-term contracts with Russian counterparts.

Financial services restrictions

• Russian banks: The EU imposed a transaction ban on 20 additional Russian banks.

• Third country banks: In addition, the EU has imposed a transaction ban on four financial institutions in Kyrgyzstan, Laos, and Azerbaijan for facilitating Russia's war effort. These designations underscore that the EU will apply transaction bans to non-Russian financial institutions where there is evidence of sanctions circumvention. Notably, the EU also de-listed five third-country financial entities, which committed to refrain from engaging in activities that resulted in their listing. 

• Digital assets: The EU introduced a total sectoral ban on exchanges with any Russian crypto asset service provider, including decentralised platforms due to circumvention concerns. Additionally, the new measures prohibit the use and support of specific Russian cryptocurrencies, including the RUBx stablecoin and Digital Rouble.

• Payment services agents: The package prohibits transactions with agents in Russia and other third countries that offer to facilitate international transactions from Russia to bypass EU sanctions.

Trade bans

• The 20^th sanctions package introduces new export bans on goods including laboratory glassware, certain lubricants, energetic materials, and chemicals worth over €365 million and import bans on goods including certain metals, chemicals, and minerals worth over  €530 million, and a new quota will be introduced to cap ammonia imports. Furthermore, a new prohibition on the provision of cybersecurity services to Russia has also been included.

Other measures

• A few other miscellaneous measures have been introduced, such as (1) legal protections for EU firms against retaliatory actions by the Russian government, (2) measures to prevent circumvention of the Russian propaganda broadcasting ban, and (3) restrictions on acceptance of research and innovation funding by the Russian government.

• Finally, the 20th sanctions package also aligns the EU sanctions targeting Belarus more closely with those imposed on Russia, introducing some mirrored restrictions in areas including trade, legal protection, measures on cryptocurrency, and restrictions on the provision of cybersecurity services and tourism services.

Practical Next Steps

• Screen against expanded designations. Ensure existing sanctions screening lists are up-to-date and include any new listings, including third-country entities linked to Russia's military-industrial complex, and the newly designated banks and shadow fleet vessels. 

• Strengthen export due diligence. Review end-use controls, counterparty due diligence, and monitoring of exports, particularly for goods with potential dual-use applications. 

• Review maritime and energy contractual arrangements. Vessel sellers must incorporate "no Russia" clauses; LNG operators should assess whether new prohibitions affect existing contracts. Additionally, entities with maritime exposure should monitor developments regarding the forthcoming comprehensive maritime services ban.

• Audit digital asset and payment channels. Review any touchpoints with Russian digital infrastructure in light of the additional financial services restrictions. 

• Reassess Belarus exposure. The alignment of Belarus sanctions with Russia means that Belarus-facing activities now carry increased compliance risk across all areas. 

Subscribe to Ropes & Gray Viewpoints by topic here.