The Council adopted its 21st package of restrictive measures against Russia on 23 July 2026. The instruments entered into force on 24 July 2026 (the day following publication in the Official Journal). The principal instruments are Regulation (EU) 2026/1848; Regulation (EU) 2026/1844; and Implementing Regulation (EU) 2026/1843 (amending and implementing Regulation (EU) No 269/2014).

Executive summary

• A notification duty applies to any EU-linked sale of an LNG tanker to a third country. The related due diligence and contractual obligations are not yet in force.
• Vessels that bunker, tow or conduct ship-to-ship transfers with designated vessels may themselves be designated. 41 vessels are added.
• Automatic adjustment of the crude oil price cap is suspended until 14 July 2027, freezing the current level.
• A new refinery transaction ban reaches refineries outside Russia. The first listing (Kulevi, Georgia) applies from 25 January 2027.
• 48 persons and 168 entities are newly asset-frozen, including ship managers, a bunkering operator and a crewing agency.
• 33 further banks join the transaction ban list from 13 August 2026.

Vessels, owners and operators

A wider net for “shadow fleet” designations

New points (h) and (i) of Article 3s(2) extend the vessel designation criteria beyond vessels engaged in the prohibited activity itself, to vessels providing services to designated vessels – bunkering and tug services are the examples given – and to vessels carrying out ship-to-ship transfers with them. Designation attaches to the vessel, but the commercial exposure falls on the operators and service providers behind it.

Forty-one vessels are added to Annex XLII (entries 652 to 692). Most are designated under point (b), for carrying Russian-origin crude, petroleum or mineral products while practising irregular and high-risk shipping practices within IMO Assembly resolution A.1192(33); others for supporting Russia’s energy sector (point (c)), carrying stolen Ukrainian grain or cultural goods (point (d)) and, in one case, defence-sector goods (point (a)). Five vessels – KUMANA, BILAL BEY, BEBEK-E, LADY JASMINE and OCEAN FORTUNE 18 – are the first designated under the new point (h). The Council’s press release puts the total designated fleet at 692 after this round.

Asset freezes reach further along the service chain

Implementing Regulation 2026/1843 adds 48 persons and 168 entities to Annex I to Regulation 269/2014. The listings extend well beyond vessel owners: they include ship managers such as White Agate Marine SPC (Oman) and Zulu Ships Management (UAE), Indian technical managers, the bunkering operator LLC “Lukoil-Marinbunker”, the seafarer recruitment agency LLC “Aquamarine Ship Management”, and several Russian refineries. For P&I clubs, hull underwriters, bunker suppliers, tug operators and manning agents, the asset freeze is the more consequential measure: it bites on funds and economic resources generally, not merely on services to a named ship. Screening should reach managers, crewing agents and other service providers in the chain, not only registered owners and vessels.

LNG carriers and terminals

LNG tanker sales: notification now, restrictions later

New Article 3qa of Regulation 833/2014 requires any national of a Member State, person residing in a Member State or entity established in the Union to notify its competent authority immediately on selling or otherwise transferring ownership of an LNG tanker (CN code ex 8901 20) to any third country. The notification must contain at least the identities of seller and purchaser, their incorporation documents including shareholding and management where applicable, the vessel’s IMO number and its call sign. The competent authority must inform the other Member States and the Commission within one week.

The remainder of Article 3qa is not yet operative. Paragraphs 4 to 9 – being the prohibition on selling LNG tankers to persons in Russia or for use in Russia, the seller’s obligation to identify and mitigate diversion risk proportionately to its nature and size, and the required contractual prohibition on onward resale together with mirrored flow-down terms binding subsequent buyers – apply only from the entry into force of a further Council regulation. The Council must review by 25 October 2026, on the basis of a Commission assessment of the notified data, whether that prohibition should be brought into force.

The recitals record that a Union seller acting in good faith, without information suggesting an intent to circumvent the measures, is not liable for a buyer’s subsequent breach of the end-use commitments; liability rests with the buyer. They also confirm that Article 3qa binds Union sellers only, has no extraterritorial application and imposes no compliance responsibility on the flag State. Clients in sale and purchase, ship finance or broking should establish notification workflows now and prepare anti-diversion flow-down clauses ahead of any prohibition.

Terminal services tightened

Article 3rb is replaced. From 1 January 2027 it will be prohibited to provide, directly or indirectly, LNG terminal services to any person, entity or body in Russia, or to any entity more than 50% owned, or controlled directly or indirectly, by a Russian citizen or by an entity in Russia. Maintaining contracts for such services after that date is separately prohibited. Terminal operators, port authorities and logistics providers should test ownership and control against the threshold well in advance: existing contracts must be wound down, not merely left to expire.

Temporary transfer exemption, with volume caps and reporting

Article 3ra(6) disapplies the transfer prohibition until 25 July 2027, and thereafter for successive one-year periods unless the Council decides otherwise on annual review, for transfers to third countries and related purchases where both transfer and purchase are executed under contracts concluded before 24 February 2022, exceeding one year in duration and unamended since. Permitted amendments are a closed list: lower quantities (and, for purchase contracts, lower prices and fees), confidentiality clauses, operational procedures, party addresses, transfers between affiliates, changes required by judicial or arbitral process and, for purchase contracts in landlocked countries, changes between national delivery points. The volume transferred in any year under the exemption is capped at the yearly volume of Russian-origin LNG transferred in 2025 by the relevant Union operator under its existing long-term contracts, irrespective of destination.

Operators must report historical volumes to their competent authority by 25 August 2026 and, from that date, shipment-level data every three months: cargo or bill of lading reference; vessel IMO number, name, flag State and carrier type; loading and discharge details; final destination; volumes; contract duration, value and gross revenue per cargo; and the names of purchaser, ultimate beneficiary, seller and shipper. The Commission must report by 25 June 2027 and annually thereafter, and the Council may shorten, extend or terminate the exemption. Purchases not linked to a transfer by a Union operator are prohibited from 1 January 2027, and recital 15 states that the resulting impossibility of performance may be invoked as force majeure to terminate existing obligations. Separately, Part B of Annex XXIX exempts carriage of Sakhalin-2 LNG to Japan and the Republic of Korea until 31 March 2028; the equivalent crude oil exemption for Japan is extended to the same date.

Oil: refineries, ports and the price cap

Refinery transaction ban with cross-border reach

New Article 5ae(2a) prohibits engaging, directly or indirectly, in any transaction with refineries listed in Part D of Annex XLVII. Part D is not confined to Russia: it may list refineries in third countries that are used (a) for the processing or refining of crude oil or the processing or blending of petroleum products listed in Annex XXV, or of mineral products, originating in Russia; or (b) in such a way as to facilitate or engage in the violation or circumvention, or otherwise significantly frustrate the provisions, of Regulation 833/2014, Regulation 269/2014, Regulation 692/2014 or Regulation 2022/263. One refinery is listed on both grounds – the Kulevi Oil Refinery in Georgia – and the prohibition applies to it from 25 January 2027. The Commission must report to the Council by 25 October 2026 on whether the listing should be maintained. The recitals state that transactions include access to the listed refinery’s facilities and the provision of any services. Traders, refiners, financiers and insurers should map counterparties’ refining sources now, given the reach of the criteria and the likelihood of further listings. The same Annex gains the Russian ports of Olya and Vysotsk and four airports, all with effect from 24 July 2026.

The price cap is frozen

The mechanism that automatically adjusts the crude oil price cap is suspended from 24 July 2026 to 14 July 2027 (Article 3n(11a)), the recitals citing “recent exceptional disturbances in the markets for crude oil and petroleum products“. The Commission’s corresponding obligation under Article 7a is suspended for the same period. The cap on which insurers, P&I clubs, flag registries and service providers rely will therefore hold at its current level rather than track the market. By 15 January 2027 the Commission must calculate the average market price of Russian crude over the 22 weeks from 25 June 2026 and report it to the Council, which may then amend Annex XXVIII on a joint proposal from the High Representative and the Commission. Absent a Council decision, the existing cap stands, and the automatic procedure resumes on 15 July 2027. This gives a period of relative certainty for contractual compliance thresholds, but a revised cap could take effect before the suspension ends.

Confiscated cargo: a safe disposal route

Article 3m(11) allows competent authorities to authorise the purchase, import or transfer of Russian-origin crude oil or petroleum products listed in Annex XXV, and related technical assistance, brokering, financing or other services, where the goods have been seized or confiscated in national administrative or judicial proceedings; remain under the effective control of the authorities, or an entity acting on their behalf, during custody, management and storage pending any sale; and the operations do not result, directly or indirectly, in any payment or economic resource for the benefit of Russian persons or persons established in Russia. Article 3nb(5) permits temporary storage, including under the free-zone procedure, on equivalent conditions. This is directly relevant to cargo interests, insurers, salvors and terminal operators dealing with detained vessels or cargoes.

Insurance and financial dimensions

Derogation for insurance indemnity payments

Regulation 2026/1844 inserts Article 6b(5ea) into Regulation 269/2014. Competent authorities may authorise the release, or making available, of frozen funds where necessary to allow a payment due by a person listed under Article 3(1), point (k), or by an insurance provider, as a result of a risk for which that listed person is liable. The payment must be made to an entity established in the Union, the EEA, Switzerland or a partner country listed in Annex VIII to Regulation 833/2014, or to a national or resident of such a State who is not itself listed, and must constitute the indemnity or benefit arising on materialisation of the insured risk. The derogation therefore operates in favour of the EU-side claimant: it unlocks recovery from, or on account of, a listed liable party, subject always to prior authorisation.

Russian proceedings and judgments

Regulation 2026/1844 inserts a new Article 11c into Regulation 269/2014, and Regulation 2026/1848 replaces Article 11c(1) of Regulation 833/2014, so that no injunction, order, relief, judgment or other court or administrative decision of a Russian court or authority holding an EU person liable in connection with a contract or transaction affected by the measures is to be recognised, given effect or enforced in a Member State. Both provisions expressly capture, but are not limited to, decisions under Articles 248.1 and 248.2 of the Russian Arbitration Procedure Code, on which Russian courts have relied to assert exclusive jurisdiction over sanctions-related disputes and to restrain foreign proceedings. Article 11ca of Regulation 833/2014 is also replaced: the existing power of Member State courts to order a claimant not to commence, or to discontinue, abusive Russian proceedings is extended to orders not to seek to enforce, recognise or rely on any resulting decision in any jurisdiction, backed by financial penalties proportionate to the potential loss and payable to the applicant. The damages-recovery provisions in Article 11a of both Regulations are widened accordingly.

Financial institutions and banking exposure

Thirty-three credit or financial institutions are added to Annex XIV to Regulation 833/2014 with effect from 13 August 2026: large or regionally significant Russian banks, banks facilitating cross-border payments, banks operating in or providing services over occupied Ukrainian territory, banks serving Russian military personnel, and banks already designated by the EU or partner countries. Annex XLIV gains one entity (CJSC Eco-Islamic Bank, Kyrgyzstan, from 13 August 2026) and loses one (Yelo Bank, Azerbaijan). Annex XLV Part A gains 17 entities: six banks and payment businesses from 13 August 2026, and eleven crypto-asset businesses from 23 August 2026. Recital 21 characterises the additions across those annexes as four financial entities and 14 crypto-asset service providers.

Of direct relevance to oil trading, Part C of Annex XLV – third-country entities significantly frustrating Articles 3m, 3n and 3s – gains five entities from 13 August 2026: Vistula Delta Global FZE, Estrella Integrated FZE, Linglong Trading Group FZE, Arcadia International FZE and Nexus Oil Trading FZCO.

New Article 5bc creates a mechanism to prohibit all transactions with crypto-asset service providers and exchange platforms established in third countries listed in a new Annex LVII, where the Council has identified the country as having systematically and persistently failed to prevent circumvention. No country is currently listed in Annex LVII; the mechanism therefore remains latent. A derogation permits nationals and residents of Member States, EEA States and Switzerland to withdraw funds and close accounts at institutions listed on or after 24 July 2026, provided authorisation is sought within three months of the relevant date of application and the funds move to an EU-incorporated or EU-controlled institution; authorisations last a maximum of three months.

Commodities and divestment

Annex XXI is expanded to prohibit imports of copper, nickel, lead and precious-metal ores and concentrates; zinc and chromium oxides; tall oil; a broad range of glass and glassware; unwrought zinc; and vehicle bodies and parts. Contracts concluded before 24 July 2026, and ancillary contracts, may be performed until 25 October 2026 (Article 3i(3bg)). Divestment and wind-down derogations across Regulation 833/2014 are extended to 31 December 2027.

Full text of Council Regulation (EU) 833/2014 is available via this link.

Please do reach out to Alex Brandt and/or Leigh Hansson if you have any questions on the above.