EU adopts its 20th sanctions package against Russia and Belarus

On 23 April 2026, the EU adopted its much anticipated package of sanctions against Russia and Belarus.

The package significantly expands the restrictive measures, targeting Russian energy revenues, maritime and shipping activity, the military‑industrial complex, and routes used to circumvent existing sanctions. Full implementation is staggered, with certain measures applying immediately and others subject to deferred implementation or further decisions.

We summarise the key restrictions below.

Summary of key new EU sanctions measures

1. Energy

• Ban on maritime services: The EU has reached agreement in principle on the introduction of a full ban on maritime services related to Russian crude oil and refined petroleum products. However, the ban has been deferred pending coordination with G7 partners and the Oil Price Cap Coalition. Once the ban is implemented, EU operators will be prohibited from providing services in support of Russian oil shipments at any price, removing the ability to structure compliant trades through capped pricing - effectively bringing an end to the oil price cap.
• LNG: The package introduces new restrictions targeting Russian LNG, including a ban on the provision of maintenance and other technical services for Russian LNG tankers and ice breakers. From 1 January 2027, it will become unlawful to provide LNG terminal services to Russian entities, or to entities owned or controlled by Russian nationals or operators.
• Shadow fleet: EU has expanded its measures targeting Russia’s “shadow fleet”, with 46 additional non‑EU vessels now subject to a port access ban and restrictions on the provision of a broad range of maritime transport‑related services, bringing the total number of designated vessels to 632. The new package further establishes mandatory due diligence requirements in connection with the sale of tankers, strengthening the enforcement framework underpinning these restrictions and addressing issues with the continued reliance on non‑EU shipping. Theexpansion of the EU’s shadow fleet designations increases compliance risk across the supply chain, particularly where vessel nomination, insurance arrangements or ownership structures are opaque or subject to change.
• Circumvention of oil price cap: In response to ongoing circumvention of the oil price cap, the EU has prohibited transactions involving two Russian ports—Murmansk and Tuapse—as well as the oil terminal at the Karimun port in Indonesia. These facilities are assessed as playing a key role in practices designed to evade existing oil price cap restrictions. These designations highlight an increased risk around the use of intermediary ports, ship‑to‑ship transfers and other complex routing arrangements, even where transactions are structured to appear price‑cap compliant. Once implemented, the proposed maritime services ban would remove the relevance of the price‑cap distinction; however, in the interim, these measures underscore the need for enhanced diligence on trade flows and logistics arrangements.

2. Anti-circumvention tool

The EU has, for the first time, formally activated its anti‑circumvention tool. Following detailed analysis of trade data indicating a significant increase in the re‑export of high‑priority items from Kyrgyzstan to Russia, the EU has prohibited the export of computer numerical control (CNC) machines and radios to Kyrgyzstan, where there is a high risk of onward diversion.

Since this is a new concept in the EU sanctions regime, its practical application currently remains unclear. Given the tension that the anti-circumvention tool creates with established international trade principles, it seems unlikely that it will be used broadly or routinely. Rather, its use is likely to be limited to cases where the EU can point to clear, data‑driven evidence of systematic diversion risks through a specific third country.

The activation of the EU’s anti‑circumvention tool is relevant as an enforcement signal since it demonstrates the EU’s readiness to act against diversion risks arising through third countries and non‑EU intermediaries. This increases expectations on companies to assess onward‑export and diversion risk in their wider counterparty and logistics networks, particularly where transactions involve jurisdictions or structures identified as higher risk.

3. Sanctions Designations

The EU has imposed asset freezes and sanctions designations on 120 additional individuals and legal entities which are linked to Russia. These target actors connected to Russia’s military‑industrial complex, energy sector and shipping activities. Notably, the scope of designations continues to expand beyond Russia itself, extending to entities located in third countries such as China, the United Arab Emirates, Belarus and parts of Central Asia.

4. Export/Import

The EU has also significantly expanded its trade restrictions against Russia. On the export side, the existing ban has been extended to cover additional categories of goods, including certain high‑performance lubricants and related additives, energetic materials, chemicals, articles of vulcanised rubber, steel articles, tools for metal production and industrial tractors.

Further measures restrict the import of goods, including certain metals and minerals, chemicals, articles of vulcanised rubber and tanned fur skins. The package also strengthens the prohibition on the transit of specified goods through Russian territory and introduces a quota‑based regime for the import of ammonia.

5. Banking, Crypto and Circumvention

The EU has expanded its financial sanctions by imposing transaction bans on 20 Russian banks and four third‑country financial institutions. In addition, a Kyrgyz entity has been designated due to its involvement with significant holdings of a government‑backed stablecoin.

The package also introduces a total sectoral ban on crypto‑asset service providers and platforms established in Russia that facilitate the transfer or exchange of crypto‑assets. It also prohibits transactions involving an additional cryptocurrency (RUBx) and bans all EU support for the development of the digital rouble. Netting transactions with Russian agents are now also expressly prohibited.

6. Belarus

The sanctions package includes measures targeting the Belarusian regime and are intended to mirror those imposed on Russia.

Three new entities have been listed for their relations to the Belarusian military-industrial complex and the Lukashenko regime. Notably, for the first time, a Chinese state-owned entity has been targeted under the Belarus sanctions regime, due to its role in the production of Belarusian military goods. 

Commentary

The EU’s 20^th sanctions package marks a further step change in both the breadth and ambition of the EU’s Russia and Belarus sanctions regimes. While many of the measures build on existing frameworks, the package reflects a clear shift towards closing perceived loopholes and hardening enforcement, particularly in areas where compliance structures have allowed continued economic activity through technical or jurisdictional workarounds. The proposed move away from the oil price cap model and the deepening focus on maritime logistics, LNG supply chains and shipping infrastructure underline the EU’s growing scepticism about reliance on compliance-based safe harbours. At the same time, the widening of designations across third countries and the increasing alignment of Belarusian measures with those targeting the Russia regime demonstrates the EU’s intent to treat supporting jurisdictions, intermediaries and supply chain enablers as part of the sanctions risk perimeter.

Equally significant is the activation of the EU’s anti‑circumvention tool, which represents an important legal and political development, even if its immediate practical impact is likely to be limited. The EU is signalling that it is prepared to move from purely defensive anti‑circumvention language into proactive, data‑driven trade intervention where diversion risks are deemed sufficiently acute. Taken together with expanded trade bans, financial restrictions, crypto‑asset prohibitions and enhanced maritime due diligence expectations, the 20^th package reinforces the trend towards end‑to‑end sanctions risk management rather than entity‑ or transaction‑specific screening alone.

For businesses, the cumulative effect is an increase in expectations around supply chain transparency, counterparty risk assessment, and ongoing monitoring.