EU adopts its 20th sanctions package against Russia and additional restrictive measures against Belarus

On 23 April 2026, the EU adopted its 20^th package of restrictive measures (sanctions) against the Russian Federation. Concurrently, the EU has also adopted further restrictive measures targeting the Republic of Belarus.

The measures were adopted through:

• Council Regulation (EU) 2026/506 of 23 April 2026 amending Regulation (EU) No 833/2014;
• Council Regulation (EU) 2026/511 of 23 April 2026 amending Regulation (EU) No 269/2014;
• Council Implementing Regulation (EU) 2026/509 of 23 April 2026 implementing Regulation (EU) No 269/2014;
• Council Implementing Regulation (EU) 2026/505 of 23 April 2026 implementing Article 8a (1) of Regulation (EC) No 765/2006; and
• Council Regulation (EU) 2026/513 of 23 April 2026 amending Regulation (EC) No 765/2006.

The new sanctions package (i) imposed asset freezes on certain persons and entities, (ii) further restricted LNG terminal services and LNG tanker operations, (iii) expanded export and import restrictions targeting additional categories of goods and new third country entities allegedly circumventing those, (iv) extended financial and crypto-asset prohibitions, (v) imposed new service bans covering managed security services and research funding, and (vi) strengthened the legal protection framework for EU operators.

Outlined below are the main elements of the latest package.

1. Asset Freezes

New designation criteria and derogations

With its 20^th package, the EU has implemented certain amendments to Regulation 269/2014.

First, the designation criterion authorizing the imposition of an asset freeze and the prohibition to make funds and economic resources available to persons that own, control or manage tankers and practice irregular and high-risk shipping practices has been expanded to include the owners, controllers and managers of vessels that transport mineral products and persons that otherwise provide material, technical or financial support to the operation of such vessels.

Second, new derogations from the asset freeze and prohibition to make funds and economic resources available to designated persons have been introduced when necessary in the following circumstances:

- for the work of state-funded intermediators for the foreign cultural policy of the Member States in Russia, such as cultural institutions, schools or supporting Member States’ ethnic minorities; and

- to cover arbitration costs, including tribunal fees, institutional expenses and reasonable legal costs of the opposing party, awarded in proceedings initiated by a sanctioned entity. The derogation does not extend to the payment of damages, interest, or any substantive claims and the costs must be awarded to a party that is neither sanctioned nor established in Russia.

Additional derogations have been introduced to allow (i) certain payments to the sanctioned Tikhomirov Scientific Research Institute of Instrument Engineering (entry no. 265); and (ii) subsequent to the designation of Soglasye Insurance, certain payments of insurance indemnities or benefits provided further to the materialization of a risk by the insurance company(entry no. 726). Finally, a new time-limited derogation, effective until October 24, 2026, has been introduced for Nayara Energy Limited (entry no. 639), authorizing transactions if necessary to facilitate a significant reduction by the designated entity in the intake of, or reliance on, Russian crude oil imports.

New designations

The EU has imposed asset freeze measures on a total of 120 newly designated persons under Regulation 269/2014, consisting of 37 individuals and 80 entities.

A key feature of this listing is the targeting of companies established in third countries – including China, the United Arab Emirates and Kazakhstan – accused of facilitating the flow of goods which are essential for the Russian supply chains and production of military equipment, including its electronic and mechanical components.

Lastly, 3 additional listings have been enacted pursuant to Regulation (EC) No 765/2006 implementing restrictive measures against Belarus. Mirroring the strategy adopted regarding Russia, a third-country entity, namely the China Space Sanjiang Group, was listed for its role as a key partner in a joint venture that develops and produces wheeled chassis for Belarusian military equipment.

1. Sectoral Sanctions

Energy sector

Starting from 1 January 2027, the amendment to Council Regulation (EU) No. 833/2014 introduced a prohibition on the provision by EU operators of LNG terminal services (including offloading, storage, sending out, loading and unloading, regassification, bunkering and ancillary services) to Russian entities or to EU entities more than 50% owned or controlled by Russian nationals or entities. Existing relevant contracts for the LNG terminal services must be terminated by that date.

New restrictions have been introduced on services to icebreaker vessels and LNG tankers with Russian connections. As of 25 April 2026, it is prohibited to provide technical assistance, brokering services, financing or financial assistance related to any LNG tanker registered under the Russian flag, certified by the Russian Maritime Register of Shipping, or owned or managed by a Russian person. The restriction will be extended from 1 January 2027 to all LNG tankers operating in Russia or for use in Russia, regardless of flag, certification or ownership.

The package also introduces a prohibition, from 1 January 2027, on the purchase, import or transfer of natural gas condensate from LNG production plants originating or exported from Russia.

The package removes the existing fixed oil price cap levels and provides instead that the Council shall decide, on the basis of a joint proposal from the High Representative and the Commission and in coordination with the G7 and the Price Cap Coalition, on the application of the oil price cap, with the potential result that a full ban on maritime services related to Russian crude oil and petroleum products would enter into force. Exception is provided for crude oil or petroleum products that originate in a third country (i.e., are not Russian-origin), are only being loaded in, departing from, or transiting through Russia, and have a non-Russian origin and non-Russian owner.

Vessels and ports

The package also lists two Russian ports (Murmansk and Tuapse) and one third-country terminal (Karimun Oil Terminal, Indonesia) as facilities allegedly used for circumventing the oil price cap.As a result, EU operators are prohibited from engaging in transactions with such ports.

On the so-called shadow fleet, 46 additional vessels have been added to the designated list bringing the total to over 600 designated vessels. The designation of a vessel triggers the prohibition which bans EU operators from providing a broad range of services to those vessels, including access to ports, pilotage, towing, mooring, anchorage, supply of fuel or provisions, cargo services, ship repair and modification, and the provision of insurance and reinsurance. A new recycling derogation has been provided, allowing competent authorities to authorize, on a case-by-case basis, service provision to listed shadow fleet vessels where those vessels are proceeding to a recycling facility.

The sanctions framework for tanker vessel sales has been comprehensively overhauled. Sales of oil tankers to Russia were already banned, whereas transfers to third countries were allowed only subject to prior notification requirements. Now, EU operators selling tanker vessels to third-country buyers must conduct proportionate due diligence on retransfer risks, include mandatory contractual prohibitions on onward sale to Russia, and cascade those obligations to subsequent buyers. Sales must be notified to competent authorities. EU sellers acting in good faith and having conducted appropriate due diligence will not be liable for subsequent breaches by the buyer.

Export-related restrictions

The 20^th package expands export restrictions across two categories of controlled items, targeting advanced technology items and industrial goods.

Advanced technology items

With respect to advanced technology items, the list of goods and technology prohibited for export to Russia has been extended to include three new categories of items: laboratory glassware, certain high-performance lubricants and their additives, and energetic materials. The first two categories have also been included among the categories of goods prohibited for export to Belarus.

Industrial goods

With respect to industrial goods, the export ban covers the two following categories of goods: (1) certain steel tubes and pipes, drilling equipment, pumps, oil well equipment and related machinery, as listed in the relevant annex; and (ii) chemicals used in the production of lubricant additives and solvents, rubber and articles of vulcanised rubber, screws, bolts and nuts of steel, tools for metal production, and industrial tractors above 130 kW. To avoid circumvention, the above-mentioned categories of goods have also been restricted for export to Belarus.

A wind-down exemption for the export of these newly added categories will be in force until 25 July 2026, for contracts concluded before 24 April 2026. The exemption applies for both Russia and Belarus.

Furthermore, the prohibition on transit, which bans the routing of listed goods and technology through Russian territory, has been extended to cover the newly restricted items, preventing their indirect onward movement to third countries via Russia.

A new derogation allows for the transit via Belarus of certain lubricants exported from Hungary and destined for Azerbaijan, subject to prior authorization by national competent authorities.

Lastly, the scope of one of the derogations applicable to the export of dual-use goods and advanced goods and technologies or services to Belarus has been narrowed. The derogation previously available for cyber-security and information security purposes to any natural and legal person in Belarus, with the exception of Belarus’ government and government-controlled undertakings, has been narrowed to authorize export exclusively to Belarusian entities owned or controlled by an EU-incorporated company.

Restrictions on export of certain equipment to Kyrgyzstan

The Kyrgyz Republic has been identified as a high-risk circumvention jurisdiction. The new package prohibits export of machining centres for metal working and data/voice transmission equipment to Kyrgyzstan.

These measures were adopted in response to an unusually sharp increase in trade flows: according to the EU Council, EU exports of electronics and sensitive goods to Kyrgyzstan rose by approximately 800% compared to previous years, while exports from Kyrgyzstan to Russia increased by 1200%. Such pattern indicated a significant risk that such goods may be subsequently sold, supplied, transferred, or exported onward to Russia for use in its military and defence sectors.

Import-related restrictions

New import-related prohibitions have been introduced for goods generating significant revenues for Russia, including raw materials (salt, gravel, magnesite), iron ores, slag and ash, metals and scrap (steel scrap, copper, nickel, aluminium, molybdenum, cobalt, platinum), chemicals (sulphates, epoxides, nitrile compounds, caustic soda), vulcanised rubber articles and tanned furskins, and ammonia.

An ammonia import quota of 688,000 metric tonnes per year has been introduced, exempting imports within the quota from the import ban.

The import ban from Belarus has been extended to additional goods, including certain raw materials, metals, certain minerals, scrap of steel and other metals, chemicals, articles of vulcanized rubber and tanned furskins.

Transitional wind-down periods for import from Russia and Belarus apply until 25 July 2026 for most goods, and until 25 January 2027 for imports from Russia of certain copper alloys.

In addition to the aforementioned restrictions, two further categories of restrictions have been added to the sectoral sanctions currently in force.

First, in the context of the prohibition on the purchase, import or transfer of Russian diamonds and products incorporating diamonds, diamond traceability rules have been tightened. As of 24 April 2026, importers of polished diamonds must provide, at the moment of importation, a due-diligence statement confirming that diamonds were not mined, processed or produced in Russia. This extends the traceability obligation, which was already applicable since 1 March 2025 to rough and unworked diamonds, to a broader category of polished diamonds.

Second, Liechtenstein has been added as a partner country of the EU. This means that imports of refined petroleum products from Lichtenstein are exempted from the requirement to provide evidence of non-Russian origin of crude oil used in the production of refined petroleum products.

Transaction ban

Twenty additional Russian credit and financial institutions have been added to the transaction ban list pursuant to Article 5h, effective 14 May 2026. These include Post Bank, Russian Standard Bank, Wildberries Bank and Avangard Bank, among others. Four third-country financial entities have also been listed for enabling circumvention, including the Joint Development Bank in Laos and two Kyrgyz banks.

At the same time, three Tajikistan banks (Spitamen Bank, Dushanbe City Bank and Commerce Bank of Tajikistan) have been delisted from the list of banks subject to the transaction ban. These banks were designated earlier as part of 19^th package for connecting to the system for transfer of financial messages (SPFS) of the Central Bank of the Russian Federation or to other payment services, such as the Russian National Payment Card System (Mir) or the Fast Payments System (SBP), set up by the Central Bank of the Russian Federation.

Three new exemptions have been introduced under the transaction ban for banks: (i) for the reception of payments due by the legal persons, entities or bodies referred to in Annex XIV pursuant to contracts and obligations performed before 24 April 2026, (ii) for the reimbursement of fees for legal services, and (iii) for state-funded cultural organizations of Member States operating in Russia. The same exemptions have been introduced under the Belarus programme transaction ban.

Furthermore, a new category of persons may now be designated as subject to a transaction ban under Article 5ai. While no person was listed in Annex LIV, Article 5ai allows the imposition of a transaction ban on persons that benefitted, including by operating in the same sector, from a decision pursuant to the Decree of the President of the Russian Federation No 302 of 25 April 2023, Federal Law No 470‑FZ or related or equivalent Russian legislation.

The Decree of the President of the Russian Federation No 302 of 25 April 2023 establishes a mechanism for the Russian state to place certain foreign-owned assets under temporary state administration in response to actions by so-called “unfriendly” countries. Federal Law of the Russian Federation No 470‑FZ of 4 August 2023 sets out a mechanism allowing Russia to limit the control of foreign holding companies over “economically significant” Russian enterprises and enable Russian beneficiaries to obtain direct title to shares of such enterprises.

In addition, a new transaction ban was imposed on Russian entities that use the intellectual property rights or trade secrets of EU companies’ Russian subsidiaries without consent, under Presidential Decree No 122 of 15 February 2024 or equivalent Russian legislation. Affected EU right holders must notify their national competent authority of any such unauthorised use, and Member States must in turn inform the Commission.

Moreover, a new transaction ban targeting parties who seek to enforce outside the EU judgments and decisions against EU operators arising from contracts affected by sanctions or Russian countermeasures was introduced. The designation criteria also included cooperation or facilitation of enforcement of such judgments and decisions in third countries.

While the Council has not yet made designations under these frameworks, they create a disincentive for third parties (except for the lawyers and members of the judiciary) that assist in executing such judgments.

An analogous provision was included under the Belarus sanctions package. Exemptions only apply to ensure the flow of humanitarian and agricultural goods, to protect the access to justice within Member States and to allow transactions necessary for the said recovery of damages.

Finally, the list of restricted crypto-assets subject to a transaction ban pursuant to Article 5ba has also been expanded. The A7A5 stablecoin, digital rouble and RUBx stablecoin have been added to the list of designated crypto-assets. EU persons are prohibited from directly or indirectly engaging in any transactions involving these crypto-assets, including any support to their development. The restrictions concerning the digital rouble and RUBx will enter into force on 24 May 2026. The same prohibition, effective on the same date, has been added in relation to transactions involving the Belarusian digital rouble.

Effective 24 May 2026, a new blanket prohibition of transactions with Russian-established crypto-asset service providers and exchange platforms has been introduced. This goes beyond the previous approach of listing individual providers and targets instead all Russia-based crypto service providers. The same restrictions have been introduced with respect to transactions with crypto-assets services or platforms within Belarus.

Limited exemptions apply for diplomatic missions in Russia and Belarus and for nationals of Member States who became residents in Russia or Belarus before 24 February 2022. A derogation for divestment from Russia is available to those willing to seek a license from national competent authorities. Lastly, a new category of persons can be designated as subject to the transaction ban under Article 5ad. The amendment targets persons that are not a credit or financial institution or an entity in crypto-asset services or payment services that offers services that enable the performance of international transactions, including through payments from accounts in countries other than Russia, through netting, set-off, reconciliation or settlement, that frustrate the purpose of the prohibitions in this Regulation or in Regulation (EU) No 269/2014. Four entities have been listed under this new basis.

Provision of services

The scope of restricted services in Article 5n of Regulation 833/2014 has been expanded to include managed security services and related technical and financial assistance and brokering services, applicable from 25 May 2026. Article 5n prohibits certain services to the Government of Russia or legal persons incorporated in Russia

A similar, but not identical, prohibition has been added in the Belarus programme, prohibiting certain services to its government, its public bodies, corporations or agencies or to any natural or legal person, entity or body acting on their behalf or at their direction.

A new exemption has been introduced for services to Russian consular and diplomatic representations in EU Member States where those services are strictly necessary for the functioning of these representations.

Furthermore, the prohibition under Article 5t of Regulation 833/2014 to accept Russian research and innovation funding has been substantially expanded. The restriction now covers public and private research institutions, universities, higher education establishments, research and technology organisations, NGOs, public bodies and agencies, as well as commercial enterprises of all sizes that carry out research and innovation activities, and natural persons associated with them.

Lastly, the Belarus package has been aligned with the Russian one, by introducing – as of 25 June 2026 – a ban on the provision of services directly related to tourism activities in Belarus, including those offered by travel agencies, tour operators and guides. A prior authorization is required for any services provided to the Belarusian State or its public bodies not already covered by the said bans, unless necessary for the functioning of Belarusian consular or diplomatic representations within the EU. The same restriction also applies in the context of the Russia programme.

Broadcasting

The broadcasting prohibition has been extended to cover mirror entities – outlets replicating the content of already-banned media – where at least two of five defined criteria are met: substantially identical content, continuity of branding, overlapping ownership or management, redirection of users from a banned entity, or continuity of technical infrastructure.

Legal protection for EU operators

The 20^th package enables EU operators to better protect their rights and interests.

The transaction ban affecting beneficiaries of the “temporary management” in Russia, the transaction ban related to IP violations and the transaction ban with entities which seek enforcement of judgments outside Russia are meant to strengthen protections of rights and interests of EU operators.

Changes to the “no-claims” provision

Prior to the 20^th package, the “no-claims” provision shielded EU operators against claims brought by listed persons/entities or their non-EU subsidiaries, any other Russian persons/entities, and those active through or on behalf of them.

The 20^th package broadens the prohibition to cover claims brought by third-country persons (i.e., persons and entities established in non-EU countries other than listed “partner countries”) in connection with contracts or transactions the performance of which has been affected by the relevant restrictive measures.

The “no-claims” clause will also be applicable regardless of whether or not the goods, technology or services in question originate in the Union. The same amendment to the no-claims clause was enacted under the Belarus package.

No claims in connection with any contract or transaction the performance of which has been affected by the restrictive measures shall be satisfied if made by natural or legal persons from third countries involving transactions with prohibited goods, technologies, or services, also in the context of the Belarus programme.

Extended right to claim damages

The 20^th package extends the existing right of EU operators to claim damages before EU Member State courts in connection with attempts to enforce outside of the EU injunctions, judgments or administrative decisions relating to contracts affected by sanctions or Russian countermeasures.

This provides for an opportunity to seek damages arising from enforcement outside Russia.

Comparable rights also apply under the Belarusian sanction framework.

Anti-suit injunctions

The 20^th package introduces, for the first time, an express anti-suit injunction mechanism in the framework of EU restrictive measures against Russia.

Competent courts of EU Member States are now empowered to issue orders requiring parties to cease or refrain from initiating legal proceedings before Russian courts, where those proceedings: (a) assert jurisdiction in breach of applicable jurisdictional rules; or (b) are brought on the basis of Articles 248.1 and 248.2 of the Russian Arbitrazh Procedure Code, which grant Russian arbitrazh courts exclusive jurisdiction over disputes involving sanctioned parties notwithstanding the contractual dispute resolution clauses.

The anti-suit injunction can be backed by significant financial penalties (proportionate to the potential loss) to deter Russian parties from prosecuting proceedings in breach of the arbitration/exclusive jurisdiction clauses.

The measure is complementary to the no-claims clause and the damages remedy specified above.