Deadlock Broken: EU Adopts 20th Russia Sanctions Package

The EU has adopted its 20th package of sanctions in connection with Russia's ongoing war against Ukraine, resolving a prolonged internal political deadlock that had been caused by vetoes from Hungary and Slovakia. The package amends Regulations 833/2014, 269/2014, and 765/2006 and the respective Council Decisions and Implementing Regulations. The texts entered into force on 24 April 2026. They are available through this link.

The key elements of the package are summarized below.

ADDITIONAL ASSET FREEZE TARGETS

• • Russia designations: Under the Russia sanctions program, the EU has designated 117 additional individuals and entities as asset freeze targets. The new designations include, among others, persons and entities known to have facilitated sanctions circumvention or active in the military manufacturing industry, industrial complex, energy sector, and shipping industry. The designations extend to third-country parties, including entities located in China, the United Arab Emirates, Uzbekistan, Kazakhstan, and Belarus.
  • Belarus designations: There were three new designations under the Belarus sanctions regime: Belarusian Oil Company; a Belarusian joint venture company (Volat-Sanjiang Joint Venture LLC) involved in the production of military equipment; and the JV’s Chinese co-founder.

EXPORT RESTRICTED PARTIES

An additional 60 entities have been added to Annex IV of Regulation 833/2014, subjecting them to a restriction on selling or exporting — directly or indirectly — certain dual-use goods or other advanced goods and technologies. The expanded list includes entities located in Russia and third countries, including China (including Hong Kong), Türkiye, and the United Arab Emirates.

It is recommended to check whether any screening software used for party screening purposes captures this list, as inclusion can raise a red flag for potential Russian diversion even where the relevant dual-use or advanced goods and technologies are not involved, or where EU jurisdiction does not directly apply.

ADDITIONAL EXPORT AND IMPORT RESTRICTIONS

• • Export restrictions: New items have been made subject to export restrictions on Russia and Belarus. These include laboratory glassware, certain high-performance lubricants and their additives, energetic materials, rubber and articles of vulcanized rubber, articles of steel, and tools for metal production and industrial tractors. With respect to the additional export restrictions under Article 3k of Regulation 833/2014, the amending Regulation provides for a limited grandfathering period permitting the execution until 25 July 2026 of contracts concluded before 24 April 2026, as well as ancillary contracts necessary for their performance.
  • Import restrictions: Import restrictions have been extended to cover additional goods, such as salt (including table salt and denatured salt), quicklime, metals, certain minerals, steel and other metal scrap, chemicals, vulcanized rubber articles, and tanned furskins. With the exception of ammonia, the amending Regulation provides for a limited grandfathering period allowing the execution until 25 July 2026 of contracts concluded before 24 April 2026, as well as ancillary contracts necessary for their performance. For refined copper — other than cathodes (or sections thereof), wire-bars, or billets — the grandfathering period is extended to 25 January 2027.

OIL AND GAS-RELATED RESTRICTIONS

• • LNG terminal services ban: The new sanctions package introduces a prohibition on the provision of liquefied natural gas (LNG) terminal services. With effect from 1 January 2027, it will be prohibited to provide, directly or indirectly, LNG terminal services to persons or entities in Russia, or to EU-established entities that are more than 50% owned or controlled by a Russian citizen or entity. It will equally be prohibited to maintain contracts relating to such prohibited services. The preamble to the amending Regulation provides that relevant contracts for LNG terminal services, including long-term contracts, are to terminate automatically on 1 January 2027.
  • Framework for maritime services ban: The amendments lay the basis for a future maritime services ban on Russian crude oil and petroleum products. However, implementation is contingent on full coordination and consideration within the G7 and the Price Cap Coalition, which has not yet been undertaken or implemented.
  • Partner country: Liechtenstein has been added to the list of partner countries for the importation of petroleum products. As a result, importers will no longer be required to provide evidence of the country of origin of the crude oil used in the refining of petroleum products imported from Liechtenstein.

MARITIME-RELATED RESTRICTIONS

• • New vessel designations: An additional 46 vessels have been added to the list in Annex XLII to Regulation 833/2014, subjecting them to a port access ban and additional services restrictions. To encourage the recycling of listed vessels rather than their continued operations, and to enable EU operators to be involved in recycling-related activities, a new derogation has been introduced.
  • Tanker vessel sales: The conditions applicable to sales of tanker vessels to operators in third countries have been further tightened. Any EU Operator selling a tanker vessel, regardless of where the sale takes place, is now required to conduct specific due diligence and to include a mandatory contractual clause in tanker vessel sales agreements confirming that the vessels cannot be sold on or transferred to any person or entity in Russia, or for use in Russia.

The preamble to the amending Regulation states that such due diligence should be proportionate and include screening of all parties to the transaction. Importantly, it further clarifies that where an EU seller carries out appropriate due diligence and obtains the required contractual commitments, the seller will not be held liable for any subsequent breach of those commitments by the buyer.

• • Icebreaker and LNG tanker vessel restrictions: The package introduces a prohibition on providing — directly or indirectly — technical assistance, brokering services, or financing or financial assistance in connection with any icebreaker vessel or LNG tanker vessel where such vessel is: (i) registered under the flag of Russia; (ii) certified by the Russian Maritime Register of Shipping (RMRS); (iii) owned or managed by any Russian natural person or entity; (iv) operating in Russia; or (v) intended for use in Russia.

The prohibition applicable to LNG tanker vessels is subject to staggered implementation. Restrictions on LNG tanker vessels that are registered under the flag of Russia, certified by the RMRS, or owned or managed by any Russian natural person or entity enter into force on 25 April 2026. Restrictions on vessels operating in or intended for use in Russia — other than those that are registered under the flag of Russia, certified by the RMRS, or owned or managed by any Russian natural person or entity — take effect on 1 January 2027.

• • Port transaction ban: Two new Russian ports — Murmansk and Tuapse — have been added to the EU’s port transaction ban, along with the Karimun Oil Terminal in Indonesia. It is prohibited to engage in any transaction — directly or indirectly — with those ports.

FINANCIAL AND CRYPTO-RELATED RESTRICTIONS

• • Transaction ban: An additional 20 Russian banks have been made subject to a transaction ban, which enters into force on 14 May 2026. 

Furthermore, the EU has introduced a new ground for inclusion on its crypto-related transaction ban list, targeting financial institutions or crypto-asset service providers that offer services enabling 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 EU's Russia regulations. Four entities have been listed on this new ground (with entry into force on 14 May 2026). Three other banks have been added to the crypto-related transaction ban list (with entry into force on 14 May 2026), and five previously listed banks have been removed from the list following the closure of relevant loopholes and termination of illicit activities.

• • Crypto-asset restrictions: The package introduces a prohibition on engaging, directly or indirectly, in any transaction involving crypto-assets and central bank digital currencies listed in Annex LIII of Regulation 833/2014, or providing support to the development of such crypto-assets or currencies. The listed assets include A7A5, RUBx, and the digital rouble. To enable the orderly termination of existing relevant contracts, the prohibition for RUBx and the digital rouble enters into force on 24 May 2026 (the prohibition for A7A5 entered into force on 25 November 2025). The package also introduces a prohibition on engaging with any crypto-asset service provider established in Russia and on making use of any platform established in Russia that facilitates the transfer and exchange of crypto-assets.

ANTI-CIRCUMVENTION MEASURES

• • • First activation of the anti-circumvention tool: The EU has activated its anti-circumvention tool for the first time, prohibiting the export of computer numerical control machines and radios to Kyrgyzstan. The EU has identified Kyrgyzstan as a jurisdiction where the risk of circumvention is systematic and persistent, with authorities failing to prevent the sale, supply, transfer, or export of such restricted goods and technology to Russia.
    • Broadcasting: The existing broadcasting prohibition has been extended to include websites that mirror previously prohibited sites.
    • Transit ban: The EU has extended the list of goods subject to the prohibition on transit via Russia with a view to minimizing the risk of circumvention.

SERVICES

The existing restrictions on the provision of various services to the Government of Russia and to Russian entities have been extended to cover the provision of managed security services.

DIAMONDS

The EU has amended the traceability requirements for diamonds by requiring importers of polished diamonds — including diamonds polished in third countries — to provide a due diligence statement confirming that the diamonds were not mined, processed, or produced in Russia.

LEGAL PROCEEDING PROTECTIONS

The 20th package introduces notable enhancements to the protections for EU operators against “Russian” claims:

• • Extended “no claims” clause: The scope of the “no claims” clause has been extended to cover third-country persons and entities that sell or export prohibited goods, technology, or services to parties whose claims were already barred under the previous “no claims” clause. This extension does not apply to claimants in partner countries.
  • Protection against enforcement of foreign judgments: EU operators are now protected against the enforcement in third countries of judgments obtained by parties whose claims are barred under the “no claims” clause — including judgments related to the Russian temporary management regime. Damages resulting from such enforcement may be recovered from those who seek or cooperate in the enforcement, or from persons and entities that own or control them. Lawyers and members of the judiciary are excluded.
  • Anti-suit injunction mechanism: Where a Russian party has brought proceedings before a Russian court in breach of an exclusive jurisdiction or arbitration clause — or pursuant to Articles 248.1 or 248.2 of the Russian Arbitration Procedure Code — an EU party may seek a court order from a competent EU Member State court compelling the Russian party to discontinue those proceedings. Noncompliance triggers financial penalties proportionate to the potential loss of the EU party, payable directly to that party.

HOUSEKEEPING

The Council has also taken the opportunity to delete derogations and grandfathering clauses that have lapsed and are no longer applicable, and to fine-tune a number of existing provisions and derogations.

BELARUS

Additional measures have been introduced against Belarus, mirroring some of the measures imposed on Russia. These include additional trade sanctions, legal protection measures, restrictions on crypto-assets, and prohibitions on the provision of cybersecurity services and tourism services.

If you have any questions about this alert, or EU sanctions issues more broadly, please contact the authors.