The EU adopts its 20th sanctions package against Russia

On 23 April 2026, the EU adopted its twentieth sanctions package against Russia in response to Russia’s full-scale invasion of Ukraine. The adoption comes shortly after the four-year anniversary of the full-scale invasion, and after a prolonged political deadlock due to Hungary’s use of its veto. The new measures focus in particular on sanctions circumvention, as well as the energy sector, maritime transport and financial services. The majority of the measures entered into force on 24 April 2026. Norway is expected to implement the twentieth sanctions package into Norwegian law, in line with previous practice. Businesses should therefore already begin assessing the potential implications of the new measures.

Energy and maritime transport

The twentieth sanctions package paves the way for a possible ban on maritime transport services relating to Russian oil and petroleum products, in coordination with the G7 and the so-called Price Cap Coalition. The Council will determine when any ban on such maritime services will enter into force, including what will constitute an appropriate wind-down period.

The provision of services to Russian-flagged icebreakers is prohibited with immediate effect, while the ban on services to Russian LNG tankers entered into force on 25 April 2026. For foreign-owned vessels operating in Russia, the ban applies from 1 January 2027. From the same date, the provision of LNG terminal services to Russian-controlled entities will be prohibited. While 46 new vessels are added to the EU’s shadow fleet list, 11 vessels are simultaneously delisted. In total, the EU’s shadow fleet list now includes 632 vessels. Furthermore, the EU’s transaction ban against the Russian ports of Murmansk and Tuapse, as well as the Karimun Oil Terminal in Indonesia, is expanded. This is the first time the port ban has been extended beyond Russian territory.

The twentieth sanctions package also introduces several specific measures to prevent tankers sold from the EU from ultimately being used for Russian purposes. These include a specific due diligence assessment by EU sellers and the mandatory use of so-called “no Russia” clauses, which must be carried forward in any subsequent sale contracts. The package also introduces a clause on the scrapping of shadow fleet vessels, intended to facilitate the removal of vessels from the shadow fleet and their decommissioning.

Financial measures

The twentieth sanctions package expands the transaction ban to a further 20 Russian banks, bringing the total number of Russian banks excluded from the EU internal market to 70. The transaction ban is also expanded to cover four banks in Kyrgyzstan, Laos and Azerbaijan, while five financial entities in third countries are simultaneously delisted. This latter approach, targeting financial institutions in third countries, represents a relatively new direction in EU sanctions practice, with the Union showing a greater willingness to adopt a more “extraterritorial” approach to sanctions circumvention.

The transaction bans also target non-financial undertakings that facilitate international payments from Russia, for example through set-off arrangements or other alternative settlement mechanisms. The package also introduces a comprehensive sector-wide ban on Russian crypto-asset service providers and platforms. This includes a prohibition on the use of, and support for, the RUBx cryptocurrency and the digital rouble. These instruments are considered to facilitate sanctions circumvention.

Trade measures

The package introduces new export and import restrictions to weaken Russia’s military-industrial base. This includes a number of new export bans, including on rubber, industrial tractors, laboratory glassware and certain chemicals. The package also introduces several import bans on certain raw materials, chemicals and metals. A new annual import quota for ammonia was also introduced.

For the first time, the EU uses its “anti-circumvention tool” by prohibiting exports of computer numerical control (CNC) machine tools and radios to Kyrgyzstan where there is a high risk that the products will be re-exported to Russia. The decision is based on an analysis of trade data showing a significant increase in re-exports of priority goods via Kyrgyzstan to Russia.

Listings

The package introduces new individual listings, including 83 legal persons and 33 natural persons. The package further tightens the pressure on Russia’s military industry through the listing of 58 companies and associated persons considered to be involved in the development of military equipment. Sixteen actors considered to be suppliers of military dual-use goods or weapons systems are from third countries such as China, the United Arab Emirates, Belarus, Uzbekistan and Hong Kong. In addition, 60 entities are added to a separate list of actors supporting Russia’s military and industrial complex, and are therefore subject to specific export restrictions. Of these, 32 are established in Russia and 28 in third countries, including China, Hong Kong, Türkiye, Thailand and the United Arab Emirates. Overall, the listings cover actors with links to Russia’s military industry, as well as, for example, energy companies, oligarchs and persons considered to be involved in the unlawful deportation or transfer of Ukrainian children, propaganda and the looting of cultural heritage.

Protection of EU operators

Russia has introduced a regime for the so-called “temporary administration” of property on Russian territory belonging to foreign persons from designated “unfriendly foreign states”. This typically includes states that have imposed sanctions against Russia. In such cases, the “temporary administration” is often granted to Russian competitors of EU undertakings, giving them a direct economic advantage. The EU considers these “administration regimes” to amount to de facto unlawful expropriation. A similar regime has been introduced by Russia for EU operators’ intellectual property rights. Against this background, the twentieth sanctions package introduces a transaction ban targeting specifically listed Russian competitors considered to benefit from such expropriation-like practices.

The package also empowers courts in EU Member States to fine Russian persons who bring claims considered to be wrongful before Russian courts, as well as a right for EU operators to claim compensation if such claims are enforced in third countries outside Russia. The package also gives the Council the power to impose transaction bans on undertakings and individuals in third countries that contribute to the enforcement of this type of wrongful claim.

Other measures

The package also introduces a prohibition on providing cybersecurity services to Russian persons and entities. It also expands the existing prohibition on receiving funding, including donations and grants, from Russian authorities for private or public entities in the EU engaged in research and innovation.

Furthermore, the package expands the EU’s broadcasting ban by enabling so-called “mirror channels” and online domains that replicate content from already listed propaganda outlets, and thereby circumvent the broadcasting ban, to be shut down more quickly and prohibited from distribution in the EU.