EU adopts 21st package of restrictive measures against Russia

The Council adopted five regulations, two of which concern Belarus:

• Council Regulation (EU) 2026/1844 of 23 July 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 Regulation (EU) 2026/1848 of 23 July 2026 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine
• Council Implementing Regulation (EU) 2026/1843 of 23 July 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) 2026/1846 of 23 July 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) 2026/1817 of 23 July 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

Asset freeze framework

48 individuals and 170 entities are newly subject to an asset freeze and to the prohibition on making economic resources available to them.

Notable among these designations are 94 banks and financial institutions, 56 entities linked to Russia’s military-industrial complex, and 18 operating in the Russian energy sector. The Council also designated 4 persons connected to the A7 network – a Russian crypto-based payment channel used to circumvent EU sanctions.

Financial sector restrictions

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

• 33 additional Russian banks;
• four third-country banks – in Mongolia, Kyrgyzstan, and India – due to their involvement in sanctions circumvention;
• 14 cryptoasset service providers established in Georgia, Panama, El Salvador, UAE, the Marshall Islands, and Belarus.

In addition, Russian nationals are now prohibited from owning, controlling, or serving on the board of EU cryptoasset service providers.

The Council also introduced a mechanism to designate third countries that have systematically failed to prevent crypto-based circumvention of EU sanctions, and to prohibit EU operators from dealing with any cryptoasset service provider located there.

Energy sector restrictions

The 21^st package has frozen the automatic adjustment of the Russian oil price cap agreed in the 18^th sanctions package until 15 July 2027, subject to an interim review.[1]  

Measures regarding LNG:

• a one-year exemption allows EU operators to keep transferring Russian LNG to third countries under pre-24 February 2022 contracts;
• EU sellers must notify any LNG tanker sale;
• the ban on providing LNG terminal services to Russian persons is extended to third-country operators owned or controlled by Russian persons.

In addition, a transaction ban is imposed on (i) Georgia’s Kulevi refinery, effective 25 January 2027, and (ii) five oil traders – Vistula Delta Global FZE, Estrella Integrated FZE, Linglong Trading Group FZE, Arcadia International FZE, and Nexus Oil Trading FZCO.

Russia’s shadow fleet

A further 41 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 673.

The Council also broadened the listing criteria to capture vessels that service or refuel Russia’s shadow fleet.

Infrastructure restrictions

A full transaction ban has now been imposed on two Russian ports (Olya and Vysotsk) and four Russian airports (Sheremetyevo, Ulyanovsk-Vostochny, Rostov-on-Don Platov and Mineralnye Vody).

Export controls

Export bans to Russia or for use in Russia are expanded to include items used in Russia’s war effort. These notably include specialty metals and alloys, UAV-specific aviation equipment, and flight termination systems for drones and missiles.

Furthermore, 51 Russian and foreign companies supporting Russia’s military-industrial complex or enabling EU sanctions circumvention are now subject to stricter export control restrictions on dual-use goods and technologies.

Import restrictions

New import bans are introduced on goods generating significant revenues for Russia. These include certain ores, metals and metal oxides, tall oil, glassware, and car parts.

Legal protection for EU operators

The 21^st package introduces mechanisms protecting EU operators against Russian retaliatory actions:

• EU persons may now recover, before Member State courts, damages suffered as a result of claims brought against them before third-country courts in connection with sanctions-affected contracts or transactions, where they have no effective access to remedies in the third country concerned;
• This recovery right is extended to cover claims brought by third-country persons that have sold, supplied, transferred or exported goods, technology, or services whose export to Russia is prohibited;
• Member State courts can now issue “anti-enforcement injunctions”. These are orders restraining a party from enforcing an unlawful Russian judgment or decision in third countries;
• Member States must not recognise or enforce any judicial, arbitral, or administrative decision issued in Russia in connection with sanctions-affected contracts or transactions.

Restrictive measures targeting Belarus

The Council also introduced restrictive measures targeting Belarus, largely mirroring those imposed on Russia. These include import bans on goods generating significant revenue for Belarus, export restrictions on goods and technology used by its military industry, and legal protection for EU operators equivalent to that provided under the regime relating to Russia.

[1] . The 18th package introduced a dynamic pricing mechanism setting the price cap for Russian crude oil exported to third countries at 15% below the average market price for Russian crude oil. In practice, this lowered the cap from USD 60 to USD 47.60 per barrel, with automatic adjustments every six months and the possibility of ad hoc reviews.