On Thursday 23 April 2026, the EU approved what is now its 20th sanctions package in response to the war of aggression against Ukraine. The package contains a wide range of measures targeting the energy and financial sectors, including cryptocurrencies. It also introduces new import and export restrictions and takes additional steps to shield EU companies from Russian countersanctions. The package moreover marks the first use of the anti-circumvention tool introduced with the 11th sanctions package, which allows the EU to ban the export of certain high-risk EU goods to countries involved in the circumvention of EU sanctions. In parallel, the EU approved a comprehensive EUR 90 billion aid package for Ukraine to ensure its financial stability.
With Hungary and Slovakia withdrawing their political opposition to new EU measures against Russia, the EU has now adopted the 20th sanctions package originally planned for February 2026 to coincide with the anniversary of Russia’s full-scale invasion of Ukraine. The EU’s latest measures build on its 19th sanctions package adopted in October 2025 (our report: Foreign Trade Law Update: 19th Package of EU Sanctions against Russia | Gleiss Lutz). The 20th sanctions package entered into force on 24 April 2026 and covers measures across a wide range of areas already targeted in previous packages, spanning energy, shipping – including the shadow fleet – and finance as well as new import and export restrictions and steps to protect EU companies from Russian countersanctions.
Alongside the 20th sanctions package, the Council adopted the final measures required to activate the EU’s EUR 90 billion loan for Ukraine.
EU sanctions against Russia
The 20th sanctions package mainly incorporates the following acts:
- Amending Regulation (EU) 2026/506 tightens the largely trade-related sanctions set out in Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine.
- Amending Regulation (EU) 2026/511 largely expands the listing criteria set out in Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Implementing Regulation (EU) 2026/509 amends Annex I to Regulation (EU) 269/2014, which lists the natural and legal persons subject to financial sanctions.
- Amending Regulation (EU) 2026/513 implements the trade-related sanctions set out in Regulation (EC) 765/2006 on restrictive measures in view of the situation in Belarus and Belarus’ involvement in Russia’s aggression against Ukraine. Implementing Regulation (EU) 2026/505 amends Annex I to Regulation (EC) 765/2006, which lists the natural and legal persons subject to financial sanctions.
Particularly noteworthy changes include:
Tougher sanctions against Russia’s shadow fleet and maritime transport
The EU has further expanded its measures against Russia’s shadow fleet. The 20th sanctions package adds an additional 46 vessels suspected of being involved in the circumvention of sanctions to the list in Annex XLII to Regulation (EU) 833/2014. This brings the total number of sanctioned vessels to 632.
A new due diligence requirement has been introduced for the sale of tanker vessels used for the transport of crude oil or petroleum products (Article 3q Regulation (EU) 833/2014). EU economic operators selling such tanker vessels to buyers in third countries will in future be required to assess and document the risks of subsequent resale to Russia and put in place appropriate policies to mitigate those risks. A mandatory clause must also be included in the sales agreements stating that the vessels cannot be sold on or transferred to persons in Russia or for use in Russia. The provision is clearly modelled on the due diligence requirements set out in Articles 12g and 12gb Regulation (EU) 833/2014, which apply to the sale, supply, transfer and export of common high priority items. Unlike the aforementioned provisions, the new Article 3q Regulation (EU) 833/2014 does not however provide for an exemption covering transactions with partner countries listed in Annex VIII.
The new Article 3sa Regulation (EU) 833/2014 moreover introduces restrictions on ice-breakers and LNG tanker vessels operating in Russia. It is now prohibited to provide technical assistance, brokering services, financing or financial assistance related to these vessels if they fly the Russian flag, are owned or managed by Russian persons or are operating in Russia. Staggered transition periods apply to LNG tanker vessels: vessels flying the Russian flag or owned by Russians will be subject to the ban from 25 April 2026, whereas the ban will only apply from 1 January 2027 to LNG tanker vessels operating in Russia that do not fly the Russian flag.
A further two ports in Russia – Murmansk and Tuapse – as well as the Karimun Oil Terminal in Indonesia have been added to the list of ports used by shadow fleet vessels to circumvent the oil price cap and are therefore subject to a transaction ban.
Basis for a comprehensive ban on maritime services
The 20th sanctions package creates the basis for a future comprehensive ban on maritime services related to Russian crude oil and petroleum products. Previously, the ban on maritime services applied only to vessels and companies that did not comply with the Western oil price cap. In future, all maritime services related to Russian crude oil are to be prohibited – regardless of price. This ban is intended to replace the existing G7 oil price cap, but its implementation is contingent on reaching consensus at G7 level. The Council will decide on the application of the oil price cap based on a joint proposal from the High Representative and the Commission.
Expansion of sanctions in the financial sector
Sanctions in the financial sector have also been significantly ramped up. This includes adding 20 credit or financial institutions to the list of legal persons subject to a transaction ban, bringing the number of Russian banks denied access to the European single market to 70. Beyond this, the transaction ban has been extended to credit institutions outside Russia that support its war effort through financial services, notably in Kyrgyzstan, Laos and Azerbaijan.
Sanctions related to cryptocurrencies have likewise been significantly tightened. The list of prohibited crypto-assets has been expanded to include additional cryptocurrencies, and a complete sector-wide ban has been introduced for crypto-platforms established in Russia. It is worth noting that this transaction ban is not limited to persons explicitly listed in an annex, as is usually the case, but instead applies to all legal persons, entities or bodies established in Russia that provide crypto-assets services or enable the exchange or transfer of crypto-assets via a platform.
The sanctions package also introduces new restrictions affecting intermediaries that facilitate circumvention. Under the new Article 5ad(1)(d) Regulation (EU) 833/2014, operators outside the financial sector now, for the first time, fall within the scope of the Regulation if they offer services that enable the performance of international transactions and frustrate the purpose of the restrictive measures.
First activation of anti-circumvention tool
Another notable development is the EU’s first use of the anti-circumvention tool under Article 12f Regulation (EU) 833/2014 to prohibit the sale, supply, transfer or export of certain CNC machines and telecommunications equipment to the Kyrgyz Republic. This step addresses the systematic and sustained diversion of these EU-origin goods from the Kyrgyz Republic to Russia, where they are used in the manufacture of drones and missiles. An analysis of trade data identified a significant increase in re-exports of these items to Russia via the Kyrgyz Republic. While the anti-circumvention tool was already introduced as part of the 11th sanctions package in June 2023, this is the first time that entries have been added to the corresponding Annex XXXIII.
Further personal sanctions
The EU has also expanded the measures against companies operating in Russia’s military-industrial sector. The latest sanctions package designates 58 additional companies and individuals. Annex IV to Regulation (EU) 833/2014 now lists a large number of new entities that directly support the Russian military-industrial complex, including companies based not only in Russia but also in third countries such as China, Hong Kong, Turkey, the United Arab Emirates, Kazakhstan and Thailand. Under Article 2b Regulation (EU) 833/2014, these entities are subject to an export ban on dual-use goods and on items that might generally contribute to the technological enhancement of Russia’s defence sector.
Further businesspersons and entities have also been added to the sanctions list in Annex I to Regulation (EU) 269/2014 and will accordingly have their assets frozen and be subject to the prohibition on the provision of funds or economic resources. These include companies from the energy sector, as well as persons and companies involved in the abduction of children from Ukraine and the looting of Ukraine’s cultural heritage.
Additional trade restrictions
The latest sanctions package once again extends the range of goods subject to import and export restrictions. On the export side, the lists have been expanded to cover additional goods that might contribute to the enhancement of Russia’s industrial capacities, including chemicals, rubber and vulcanised rubber products, steel products, tools for metal production and industrial tractors. Other goods and technologies that might contribute to Russia’s military and technological enhancement, including laboratory glassware, high performance lubricants and their additives, and energetic materials, have also been added.
On the import side, further restrictions have been introduced for goods that generate substantial revenue for Russia, including certain raw materials and metals such as copper, nickel and aluminium, certain minerals, scrap of steel and other metals, chemicals, vulcanised rubber products and tanned furskins. The overall value of the new import restrictions exceeds EUR 570 million, while the new export restrictions are valued at over EUR 360 million.
Protection of EU companies
The EU has substantially enhanced the legal protection available to European companies against retaliatory actions by the Russian judiciary. Under the new Article 11ca Regulation (EU) 833/2014, Member States’ courts will in future be able to fine persons who bring abusive actions before Russian courts. If such judgments are enforced in third countries, EU companies will be entitled, under amended Articles 11a and 11b(1a) Regulation (EU) 833/2014, to claim damages from the responsible Russian party and its owners.
Transaction bans may moreover be imposed on Russian parties that benefit from the so-called “temporary management” of assets of European operators – which is tantamount to expropriation – as well as on entities that use the intellectual property rights of European companies in Russia without such companies’ consent. No entries have been added to the corresponding annexes to date, which means that these transaction bans have not yet been activated.
EU sanctions against Belarus
The 20th sanctions package also extends the sanctions against Belarus. It contains three new listings related to the Belarusian military-industrial complex and the Lukashenka regime including, for the first time, a Chinese state-owned company involved in the production of Belarusian military equipment.
The package also mirrors certain provisions of the Russian sanctions regime related to trade, finance, services and legal protection for EU companies in the Belarus regime. This applies in particular to the trade restrictions and bans on crypto services, cybersecurity and tourism. The Belarus sanctions regime will now apply until 28 February 2027.
Aid package for Ukraine
In parallel, the EU has approved an interest-free loan of EUR 90 billion to Ukraine for 2026 and 2027. The regulatory framework underpinning this loan was already adopted in February this year. EUR 60 billion of the loan is allocated to enhancing Ukraine’s defence capacities and supporting the procurement of military equipment. A further EUR 30 billion will be made available for macro-financial assistance and budget support. The aid package will be financed through joint EU bonds on the capital markets and backed by the long-term EU budget headroom. Ukraine will only be expected to repay the loan if Russia pays reparations after the war of aggression has ended; otherwise, the EU reserves the right to draw on frozen assets of the Central Bank of Russia.
Outlook
With the 20th sanctions package, the EU is yet again stepping up its economic and political pressure on Russia. This includes in-principle agreement on a comprehensive ban on maritime services, but consensus at G7 level is required for this to be implemented. Should the ban come into force, it would replace the existing oil price cap and significantly restrict Russia’s ability to generate revenue from oil exports. By activating its anti-circumvention tool for the first time, the EU is also sending a clear signal that it is committed to cracking down on the systematic circumvention of sanctions via third countries. Lastly, the planned EUR 90 billion package for Ukraine also underscores the EU’s long-term strategic course. Beyond demonstrating ongoing financial and economic support, it will also help bolster the country’s stability and resilience in dealing with the consequences of the war.
Forward
