EU’s 20th Sanctions Package Against Russia

The Council of the European Union has now adopted its 20th sanctions package against Russia, continuing the EU’s steady shift from economic restrictions to more targeted tools aimed at anti-circumvention and legal protection for EU operators. As with earlier packages, the stated objective is twofold: to increase pressure on revenue critical and war supporting sectors, while tightening the perimeter around existing prohibitions to address routing through third countries, “shadow” logistics structures, and alternative payment mechanisms.

Our interdisciplinary team of sanctions and litigation specialists has prepared a focused analysis of the most noticeable and important developments in the package: namely (i) the energy and maritime measures, including the EU’s renewed “shadow fleet” pressure and the new compliance expectations around tanker sales, (ii) the financial measures targeting alternative payment methods (including crypto) and additional transaction bans, (iii) key trade and anti circumvention updates, most notably the activation of the EU’s anti circumvention tool in relation to exports to Kyrgyzstan, and (iv) the package’s litigation and arbitration provisions, which further strengthen EU side remedies against Russia linked claims and abusive proceedings.

Energy & maritime measures: “Shadow fleet” pressure and LNG tightening

Maritime service ban

With the oil and gas industry remaining as invaluable for the survival of the Russian economy, containing Russia’s energy revenues has consistently been a priority for the EU. While Brussels had been pushing for a G7-wide maritime service ban to replace the price cap, no consensus was reached among member states. As a result, the 20th sanctions package includes a basis for a future maritime service ban on Russian crude oil and petroleum products, in full coordination and discussion with the G7 and price cap coalition. EU operators can expect an appropriate wind-down period when the Council will decide that the maritime service ban will enter into force.

It remains to be seen whether any move towards a full ban on “maritime services” will be accompanied by a consolidated statutory definition of that term. For now, the relevant service categories must be derived from Article 3n of Regulation (EU) 833/2014 (as amended), which covers transport and a range of ancillary services, including technical assistance, brokering, financing/financial assistance, and insurance and reinsurance in relation to the carriage of Russian oil.

Additional sanctions targeting the Russian shadow fleet

The EU has stepped up its “shadow fleet” enforcement, by adding 46 vessels to Annex XIII of EU Regulation 833/2014. As of 24 April 2026, the listed vessels are subject to a port access ban and/or restrictions on the provision of services. The measures are not limited to EU‑flagged vessels but instead also target non‑EU vessels involved in practices aimed at circumventing the oil price cap mechanism.

In parallel, the EU has expanded the port listings for their connections with the shadow fleet and circumvention of the oil price cap. It has listed two Russian ports, Murmansk and Tuapse, and, for the first time, a third country port (Karimun Oil Terminal, in Indonesia).

Beyond designations, the package includes a new, concrete due diligence for EU operators selling or transferring oil tankers (HS code ex 8901 20) to buyers in third countries, in order to ensure that such vessels do not join or support the shadow fleet. Article 3q of Regulation (EU) 833/2014 has been fully replaced and now requires any EU sellers to:

• carry out and document an appropriate risk assessment, proportionately to their nature and size, of the risk of retransfer of the vessel to Russia or for use in Russia;
• implement appropriate policies and controls, proportionately to their nature and size, to manage and mitigate that risk effectively;
• include in the sale agreement a written contractual prohibition on any further resale or transfer to Russia or for use in Russia, and require the buyer to mirror that prohibition in any subsequent transfer of the vessel; and
• notify the competent authority of the relevant Member State immediately upon completion of any such sale or transfer, providing details of the identities of seller and buyer, the IMO ship identification number, and the vessel’s Call Sign.

On the new due diligence obligation, two practical points stand out. First, Article 3q uses open-textured standards (“proportionately to their nature and size” and “appropriate”), meaning the expected depth of diligence and controls will likely be assessed case-by-case. Further guidance on what “proportionate” looks like for different seller profiles would be welcome. Second, the obligation to notify the competent authority “immediately” upon completion is not defined. In our view, it is likely to be interpreted as “without undue delay”, requiring sellers to be in a position to report the required information at closing.

LNG terminal services ban (effective 1 January 2027)

The 20th package introduces a new prohibition on the provision of LNG terminal services to Russian entities, and to EU-established entities that are more than 50% owned or controlled by a Russian natural or legal person. The prohibition applies as of 1 January 2027. Existing contracts must be terminated by that date and the package does not provide for a grandfathering period beyond the transition date itself.

The prohibition’s extension to EU-established entities that are more than 50% Russian-owned is worth highlighting. The standard formula in Regulation 833/2014 for service prohibitions targets entities “in Russia” or services “for use in Russia”, anchoring the prohibition to the geographic location or destination of the service. Article 3rb moves away from that formula by also capturing EU-established entities on the basis of their ownership structure, expressly to prevent the use of EU-registered subsidiaries or joint ventures as a conduit for circumvention.

Following the provided definition of “LNG terminal services”, the following activities are in scope of the prohibition: offloading, storage, sending out, berthing (both loading and unloading), regasification, backhaul liquefaction, truck loading, and bunkering of LNG falling under CN code 2711 11 00. The definition further includes ancillary services and temporary storage necessary for the regasification process and subsequent delivery to the transmission system.

EU operators with contracts in scope are recommended to carry out a targeted review well before 1 January 2027. This means identifying the governing law of each affected contract, mapping available exit routes, and executing the appropriate steps in time. While the prohibition sets a hard compliance deadline, it leaves the contractual mechanics of unwinding entirely to the applicable law.

The package further tightens restrictions around LNG transshipment operations, including ship‑to‑ship transfers, the use of EU ports as transit points, and prohibitions on maintenance and “certain other services” for Russian LNG tankers and icebreakers. The legal risk is increasingly tied to participation anywhere in the logistics chain, not only the initial sale of energy products.

Financial measures: closing circumvention routes in payments and digital assets

Prohibition on the digital rouble and crypto-asset service providers

Another worth mentioning feature of the 20th package is the EU’s sharper stance on alternative payment methods. With Russia largely having decoupled from SWIFT for years now, non‑traditional payment mechanisms like crypto‑assets and Russia‑linked digital instruments have been used to route value around restrictions.

As a result, the package prohibits any transaction involving central bank digital currencies, such as the digital rouble or providing support to the development of such projects. In addition, a blanket prohibition on transacting with any crypto-asset service provider or exchange platform established in Russia is introduced, moving away from targeted listing towards a jurisdiction-wide prohibition.

Extension of transaction ban to non-financial entities

The package also extends the transaction ban to non-financial entities offering services that enable international transactions through netting, set-off, reconciliation or settlement, identified by the EU as new circumvention schemes to enable international transactions without using traditional payment channels. Four entities are designated immediately in a new Part D of Annex XLV (Arneis, Asia Import Group, GPAgent and Platejka), effective 14 May 2026.

Transaction ban for additional banks and third country institutions

The package imposes a transaction ban on another 20 Russian banks, effective 14 May 2026. The exemption permitting the receipt of payments due and the fulfilment of prior obligations by the entities included in Annex XIV to Regulation (EU) No 833/2014 has been extended from 15 May 2022 to 24 April 2026. An exemption was added for the payment of reasonable professional fees or the reimbursement of incurred expenses associated with the provision of legal services.

In addition, 4 financial institutions in third countries (Laos, Kyrgyzstan and Azerbaijan) are targeted with a transaction ban for connecting to the system for transfer of financial messages of the Central Bank of the Russian Federation, or enabling the circumvention of EU restrictive measures, also effective 14 May 2026.

Trade & anti circumvention: updated goods lists and third country routing risks

Expanded import and export ban

The updated annexes include restrictions affecting among others:

• laboratory glassware;
• certain high‑performance lubricants and lubricant additives;
• energetic materials and chemicals;
• rubber and articles of vulcanised rubber;
• articles made of steel;
• tools for metal production; and
• industrial tractors.

In addition, the EU introduced further restrictions on imports of goods generating significant revenues for Russia, including certain raw materials, metals and minerals, steel and other metal scrap, certain chemicals, vulcanised rubber goods, and tanned fur skins.

Legal protection for EU operators

Extension of the no-claims prohibition to third-country operators: Article 11(1)(d)

The 20th package adds a new point (d) to Article 11(1) of Regulation 833/2014, extending the no-claims prohibition to third-country operators that supply prohibited goods, technology or services to the persons, entities or bodies already covered by Article 11(1)(a), (b) and (c), or for use in Russia. The phrase “whether or not originating in the Union” is the critical addition: it also captures goods and services that do not originate in the EU but are routed through or by third-country operators toward sanctioned Russian persons or for use in Russia.

The practical effect should not be overstated: Article 13 still determines when the EU has jurisdiction to enforce. For third-country operators with no EU nexus, practical enforceability remains limited. The provision is best read as a compliance signal and a basis for enforcement where EU courts can establish jurisdiction, rather than as a broadly applicable prohibition enforceable against all third-country actors.

Damages for enforcement of Russian judgments in third countries: Article 11a (revised)

The revised Article 11a introduces a second paragraph extending the existing damages regime beyond Russia-based proceedings. The new paragraph covers the scenario in which a court or administrative body in a third country, not being Russia, issues a decision enforcing a Russian judgment that upholds the type of claims referred to in Article 11a(1). In such cases, EU persons may recover direct and indirect damages, including legal costs, before the competent courts of a Member State from the persons or entities seeking or cooperating in that enforcement, as well as from entities that own or control them.

Damages for enforcement of Russia’s “temporary management” measures: Article 11b(1a)

Article 11b(1) of Regulation (EU) 833/2014 already provides a damages remedy for EU persons who suffer loss as a result of Russia’s so-called “temporary management” measures. These are Decree No. 302 of 25 April 2023 and Federal Law No. 470-FZ of 4 August 2023, legislation under which the Russian government can impose forced administration over assets in Russia belonging to persons from “unfriendly states,” i.e., states that have imposed sanctions on Russia. In practice, this means that Russian-appointed managers can take over the ownership or operational control of foreign-owned companies or assets located in Russia, effectively expropriating them. The EU has characterised this as “tantamount to expropriation.”

The new paragraph 1a extends that damages framework to a further scenario: where a court or administrative body in a third country other than Russia issues a decision enforcing or implementing those same Russian “temporary management” measures, EU persons may now also seek to recover damages before Member State courts. Two cumulative conditions apply: (i) the third-country decision must be unlawful under international customary law or under a bilateral investment treaty concluded between the relevant Member State and the relevant jurisdiction; and (ii) the person concerned must not otherwise have effective access to remedies in that jurisdiction.

Anti-suit relief against abusive Russian court proceedings: Article 11ca

Where persons or entities falling under Article 11(1)(a), (b) or (c), i.e. listed entities, Russian persons, and their proxies, have initiated proceedings before a Russian court in breach of an exclusive jurisdiction or arbitration clause, or pursuant to Russian procedural law (specifically Articles 248.1 and 248.2 of the Russian Arbitration Procedure Code), the protected EU party may now apply to a Member State court for:

• an order upholding the exclusive jurisdiction or arbitration clause; and
• an order requiring the opposing party not to initiate or to discontinue those Russian proceedings.

Failure to comply with such an order triggers financial penalties proportionate to the potential loss of the protected party, payable directly to that party.

The road ahead

The 20th package is an important addition to the EU sanctions architecture and includes more precision, and more anti‑circumvention pressure both within Russia‑related trade flows and across third‑country routes.

The new package signals a maturing sanctions regime: one that is less concerned with adding new prohibitions than with ensuring that existing ones actually bite. Whether that precision translates into real economic pressure on Russia will ultimately depend as much on enforcement capacity as on legislative design. At the same time, EU leaders are already pushing to move ahead with a 21st sanctions package against Russia.