EU Adopts 20th Package Against Russia & Parallel Sanctions on Belarus

Initially proposed by the European Commission (“Commission”) on February 6, 2026, the European Union finally adopted its 20^th package of sanctions targeting Russia, along with parallel amendments to sanctions against Belarus, on April 23, 2026. This package, designed to ramp up pressure on the energy, finance, and military-industrial sectors, target both Russia and those which help Russia evade sanctions. Illustrating the anti-circumvention focus of this package, the EU has, for the first time, extended certain trade restrictions to Kyrgyzstan.

New asset freeze measures were imposed through Decision 2026/504 and Regulation 2026/509 under the main asset freeze regime targeting Russia (Decision 2014/145 and Regulation 269/2014) and through Decision 2026/503 and Regulation 2026/505 under the Belarus sanctions regime (Decision 2012/642 and Regulation 765/2006). In addition, Decision 2026/504 and Regulation 2026/511 amended the asset freeze measures framework under the main asset freeze regime targeting Russia. These provisions entered into force on April 23, 2026.

Amendments to sectoral sanctions targeting Russia (Decision 2015/512 and Regulation 833/2014) and Belarus (Decision 2012/642 and Regulation 765/2006) were made through, respectively, Decision 2026/508 and Regulation 2026/506 and Decision 2026/512 and Regulation 2026/513, which entered into force on April 24, 2026.

1. Asset Freeze Measures

New Designations (Russia & Belarus): The European Union imposed travel ban and/or asset freeze measures against 37 individuals and 83 legal persons, entities, or bodies (collectively, “entities”). Designations target primarily the energy sector and shadow fleet ecosystem, the military-industrial complex, third-country providers of critical high-tech items as well as persons or entities involved in the deportation of Ukrainian children, Russian propaganda, and the looting of Ukrainian cultural heritage. Consistent with the European Union’s strengthened extraterritorial reach, 17 entities located in China, the United Arab Emirates, Uzbekistan, Kazakhstan and Belarus have been designated.

Amendments to the Asset Freeze Framework under Regulation 269/2014 (Russia):

• Extending the ground for designation targeting the Russian shadow fleet, to target not only vessels that transport Russian oil, but also those transporting Russian mineral products.
• Introducing new derogations, notably to (i) permit certain insurance payments by a newly listed Russian insurer; (ii) disincentivize arbitration by asset-freeze targets; and (iii) permit time-limited transactions with Nayara Energy where strictly necessary to reduce Russian crude oil dependency.

2. Other List-Based Sanctions (Russia)

Using List-Based Sanctions Frameworks to Further Isolate Russia and Target third-country Operators that Support It:

• EU “Entity List”: 60 entities added to the list of parties subject to enhanced export-related restrictions on dual-use and advanced technology items (Article 2b and Annex IV of Regulation 833/2014), including 28 in China, Hong Kong, Thailand, Turkey and the United Arab Emirates.
• Designated vessels: 46 vessels designated as subject to an EU port ban and ban on a broad range of activities and services (Article 3s and Annex XLII of Regulation 833/2014).
• Transaction bans: 20 Russian banks, one bank in Azerbaijan, one bank in Laos, three banks in Kyrgyzstan, and four “payment agents” are subject, effective May 14, 2026, to transaction bans based on different frameworks (including an extended framework to target payment agents; i.e., intermediaries that help Russia frustrate sanctions by facilitating cross-border payments).¹
• Infrastructure transaction ban: Two ports in Russia (Murmansk and Tuapse) and one port in Indonesia (Karimun) have been designated, with effect from April 24, 2026.

De-listing Parties that Stopped Engaging in Illicit Activities: Five banks in China and Tajikistan and 11 vessels have been de-listed.

Introducing Catch-All Broadcasting Bans: list-based broadcasting bans have been extended to cover any online content of mirror entities.

3. Export-Related Restrictions (Russia & Belarus)

Extended lists of controlled items

• Advanced technology items (Articles 2a and 2b and Annex VII of Regulation 833/2014 & Article 1f and Annex Va of Regulation 765/2006), to include (i) laboratory glassware; (ii) certain high-performance lubricants and their additives; and (iii) energetic materials.
• Industrial items (Article 3k and Annex XXIII of Regulation 833/2014 & Article 1bb and Annex XVIII of Regulation 765/2006), to include (i) chemicals used in the production of lubricant additives and solvents; (ii) rubber and articles of vulcanized rubber; (iii) screws, bolts and nuts of steel; (iv) tools for metal production; and (v) industrial tractors.²

Preventing Diversion of Tankers to Russia through Extended Due Diligence Requirements for Sales to Third Countries (Article 3q of Regulation 833/2014): Sales of oil tankers to Russia were already prohibited, while sales to third countries were subject to mandatory notifications. Going further, the 20^th package requires EU operators to also (i) conduct mandatory due diligence, and (ii) insert contractual clauses to prevent diversion to Russia.

Activating, for the First Time, the Anti-Circumvention Mechanism to Impose Export-Related Restrictions against Kyrgyzstan (Article 12f and Annex XXIII of Regulation 833/2014): To address systematic and persistent circumvention, Kyrgyzstan is now subject to the same export-related restrictions as Russia for certain metal-cutting machines and telecommunications equipment.

Housekeeping Changes (Russia): Adjustments have been made to the lists of controlled (i) oil and gas exploration goods (moved from Annex II to Article 3k of Regulation 833/2014), and (ii) luxury goods (with deletion in Annex XVIII of duplicates contained in Annex XXIII of Regulation 833/2014).

Adjusting Exemptions & Derogations: A new exemption from the arms embargo permits the military forensic analysis of Russian-origin items recovered from Ukraine (Article 4 of Regulation 833/2014), while the dual-use and advanced technology derogation for cybersecurity and information security is now limited to Russian entities that are owned or controlled (solely or jointly) by an EU-incorporated company (Articles 2 and 2a of Regulation 833/2014).

4. Import-Related Restrictions (Russia & Belarus)

Extended list of controlled revenue generating items (Article 3i and Annex XXI of Regulation 833/2014 & Article 1ra and Annex XXVII of Regulation 765/2006), to include (i) raw materials; (ii) metals such as iron ore, copper and processed aluminum goods; (iii) certain minerals such as silicon, salts, quicklime; (iv) scrap of steel, aluminum, copper, nickel, iron ore slag; (v) chemicals; (vi) articles of vulcanized rubber; (vii) tanned fur skins; and (viii) ammonia.³

Extension of Russian crude oil and petroleum products restrictions to natural gas condensates (Articles 3m and 3n and Annex XXV of Regulation 833/2014), with effect from 1 January 2027.

Extended list of partner countries for importation of petroleum products, for which imports of petroleum products do not require proof of origin of the crude oil used for refining (Article 3ma and Annex LI of Regulation 833/2014), to include Liechtenstein.

Paving the way to replace the oil price cap with a full Russian oil maritime services ban (Article 3m of Regulation 833/2014), with a decision postponed for coordination at G7 level.

Reinforced traceability evidence for imports of polished diamonds into the EU (Article 3p and Annex XXXVIIIB of Regulation 833/2014), by requiring due-diligence statements (instead of certificates) to confirm that polished diamonds are not mined, processed, or produced in Russia.

5. Energy-Related Services Restrictions (Russia)

Prohibiting LNG terminal services as of January 1, 2027 (new Article 3rb of Regulation 833/2014), effectively requiring to terminate contracts with Russian counterparties and EU entities they own for more than 50%.

Prohibiting services related to icebreakers and LNG tankers linked to, operating or for use in Russia (new Article 3sa of Regulation 833/2014), with immediate entry into force in most cases, but postponed to January 1, 2027 for LNG tankers operating or for use in Russia, which are not Russia-flagged, certified by the Russian Maritime Register of Shipping, or owned/managed by any Russian individual or entity.⁴

6. Other Services Restrictions (Russia & Belarus)

Inclusion of managed security services (i.e., cybersecurity services) in the list of restricted professional services (Article 5n of Regulation 833/2014 & Article 1jc of Regulation 765/2006): The provision of these services to (i) the Government of Russia or entities established in Russia, and (ii) the Republic of Belarus, its government, its public bodies, corporations, or agencies is now prohibited.

Introducing restrictions on services directly related to tourism activities in Belarus (Article 1jc of Regulation 765/2006), thereby aligning with sanctions targeting Russia.

Introducing new exemptions from catch-all controls on the provision of services to the Russian and Belarusian governments, to permit the provision of services necessary for the functioning of their consular or diplomatic representations.

7. Financial Restrictions (Russia & Belarus)

Reinforcing crypto-related sanctions:

• Extending transaction bans against crypto-assets to also target central bank digital currencies (Article 5ba and Annex LIII of Regulation 833/2014 & new Article 1ze and Annex XXXIV of Regulation 765/2006), with the listing of RUBx, the Russian Digital Ruble and the Belarusian Digital Ruble, effective May 24, 2026.
• Prohibiting transactions with Russian and Belarusian crypto-asset services providers and platforms (new Article 5bb of Regulation 833/2014 & new Article 1zf of Regulation 765/2006) effective May 24, 2026.

Prohibiting funding by the Russian government in the research and innovation sector (Article 5t of Regulation 833/2014).

8. Reporting Obligations (Russia)

Clarification through recitals that EU operators must report to national authorities information on circumvention and suspicious transactions (Recital (23) of Regulation 2026/506).

Requiring EU operators to notify national authorities if their IP rights or trade secrets are unlawfully used in Russia (new Article 5sa of Regulation 833/2014), as a result of Russian countermeasures entitling IP rights and trade secrets of EU-owned Russian subsidiaries to be used without their right holder’s consent.

9. Measures to Protect EU Operators (Russia & Belarus)

The carrot before the stick: The European Union introduced new transaction ban framework, which would entitle it to retaliate against actions that prejudice EU operators, but has not yet made any designations under these frameworks. Potential targets consist of:

• Entities that benefit from Russian “temporary management” or expropriation decisions (new Article 5ai and Annex LIV of Regulation 833/2014);
• Individuals or entities that seek to enforce, outside the European Union, third-country judgements relating to sanctions-affected contracts or Russian countermeasures (new Article 5aj and Annex LV of Regulation 833/2014 & new Article 1zd and Annex XXXIII of Regulation 765/2006).
• Entities that use, pursuant to Russian countermeasures, IP rights, or trade secrets without the consent of the right holder (new Article 5sa and Annex LVI of Regulation 833/2014).

Preventing non-EU parties’ claims in the European Union for sanctions-affected contracts, by extending the scope of “no claims” clauses (Article 11 of Regulation 269/2014, Article 11 of Regulation 833/2014 and Article 8d of Regulation 765/2006).

Extending the possibilities for EU operators to recover damages, in connection with attempts to enforce judgments relating to sanctions-affected contracts or Russian countermeasures in non-EU courts outside Russia (Article 11a of Regulation 269/2014, Articles 11a and 11b of Regulation 833/2014 & Article 8h of Regulation 765/2006).

Introducing anti-suit injunction mechanisms, to prevent disputes being brought in Russia in breach of jurisdictional rules or based on Russian procedural countermeasures (new Article 11ca of Regulation 833/2014).