EU adopts its 20th package of sanctions against Russia

The new measures were adopted close to two months after the four-year anniversary of Russia's full-scale invasion of Ukraine, with the EU having "finally broken the deadlock" as Hungary lifted its veto. 

The package is notable both for its scale – 120 new individual listings, the most in a single package for two years – and for several structural innovations, including the first-ever use of the EU's anti-circumvention tool and an overall strong anti-circumvention angle, a legal framework for a future ban on maritime services linked to Russian oil, and a broadened financial services crackdown covering crypto assets. 

The new measures are published in the Official Journal of the EU. 

Energy and maritime measures 

The 20th package includes the creation of a legal basis for a future prohibition on the provision of maritime transport services for Russian crude oil and petroleum products. The ban is to be introduced in coordination with G7 partners and the Price Cap Coalition, following an appropriate wind-down period determined by the Council. The fact that no timeline has been outlined for the entry into force of such a ban is likely a reflection of recent geopolitical developments. 

An additional 46 vessels from the Russian shadow fleet have been added to the list of vessels subject to a port access ban and a prohibition on receiving a broad range of maritime services, raising the total to 632 vessels. New measures also require EU sellers of tankers to conduct mandatory due diligence and to include a contractual "no Russia" clause, reducing the risk of vessels entering the shadow fleet. A dedicated scrapping clause has also been introduced to facilitate vessels leaving the shadow fleet through decommissioning or recycling. 

The package extends the port infrastructure ban for the first time beyond Russian territory. In addition to the Russian ports of Murmansk and Tuapse, the Karimun Oil Terminal in Indonesia has been listed, owing to its stated role in shadow fleet operations and circumvention of the oil price cap. 

The package takes aim at the entire value chain of the Russian oil industry, with 36 companies designated across the sector — from exploration and extraction through to refining operations and transportation.

The package cuts off a further avenue of support for Russian energy exports by banning EU operators from providing maintenance services for Russian LNG tankers and icebreakers. Effective January 2027, EU operators will also be prohibited from making LNG terminal services available to Russian-owned, -controlled or -connected entities.

Financial sector measures 

Twenty additional Russian banks are now subject to the transaction ban, bringing the total number of Russian banks excluded from the EU internal market to 70. In addition, four financial institutions in third countries have also been brought within the transaction ban, targeted for their role in actively undermining EU sanctions or for their connection to Russia's domestic banking messaging network (SPFS). The focus on third country financial institutions is still relatively novel in an EU sanctions context and the latest example of the EU flexing its extraterritorial muscles to combat circumvention.

The package introduces a sweeping ban on dealings with Russian crypto asset service providers and with decentralised trading platforms, reflecting the documented shift towards crypto as a vehicle for circumventing sanctions. 

Trade measures

The 20th package introduces a substantial set of new trade restrictions. On the export side, new prohibitions have been imposed on a broad category of commercial goods – from rubber products to agricultural and industrial machinery – with a combined value exceeding €365 million. A separate set of targeted controls applies to materials with known battlefield utility, among them explosive precursors, specialised laboratory glassware, and high-grade lubricants and associated additives.

On the import side, the package bans metals, chemicals and minerals not previously covered by sanctions, valued at over €530 million, and introduces a quota on imports of ammonia to cap existing trade flows.

Anti-circumvention

The package marks the first use of the EU's anti-circumvention tool, introduced in the 11th sanctions package in June 2023. The mechanism allows the EU to restrict the sale, supply, transfer or export of specific goods to specified third countries. The list of such specified third countries has, however, remained empty until now. The tool has now been activated in response to what the EU terms the Kyrgyz Republic's systematic failure to prevent the onward export to Russia of machine tools and certain telecommunications equipment that originated in the EU and are used in the manufacture of Russian drones and missiles. 

Trade data reviewed by the Council reportedly revealed a marked and sustained rise in the volume of these goods passing through Kyrgyzstan on their way to Russia. On the basis of that analysis, all exports of computer numerical control (CNC) machines and radios from the EU to Kyrgyzstan are now prohibited.

Designations

In total, 120 new individuals and entities have been added to the EU sanctions list. The Russian military-industrial complex is specifically targeted through the designation of 58 companies and associated individuals involved in the development and manufacture of military goods, including drones. Sixteen entities based in China, the United Arab Emirates (UAE), Uzbekistan, Kazakhstan and Belarus have been listed for supplying dual-use goods or weapons systems to the Russian military. A further 60 entities have been added to the list subject to tighter export controls, of which 28 are based outside Russia, in countries such as China (including Hong Kong), Türkiye and the UAE.

Beyond military suppliers, the listings cover oligarchs, individuals and entities implicated in the forced transfer and indoctrination of Ukrainian children, persons responsible for the appropriation of Ukrainian cultural property, and propagandists operating state-sponsored platforms.

Other measures 

• Legal protection: EU firms facing hostile litigation in Russia receive strengthened safeguards under the new package. Member State courts may now impose financial penalties on Russian parties who bring abusive proceedings against EU operators before Russian courts. Where such judgments are subsequently enforced in third countries outside Russia, the affected EU firms are entitled to seek damages in compensation.
• Broadcasting: The broadcasting ban is extended to cover mirror sites that replicate the content of designated propaganda outlets such as Russia Today and Sputnik, with distribution of such content within the EU also prohibited.
• Research: To limit Russia's ability to exert influence over European academic and scientific activity, EU research institutes, universities and individuals associated with such institutions are no longer permitted to receive financial support – whether in the form of grants, donations or other funding – from the Russian government for research and innovation purposes.