EU adopts 20th package of restrictive measures against Russia

On 23 April 2026, the Council of the EU adopted its 20th package of restrictive measures against Russia, which supplements those detailed in our previous newsflashes.

This package notably targets Russia’s energy sector and military-industrial complex, reinforces legal protections for EU operators against Russian retaliation, and strengthens (once again) anti-circumvention measures.

The Council of the EU adopted five regulations, the last two of which relate to Belarus:

• Council Regulation (EU) 2026/506 of 23 April 2026 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
• Council Regulation (EU) 2026/511 of 23 April 2026 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
• Council Implementing Regulation (EU) 2026/509 of 23 April 2026 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine
• Council Regulation (EU) 2026/513 of 23 April 2026 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine
• Council Implementing Regulation (EU) 2026/505 of 23 April 2026 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

New designations

The 20^th package adds 37 individuals and 80 entities to the asset freeze list and prohibition on making economic resources available. This primarily targets Russian energy and military entities, as well as third-country suppliers of critical high-tech items to Russia.

Financial sector restrictions

EU operators are now prohibited from engaging in any transaction with:

• 20 additional Russian banks;
• four financial institutions from Azerbaijan, Kyrgyzstan, and Laos, due to their involvement in sanctions circumvention;
• Russian cryptoasset service providers;
• RUBx (rouble-pegged stablecoin) and the digital rouble;
• third-country non-financial operators offering services enabling the performance of international payments that circumvent EU sanctions.

In contrast, five third-country financial institutions are also removed from the transaction ban after committing to comply with EU sanctions.

Energy sector restrictions

The 20^th package introduces a mechanism for a future maritime services ban on Russian crude oil and petroleum products, to be activated in coordination with the G7 and the Price Cap Coalition.[1]

In addition, it prohibits providing services or assistance to Russian icebreakers and LNG tankers, with this ban extending to all LNG tankers operating in or for Russia from 1 January 2027, regardless of ownership. From that date, LNG terminal services will also be prohibited for any Russian entity or EU-based entity more than 50% owned or controlled by Russian persons.

On the other hand, Liechtenstein has been added to the list of partner countries from which petroleum products may be imported without requiring proof of the origin of the crude oil used for refining.

Russia’s shadow fleet

An additional 46 vessels are now subject to an EU port access ban and a ban on the provision of maritime services, bringing the total number of these vessels to 632. In parallel, 11 vessels have been delisted after returning to compliance with EU sanctions.
EU sellers of tanker vessels to third countries are now subject to mandatory due diligence requirements and must include a contractual “no Russia” clause, to be passed on in subsequent sales, to ensure vessels sold in the EU do not support Russia’s shadow fleet.

Export controls

Export bans are expanded to include laboratory glassware, high-performance lubricants and additives, energetic materials, certain chemicals, rubber articles, steel articles, tools for metal production and industrial tractors.

Furthermore, 60 Russian and foreign companies supporting Russia’s military-industrial complex are now subject to stricter export control restrictions on dual-use goods and technologies.

A new ban is also introduced on providing cybersecurity services to Russian persons.

Import restrictions

New import bans have been introduced on goods generating significant revenues for Russia. These include certain raw materials, minerals, metals and scrap, tanned furskins and articles of vulcanised rubber.

An annual import quota of 688,000 metric tonnes is also introduced for ammonia originating from Russia.

Additionally, EU importers of polished diamonds must now provide a due diligence statement confirming that the diamonds were not mined, processed or produced in Russia.

Anti-circumvention measures

For the first time, the EU has activated its anti-circumvention tool under Article 12f of Regulation (EU) No 833/2014, which allows it to restrict exports to third countries that are used to systematically circumvent EU sanctions. As part of the 20th package, the EU has banned the export of certain communication equipment and metalworking machining centres to the Kyrgyz Republic, following a failure to prevent their re-export to Russia.

A transaction ban also applies to the Russian ports of Murmansk and Tuapse, as well as the Karimun Oil Terminal in Indonesia, due to their role in bypassing the oil price cap.

Legal protection for EU operators

The 20^th package introduces mechanisms protecting EU operators against Russian retaliatory actions:

• EU Member State courts can now issue injunctions ordering parties to stop actions brought in Russian courts in breach of exclusive jurisdiction or arbitration clauses or under the Russian Arbitration Procedure Code, with penalties for non-compliance payable to the EU operator;
• EU operators may now claim damages in respect of (i) claims brought before third-country courts in connection with sanctions-affected contracts, and (ii) the enforcement of related judgments or administrative decisions in any third country other than Russia;
• the prohibition on satisfaction of claims against EU operators is extended to claims by third-country operators selling goods, technology or services whose export to Russia is prohibited;
• a transaction ban has been introduced for:
  • Russian entities benefitting from Russia’s “temporary management” decrees, which are measures tantamount to expropriation that transfer EU assets to Russian competitors or grant them market advantages;
  • Russian entities using EU companies’ intellectual property rights or trade secrets without consent;
  • persons seeking or cooperating in the enforcement outside the EU of abusive Russian court decisions or expropriation decrees relating to contracts affected by sanctions.
• a new derogation allows for the release of a listed person’s frozen funds to cover costs of arbitral proceedings awarded against it, provided the proceedings were initiated by the listed person and the award is in favour of a non-listed, non-Russian party.

Other measures

The existing broadcasting ban now extends to “mirror” media outlets that republish identical content from already-listed entities.

EU research institutions, universities, higher education establishments, NGOs, public bodies and businesses engaged in research and innovation are now prohibited from accepting funding, donations or grants from the Russian government.

Restrictive measures targeting Belarus

Three additional entities have been added to the asset freeze list, including Chinese state-owned China Space Sanjiang, for its role in producing Belarusian military goods.

The 20^th package further mirrors several of the same restrictions imposed on Russia onto Belarus, particularly regarding trade, cryptoassets, services and legal protections for EU operators.

¹ The Price Cap Coalition consists of the G7, the European Union, and Australia, which jointly implement a price cap on Russian seaborne crude oil and certain refined petroleum products.