On 23 April 2026, the EU adopted its 20^th package of sanctions against Russia. These measures are contained in (i) Council Regulation (EU) 2026/506 (see here), (ii) Council Implementing Regulation (EU) 2026/509 (see here), and (iii) Council Regulation (EU) 2026/511 (see here), as published in the Official Journal of the EU.

The latest package introduces further restrictive measures spanning energy, shipping, trade, finance, and anti-circumvention, alongside expanded asset freeze and travel ban designations. This summary highlights the key measures as follows.

A. Regulation (EU) 2026/506 – Amendments to the Main Sanctions Framework

Energy

• From 1 January 2027, it is prohibited to provide LNG terminal services, directly or indirectly, to any person or entity in Russia or to any EU-established entity that is more than 50% owned, or controlled, by a Russian citizen or by a person or entity in Russia. Existing contracts must terminate by that date.
• A full ban on maritime services related to Russian crude oil and petroleum products has been agreed in principle. However, implementation is deferred: the Council will decide, on a joint proposal from the High Representative and the Commission, following full coordination with the G7 and the Price Cap Coalition.

Shipping and the shadow fleet

• 46 new vessels have been added to the shadow fleet list (entries 606–651), and 11 have been removed, bringing the net total to approximately 640 vessels.
• It is prohibited to provide technical assistance, brokering services or financing related to certain ice-breaker vessels or LNG tankers. For Russian-flagged, Russian-certified or Russian-owned/managed LNG tankers, this applies from 25 April 2026. For LNG tankers operating in Russia or for use in Russia but not Russian-flagged or-owned, the ban applies from 1 January 2027. The icebreaker ban applies from entry into force.
• Restrictions on tanker sales under Article 3q has been expanded. All tanker sales to third countries must now include a mandatory contractual clause prohibiting resale or transfer to Russia. Sellers are now required to conduct documented risk assessments of retransfer to Russia, implement proportionate controls to mitigate those risks, and notify the competent authority of the relevant Member State immediately upon any sale (providing seller and purchaser identities, incorporation documents, IMO number and call sign). The contractual prohibition must cascade: the third-country purchaser must mirror it in any onward resale and require each subsequent acquirer to do the same.
• A new derogation has been introduced to facilitate the recycling of listed shadow fleet vessels that have reached end-of-life.
• The ports of Murmansk and Tuapse in Russia, and the Karimun Oil Terminal in Indonesia, have been added to the restricted ports list and are subject to transaction bans under Article 5ae.

Export and import controls

• 60 new entities have been added to the list of those supporting Russia’s military-industrial complex, including companies in China, Hong Kong, Türkiye and the UAE, subject to tighter dual-use export restrictions.
• New items restricted for export to Russia include laboratory glassware, high-performance lubricants and their additives, energetic materials, chemicals, rubber articles, steel articles and industrial tractors.
• Further import restrictions have been introduced on Russian raw materials including salt, pebbles, silicon and ammonia; metals including nickel, iron ores and concentrates, unrefined and refined copper, and scrap metals including aluminium; chemicals; articles of vulcanised rubber; and tanned furskins.
• The list of goods prohibited from transit through Russia has been extended.

Financial and banking measures

• 20 Russian banks have been added to the transaction ban list, effective 14 May 2026.
• 5 previously listed financial entities have been removed after closing relevant loopholes.
• 4 new financial entities in third countries have been listed for facilitating Russia’s illicit financial activities.
• 2 Kyrgyz banks – Keremet Bank and OJSC Capital Bank of Central Asia – have been added for supporting Russia’s war effort.
• 1 Laotian bank, Joint Development Bank, has also been listed.

Digital currencies and crypto-assets

• Transactions involving Russia’s digital rouble and certain crypto-assets (including RUBx) are prohibited, with effect from 24 May 2026.
• All crypto-asset service providers and platforms established in Russia are banned from engaging in transactions with EU persons, also effective 24 May 2026.
• Operators outside the financial sector that enable international transactions circumventing sanctions (through netting, set-off, reconciliation or settlement) are now also subject to a transaction ban. Four such entities have been listed: Arneis, Asia Import Group, GPAgent and Platejka.

Illegitimate “temporary management”

• The Council may impose a transaction ban on Russian entities that have benefited from the Russian Government’s illegitimate seizure (so-called “temporary management”) of EU-owned property in Russia.

Managed security services

• The provision of managed security services to the Government of Russia and to entities established in Russia is now restricted.

Anti-circumvention

• The Kyrgyz Republic has been identified as a jurisdiction with systematic and persistent circumvention risk – the first country designated under the EU’s anti-circumvention tool. CHP imports from the EU to the Kyrgyz Republic were almost 800% higher, and exports from the Kyrgyz Republic to Russia were 1,200% higher, than pre-war levels. The package bans EU sales to the Kyrgyz Republic of machining centres for working metal and machines for the reception, conversion and transmission or regeneration of voice, images or other data (including switching and routing apparatus such as modems and routers).

Legal protections for EU operators

• EU courts may now issue orders requiring parties to cease or refrain from initiating legal proceedings before Russian courts that assert jurisdiction over disputes affected by EU sanctions.
• EU persons may claim damages before Member State courts from parties seeking to enforce Russian court or administrative decisions in third countries, including in cases involving illegitimate expropriations.
• The prohibition on satisfying claims has been broadened to cover claims by third-country persons (other than those in listed partner countries) in connection with contracts affected by sanctions.

B. Regulation (EU) 2026/509 – New Designations (Asset Freeze and Travel Ban)

• 37 individuals and 80 entities (117 total) have been added to the EU’s asset freeze and travel ban list under Regulation (EU) No 269/2014.
• Designated individuals include military officials involved in the use of chemical weapons against Ukraine, directors of Russian state institutions conducting unauthorised archaeological excavations in occupied Crimea, leading businesspersons, and persons facilitating sanctions circumvention through supply chains for restricted goods such as high-purity hydrogen chloride used in semiconductor production.
• Designated entities include producers of first-person-view (FPV) drones for the Russian armed forces, Russian refineries (including Tuapse, Komsomolsk, Angarsk, Achinsk, Ryazan and Afipsky, as well as multiple LUKOIL refineries), Russian oil producers (Bashneft and Slavneft and their subsidiaries), Gazprom subsidiaries (including Gazprom Flot, Gazprom LNG Technologies, Gazstroyprom, Gazpromneft Marine Bunker and Rosneftflot), UAE-based firms linked to the shadow fleet (including Centauri Services, Lumen Ship Management, Lark Shipmanagement, Alghaf Marine, and the 2Rivers-linked Altrum Group FZCO / Novus Middle East DMCC), United Capital Partners Investment Group, Soglasie Insurance Company, owners of vessels alleged to have been involved in the theft of Ukrainian grain, and entities supporting Russia’s military-industrial complex in third countries.

C. Regulation (EU) 2026/511 – Amendments to the Asset Freeze Regime

• The listing criteria under Regulation (EU) No 269/2014 have been expanded to cover persons linked to vessels involved in irregular and high-risk shipping of Russian crude oil, petroleum products or mineral products.
• New derogations have been introduced allowing the limited release of frozen funds for the payment of arbitration costs only (not principal amounts, damages or interest), where arbitral proceedings were initiated by a listed person and costs are awarded to a non-listed, non-Russian party.
• Further derogations permit the release of frozen funds to support cultural policy organisations of Member States operating in Russia, and to facilitate a significant reduction in a listed entity’s reliance on Russian crude oil imports (to be completed by 24 October 2026).
• The prohibition on satisfying claims has been broadened to cover claims brought by third-country persons (other than partner countries), and EU persons may now recover damages from those seeking enforcement of Russian decisions in third countries.
• Insurance derogations have been extended to Soglasie Insurance Company, a newly listed insurer.