May 2026 – On 23 April 2026, following a European Commission proposal and extended negotiations among the Member States, the Council of the EU adopted its 20th sanctions package against Russia in response to its ongoing aggression against Ukraine. The legal acts entered into force on 24 April 2026.
The new package adopts a pronounced anti-circumvention focus and introduces a comprehensive set of measures across Russia's energy sector, military-industrial complex, financial system, and trade, along with additional listings and reinforced legal protection for EU operators.
The first-ever activation of the EU's anti-circumvention tool, applied to the Kyrgyz Republic, rests on a quantitative trade-data assessment of re-export patterns of common high-priority items—an analytical approach that is, in principle, replicable against other third countries where comparable patterns are identified.
In parallel, the EU has adopted additional sanctions against Belarus, mirroring the trade, financial, services and legal-protection provisions of the Russia sanctions regime, and has further extended the Belarus sanctions regime.
The package at a glance
Anti-circumvention measures
- First-ever activation of the EU’s anti-circumvention tool, applied at the country level against the Kyrgyz Republic, prohibiting the export of computer numerical control (CNC) machines and radios to Kyrgyzstan, where there is a high risk of re-export to Russia for use in the manufacture of drones and missiles.
- 60 additional entities subject to tighter export restrictions on items contributing to the technological enhancement of Russia’s defence sector, including entities established in third countries (China, including Hong Kong, Türkiye, and the United Arab Emirates).
Energy sector restrictions
Liquefied natural gas (LNG) and maritime services
- Ban on the provision of LNG terminal services to Russian entities or to entities owned or controlled by Russian nationals or operators, applicable from January 2027, with relevant long-term contracts to be terminated by that date.
- New prohibition on the provision of maintenance and other services for Russian LNG tankers and icebreakers.
- Foundations laid for a future prohibition on maritime services related to the transport of Russian crude oil and petroleum products, to be activated by Council decision in coordination with the G7 and the Price Cap Coalition, with an appropriate wind-down period.
Shadow fleet, ports, and tanker sales
- 46 additional shadow-fleet vessel listings and 11 vessel delistings, bringing the total to 632 listed vessels subject to a port access ban and a ban on the provision of related services.
- Listing of two Russian ports (Murmansk and Tuapse) and, for the first time, a third-country port—the oil terminal at the port of Karimun in Indonesia—for connections with the shadow fleet and circumvention of the oil price cap.
- Mandatory due diligence on tanker sales by EU sellers, including a “no-Russia” clause in sales contracts, and a new shadow-fleet scrapping clause facilitating the decommissioning or recycling of vessels.
- Listing of a significant maritime insurer linked to the shadow-fleet ecosystem.
Designations of energy-related actors
- 36 designations across the upstream and downstream seg ments of the Russian energy sector, covering the exploration, extraction, refining, and transportation of oil.
Financial sector restrictions
Banks and payment agents
- Transaction ban on 20 additional Russian banks, bringing the total to 70 (with narrow exceptions, including for humanitarian transactions).
- Transaction ban on four banks in Kyrgyzstan, Laos, and Azerbaijan for circumventing sanctions or connecting to Russia’s System for Transfer of Financial Messages (SPFS), the Russian financial messaging network developed as an alternative to SWIFT.
- Prohibition of netting transactions with Russian agents in Russia and in third countries facilitating cross-border transactions designed to bypass EU sanctions.
- Delisting of five third-country financial entities following commitments to refrain from sanctions-frustrating activities.
Crypto-assets
- Total sectoral ban on transactions with crypto-asset service providers and platforms established in Russia.
- Designation of a Kyrgyz entity operating a platform on which substantial volumes of the Russian government-backed stablecoin A7A5 are traded.
- Prohibition on transactions involving the rouble-backed stablecoin RUBx, and on all EU support for the development of the Digital Rouble, the central bank digital currency under development by the Central Bank of Russia.
Trade measures
- New export bans worth over EUR 360 million, including laboratory glassware, certain energetic materials, certain high-performance lubricants and additives, certain chemicals, rubber and articles of vulcanised rubber, articles of steel, tools for metal production, and industrial tractors.
- New restriction on the provision of cybersecurity services to Russia.
- New import bans worth over EUR 570 million on certain raw materials, metals and minerals, scraps of steel and other metals, certain chemicals, articles of vulcanised rubber, and tanned fur skins.
- Introduction of a quota for imports of Russian ammonia.
- Enhanced prohibition on transit via Russian territory.
Russia’s military-industrial complex
- Designation of 58 companies and associated individuals involved in the development and manufacturing of military goods, including drones, together with 16 third-country suppliers of dual-use goods or weapons systems established in China, the United Arab Emirates, Uzbekistan, Kazakhstan, or Belarus.
Additional listings
- 120 additional asset-freeze and travel-ban listings—the largest single package of listings in two years—targeting Russian energy and military companies and their supply chains in third countries, oligarchs, persons involved in the abduction of children from Ukraine, propagandists, and persons responsible for looting Ukrainian cultural heritage.
Legal protection of EU operators
- Power for Member State courts to fine Russian parties launching abusive lawsuits before Russian courts, and the right for EU operators to claim damages where Russian judg ments are enforced in third countries other than Russia.
- Power for the Council to impose a transaction ban on third-country firms and individuals cooperating in the enforcement of such Russian decisions.
- Transaction ban on Russian entities benefiting from illegitimate expropriations of EU operators by the Russian government, or unlawfully exploiting their intellectual property rights in Russia.
Other measures
Fighting propaganda
- Extension of the existing broadcasting prohibition to websites and domains disseminating the same content as already-prohibited media outlets, facilitating faster takedown and blocking of proxy distribution channels.
Protection of EU research
- Prohibition on the acceptance of funding, including donations and grants, from the Russian government in the area of research and innovation, applicable to research institutes, higher education establishments, and other bodies in the EU, as well as to individuals associated with them.
Diamond traceability
- Tightened traceability requirements for diamonds, with importers of polished diamonds required to provide a due-diligence statement confirming that the diamonds were not mined, processed, or produced in Russia.
New measures under the Belarus sanctions regime, now extended until 28 February 2027
- Three new individual and entity designations related to the Belarusian military-industrial complex and the Lukashenka regime, including the first-ever designation of a Chinese state-owned entity under the Belarus sanctions regime.
- Mirroring of Russia sanctions provisions in the areas of trade, legal protection of EU operators, crypto-assets, cybersecurity services, and tourism services.
Why this matters
The 20th package marks the first activation of the EU's anti-circumvention tool and the first listing of a third-country port under the Russia sanctions regime. The activation of the anti-circumvention tool sets a methodological precedent that may inform further enforcement action against third countries where comparable re-export patterns are identified. Combined with the package's concentrated third-country designations across banking, dual-use supply, port infrastructure, and crypto-asset platforms, this signals continued and intensified EU scrutiny of circumvention pathways, in particular through Central Asia, the Caucasus, the United Arab Emirates, Türkiye, China (including Hong Kong), and Southeast Asia.
The package extends restrictions to cybersecurity services, prohibits EU research and higher-education bodies from accepting Russian-government funding, and introduces new operational obligations for EU operators in shipping, diamonds, and in contractual relationships with Russian payment agents. The legal-protection toolkit available to EU companies facing retaliatory proceedings in Russia or in third countries has been further strengthened.
Considerations for EU stakeholders
EU operators should reflect the new measures in their internal compliance and contractual frameworks, including by:
- Updating sanctions screening lists and counterparty databases to capture the new designations of individuals, entities, banks, vessels, and ports.
- Reviewing trade flows, counterparty relationships, and correspondent banking arrangements involving jurisdictions where the 20th package has concentrated third-country designations, and applying enhanced end-use and end-user due diligence to high-priority items at risk of re-export to Russia.
- Reviewing correspondent banking and payment-routing relationships for indirect exposure to financial institutions connected to Russia's SPFS messaging network, in addition to the newly designated banks themselves.
- Reviewing exposures to the newly designated ports—Murmansk, Tuapse, and the oil terminal at the port of Karimun—as well as to the additional shadow-fleet vessels.
- Adapting tanker sale contracts to include the mandatory "no-Russia" clause and aligning sale processes with the new due-diligence requirements.
- Reviewing cybersecurity service arrangements involving Russian counterparties and assessing the impact of the LNG terminal services ban taking effect in January 2027, including the wind-down of any existing long-term contracts.
- Reassessing payment, netting, and set-off arrangements involving Russian agents in Russia and in third countries.
- Aligning for the tightened due-diligence statement requirement applicable to importers of polished diamonds.
- Reviewing existing and anticipated proceedings in Russia or in third countries in light of the new legal-protection mechanisms available to EU operators.