European Union Adopts 21st Package against Russia & Parallel Sanctions on Belarus

Initially proposed by the European Commission (“Commission”) on June 9, 2026, the European Union finally adopted its 21st package of sanctions targeting Russia, along with parallel amendments to sanctions against Belarus, on July 23, 2026. This package, designed to ramp up pressure on the finance, energy and military industrial sectors, targets both Russia and those who help Russia evade sanctions.

This latest package targets Russia's finance, energy, crypto, and military-industrial sectors through expanded individual designations and tighter trade controls (including freezing the oil price cap and new measures related to liquefied natural gas (“LNG”)). It also closes loopholes in energy and crypto-asset services and reinforces the “carrot-and-stick” approach to discourage third parties from helping Russia evade sanctions.

New asset-freeze measures were imposed through Decision 2026/1845 and Regulation 2026/1843 under the main asset-freeze regime targeting Russia (Decision 2014/145 and Regulation 269/2014) and through Decision 2026/1816 and Regulation 2026/1817 under the Belarus sanctions regime (Decision 2012/642 and Regulation 765/2006). In addition, Decision 2026/1845 and Regulation 2026/1844 amended the asset-freeze measures framework under the main asset-freeze regime targeting Russia. These provisions entered into force on July 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 2026/1849 and Regulation 2026/1848 and Decision 2026/1847 and Regulation 2026/1846, which entered into force on July 24, 2026.

1.  Asset-Freeze Measures

New designations (Russia & Belarus): The European Union imposed travel bans and/or asset freezes against 48 individuals and 170 entities. Designations target primarily the financial and crypto sectors, the Russian military-industrial complex, the energy sector and shadow fleet ecosystem, the gold and diamond sectors, the mining and metallurgy sectors, Russia’s critical infrastructure, war propaganda, and individuals responsible for war crimes. The bulk of these designations consists of 94 Russian banks and financial institutions. Six entities in China, Oman, India, Singapore, and the United Arab Emirates were also sanctioned for trading in Russian oil and petroleum products or supporting shadow fleet vessels.

On July 13, 2026, the European Union had already designated 28 individuals and 10 entities under four different Russia-related regimes: (i) cyber-attacks under the EU cyber-attack regime; (ii) destabilizing activities under the Russian hybrid threat regime; (iii) human rights violations against Ukrainian prisoners of war under the EU Global Human Rights Sanctions regime ; and (iv) abusive surveillance under the Russia-specific human rights regime.

Amendments to the asset-freeze framework under Regulation 269/2014 (Russia):

• Introducing new derogations, to allow (i) (insurance) payments for risks for which shadow fleet-related asset-freeze targets are liable, (ii) the exercise by an unidentified EU credit institution of a put option contractually agreed and exercised prior to February 28, 2022 under certain conditions, and (iii) transactions with specific asset-freeze targets related to the Paks II project in Hungary.
• Introducing a new exemption for Russian Railways, despite its non-designation, to ensure that asset-freeze measures do not impact transactions necessary for (i) rail transport of goods or persons by Russian Railways between Russia and the Union, in transit through the Union, between the Kaliningrad Oblast and Russia, or within Russia, including related railway infrastructure, and (ii) services related to the operation, maintenance, or security of such rail transport.

However, it is not Russian Railways but its Director General who has been designated. While the exemption suggests that Russian Railways should be treated as an asset-freeze target, recitals indicate that it “is without prejudice to the case-by-case assessment of control of designated persons over non-designated entities.”

2.  Other List-Based Sanctions (Russia & Belarus)

Using list-based sanctions frameworks to further isolate Russia and target third-country operators that support it:

• European Union’s “Entity List”: 55 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 and Article 1fa and Annex V of Regulation 765/2006), including 27 in China, Hong Kong, India, Kazakhstan, Kyrgyzstan, Türkiye, and the United Arab Emirates.
• Designated vessels: 41 vessels added to the list of designated vessels 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). Furthermore, grounds for designation of vessels have been extended to cover those that (i) provide services to designated vessels, such as bunkering services or tug services or (ii) carry out ship-to-ship transfers with designated vessels.
• Transaction bans: Effective August 13, 2026, transaction bans apply to 33 Russian banks, one bank in Kyrgyzstan, six banks in Mongolia, India, and Nigeria, and five oil traders in the United Arab Emirates. 11 crypto-asset service providers have also been targeted, with their ban effective August 23, 2026.¹
• Infrastructure transaction ban: In Russia, two ports (Olya and Vysotsk) and four airports (Sheremetyevo, Ulyanovsk-Vostochny, Rostov-on-Don Platov and Mineralnye Vody Airport) have been designated, with effect from July 24, 2026.

Grounds for designation have been extended to target certain refineries in Russia and other non-EU countries used to process, refine or blend Russian crude oil, petroleum products and mineral products, or otherwise circumvent or frustrate EU sanctions against Russia. On that basis, the Kulevi Oil Refinery in Georgia will be subject to a transaction ban in six months, effective January 25, 2027, unless it diversifies away from Russian crude oil.

De-listing parties that stopped engaging in illicit activities: Yelo Bank in Azerbaijan has been de-listed.

3.  Export-Related Restrictions (Russia & Belarus)

Extended lists of controlled 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) nickel powders, nickel metal, and alloys of nickel used in corrosion-resistant coatings in jet engines; (ii) beryllium powders used in propellants and high-performance alloys; (iii) self-adhesive films, tapes, and strips used in the aerospace and defense sectors; (iv) aviation items specific to unmanned aerial vehicles (UAVs), such as ground support equipment, jamming/interception systems, launch systems, and servomotors; and (v) flight termination systems for UAVs or missiles.

New notification requirements for transfers of ownership of LNG tanker vessels (Article 3qa of Regulation 833/2014 and CN code ex 8901 20): Arrangements by EU nationals, residents or entities to transfer the ownership of LNG tanker vessels to any third country must be notified to competent Member State authorities. Whether further restrictions, aligned with those applicable to oil tankers, need to be imposed will be assessed after October 2026.

Adjustments to derogations: Derogations related to civilian electronic communication networks (Articles 2, 2a and 3k of Regulation 833/2014 & Articles 1bb, 1e, 1f and 1s of Regulation 765/2006) have been extended to no longer require such networks to be “non-publicly available”, while the derogation for personal household use of natural persons in Russia (Article 3k and Annex XXIII of Regulation 833/2014) now covers CN code 8414 51 (certain fans).

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 cover: (i) copper ores, nickel ores, lead ores, precious-metals ores; (ii) unwrought zinc, alkaline-earth metals, certain inorganic chemicals (zinc oxides and chromium oxides); (iii) tall oil; (iv) glassware; and (v) car parts. A wind-down exemption has been introduced allowing, for all newly listed CN codes, the execution of contracts concluded before July 24, 2026 until October 25, 2026.²

Freezing of the oil price cap (Article 3n and Annexes XXV and XXVIII of Regulation 833/2014): The cap, under which EU operators can deal with Russian crude oil and petroleum products destined to third countries, will be frozen until July 14, 2027 (unless specifically amended).

New derogations and extended exemption related to Russian crude oil and petroleum products:

• New derogation to permit, subject to conditions, transactions related to seized or confiscated Russian crude oil and petroleum products, and their placement under temporary storage or free-zone procedure (Articles 3m and Annex XXV, and Article 3nb of Regulation 833/2014).
• New derogation to forego the requirement to prove the origin of crude oil used to refine petroleum products for certain imports into EU(-associated) outermost regions and overseas countries or territories (Article 3ma of Regulation 833/2014 and CN code 2710).
• Extended exemption to transport of Russian crude oil originating in the Sakhalin-2 project to Japan until March 31, 2028 (Article 3n of Regulation 833/2014 & Annex XXIX).

New exemptions from the prohibition to transport / transfer Russian LNG to third countries:

• New exemption to transport Russian LNG products originating in the Sakhalin-2 project to Japan and South Korea until March 31, 2028 (Article 3ra and Annex XXIX, Part B); and
• New exemption to transfer, and where relevant purchases, Russian LNG destined for third countries under long-term contracts concluded before February 24, 2022, subject to notification requirements and within a cap corresponding to yearly 2025 volumes (Article 3ra of Regulation 833/2014). 

Extension of Hungary-specific exemption for purchases or imports of Russian and Belarusian saturated acyclic hydrocarbons (Article 3i of Regulation 833/2014 & Article 1ra of Regulation 765/2006 and CN code 2901 10), until December 31, 2026 instead of July 25, 2026.

5.  Services Restrictions (Russia)

Extension of prohibition on LNG terminal services to non-EU entities owned or controlled by Russian citizens or entities as of January 1, 2027 (Article 3rb of Regulation 833/2014): Effective January 1, 2027, the prohibition on providing LNG terminal services will apply not only to (i) Russian individuals or entities, and (ii) EU entities more than 50% owned by Russian citizens or entities, but also to (iii) non-EU entities owned or controlled by Russian citizens or entities.

Limitation of the scope of “services directly related to tourism activities in Russia” (Article 5n of Regulation 833/2014): The provision of “computerized reservation system” is now expressly excluded.

6.  Crypto-Related Restrictions (Russia & Belarus)

Reinforcing crypto-related sanctions:

• Prohibition for Russian and Belarusian citizens and residents to own, control or hold posts in EU crypto-asset services providers (Article 5b of Regulation 833/2014 & Article 1u of Regulation 765/2006): as from August 25, 2026, the prohibition will no longer be limited to EU entities providing crypto-asset wallet, account or custody services, but will cover all crypto-asset service providers under MiCA.
• New framework to threaten transaction bans against crypto-asset service providers and crypto platforms in specified third countries that help Russia evade sanctions (new Article 5bc and Annex LVII of Regulation 833/2014): to date, no third country has been targeted.

7.  Facilitating Exits From Russia

Several exemptions and derogations have been extended until December 31, 2027, while EU operators are warned to “take any possible steps to wind down businesses in Russia and not to start new businesses there”:

• Exemptions and derogations under the State-owned entities transaction ban framework to wind-down joint ventures and divest from EU entities (Article 5aa and Annex XXIX of Regulation 833/2014).
• Derogations authorizing the satisfaction of claims under Russia sectoral sanctions, where needed to divest from Russia or wind-down business activities in Russia (Article 11 of Regulation 833/2014).
• Derogations for transactions covered by export- or import-related restrictions, as well as professional services restrictions necessary to divest from Russia or wind-down business activities in Russia (Article 12b of Regulation 833/2014).

8.  Reinforcing the Protection of EU Operators (Russia & Belarus)

A number of measures have been reinforced to take account of the fact that claims connected with sanctions-affected contracts are increasingly brought or enforced in non-EU jurisdictions:

• Extension of damages recovery to entitle EU operators to sue non-Russian or non-Belarusian counterparties (Article 11a of Regulation 269/2014, Article 11a of Regulation 833/2014 & Article 8h of Regulation 765/2006).
• Non-recognition of Russian decisions in sanctions-affected disputes (new Article 11c of Regulation 269/2014 and amended Article 11c of Regulation 833/2014).
• Reinforced anti-suit injunction mechanism, to deter the enforcement in non-EU countries of sanctions-related Russian judgments (Article 11ca of Regulation 833/2014).

9.  Miscellaneous

New framework to impose visa restrictions on Russian combatants (Article 5f of Decision 2026/1849): The framework, which is not yet applicable, would require Member States to refuse short-stay visas for applicants who served, since February 24, 2022, in active duty in the Russian Armed Forces or associated groups, where they have directly contributed to combat operations in Ukraine.

New derogation from Russian government funding restrictions (Article 5t of Regulation 833/2014): Authorisations can be obtained in connection with the acceptance of certain donations, economic benefits or supports from the Government of the Russian Federation under specific projects.

Notification requirements in case of breaches of Russian diplomats visa restrictions (Article 5v of Regulation 833/2014): Member States must inform the Council, Iceland, Liechtenstein, Norway and Switzerland of any breach.

Alignment of exemption from prohibition to sell certain transferable securities to Belarusian nationals, residents or entities (Article 1y of Regulation 765/2006): The prohibition no longer applies to dual-citizens or residents of the EEA and Switzerland, in addition to the European Union.

Housekeeping changes: A number of prior contract derogations or exemptions that have since expired have been removed.

¹ Measures can extend to affiliates of designated parties and a new limited exemption has been introduced.

² Conversely, tanned or dressed furskins of sable (Martes zibellina) under CN code 4302 have been excluded from the list of controlled items under Annex XXI of Regulation 833/2014. Other furskins falling under CN code 4302 remain, however, covered.