EU Council Adopts 21st Sanctions Package Against Russia 

On July 23, 2026, the Council of the European Union (EU) adopted its highly anticipated 21st sanctions package against Russia. The package introduces a new round of restrictive measures targeting key sectors of Russia’s economy, including the energy, financial services and crypto, trade, and military sectors, while further targeting entities in several non-EU countries for their involvement in the circumvention of EU sanctions and other activities supporting Russia's war effort.

Alongside the Russia measures, the EU has updated the Belarus sanctions regime by aligning it more closely with certain restrictive measures applicable to Russia.

The latest package of EU restrictive measures is set out in nine legal instruments:

• Council Decision (CFSP) 2026/1845;
• Council Decision (CFSP) 2026/1847;
• Council Decision (CFSP) 2026/1849;
• Council Regulation (EU) 2026/1844;
• Council Regulation (EU) 2026/1846;
• Council Regulation (EU) 2026/1848;
• Council Implementing Decision (CFSP) 2026/1816;
• Council Implementing Regulation (EU) 2026/1817;
• Council Implementing Regulation (EU) 2026/1843.

Individual designations

The 21st sanctions package contains the highest number of listings adopted by the EU since 2022. As part of the package, 216 individuals and entities are designated under the EU asset-freeze sanctions against Russia.[1] The new designations include 18 entities and one associated individual operating in the Russian oil sector, as well as six individuals and 35 entities supporting Russia’s military-industrial complex. The EU has also designated three entities based in the United Arab Emirates (UAE), one entity based in Singapore, and one entity based in China. The designation of third-country entities reflects an increasing trend toward targeting actors that facilitate sanctions circumvention or otherwise materially undermine sanctions prohibitions.

In addition, the 21st package includes two new designations under the Belarus sanctions regime.[2] The newly designated entities are European Trading Company LLC and OJSC Mozyr Oil Refinery, two major Belarusian companies operating in the oil trading and refining sectors.

Restrictive measures on the energy sector 

The energy sector is a principal focus of the EU’s 21st sanctions package. Notably, the operation of the crude oil price cap adjustment mechanism introduced under the 18th sanctions package has been suspended for one year.[3] As a result, the price cap for Russian crude oil will remain fixed at USD 44.10 per barrel for the next 12 months. The objective of the suspension is to keep strong downward pressure on Russian crude exports to ensure that Russia does not benefit from the closure of the Strait of Hormuz. In addition, the package introduces an interim review of the suspension to ensure that the mechanism remains necessary and proportionate taking into consideration market developments. From July 15, 2027, the original procedure for reviewing and adjusting the price cap will resume.

A key change is the introduction of a temporary exemption, until July 25, 2027, for transfers of Russian LNG to third countries and purchases related to such transfers. The exemption applies only where the relevant transactions are carried out under contracts concluded before February 24, 2022, with a duration exceeding one year. The relevant contract must not have been amended after 24 February 2022, except for certain limited categories of permitted amendments. In particular, amendments increasing contracted volumes would not be permitted. The exemption is also subject to an annual volume cap based on the historical volume of Russian LNG transferred in 2025 under the relevant contract(s), irrespective of the destination of those 2025 transfers. The reporting obligations include notifying the competent national authority of the relevant historical 2025 volumes by August 25, 2026, as well as providing transaction-specific information every three months.

The package also introduces a prohibition on engaging in any transaction with listed refineries in Russia and in third countries that process or refine Russian-origin crude oil, process or blend Russian-origin petroleum products, or facilitate or engage in the violation or circumvention, or otherwise significantly frustrate the provisions of Regulations (EU) 833/2014, 269/2014, 692/2014, or 2022/263.[4]  The only designated refinery for now is Georgia's Kulevi Oil Refinery, which is subject to a transaction ban effective from January 25, 2027, following a six-month transitional period intended to enable the refinery to diversify away from Russian crude oil inputs.

The 21st package includes new compliance obligations relating to the sale of LNG tanker vessels. In particular, it imposes a notification obligation for any sale or transfer of ownership of any LNG tanker vessel by EU persons to any third country, enabling the EU to monitor transactions that could facilitate the transport of Russian LNG.[5]  Following a Commission assessment due by October 25, 2026, the Council will decide whether to introduce a full ban on LNG tanker sales to any person in Russia or for use in Russia. 

Further key changes include:

• The listing of 41 additional shadow fleet vessels that are subject to a port access ban and a prohibition on receiving financing or financial assistance and technical assistance and other services, bringing the total number of listed vessels to 673.

• The criteria for vessel listings have been expanded to target, for the first time, vessels that provide services such as bunkering and tug services to designated vessels, as well as vessels that carry out ship-to-ship transfers with designated vessels.[6]
• The designation of entities involved in the Russian oil and shipping sectors, including major Russian energy supplier Inter RAO UES; three Russian oil refineries (the Anzhersky, Kuibyshevsky and Novokuibyshevsky refineries); five oil trading companies; and five UAE-based entities identified as significantly frustrating prohibitions relating to Russian crude oil and petroleum products.[7]
• Extension until March 31, 2028, of the exemption from the oil price cap allowing the transport by vessel of crude oil originating from the Sakhalin‑2 project in Russia to Japan, as well as related technical assistance, brokering services, financing, and financial assistance.
• Clarification that the LNG terminal services ban introduced in the 20th sanctions package covers not only persons in Russia and EU persons owned or controlled by a Russian citizen or persons in Russia, but also non-Russian, non-EU persons that are controlled by a Russian citizen or persons in Russia.[8]
• New basis for derogation for transactions in connection with natural gas pipelines Nord Stream and Nord Stream 2, with regard to the completion, operation, maintenance or use of the pipelines, where the transactions are considered strictly necessary.

Restrictions on access to finance and financial services 

To further strengthen restrictions on Russia's financial sector and disrupt payment, banking, and crypto-asset channels used to support Russia’s war economy and circumvent EU sanctions, the 21st sanctions package introduces the following measures:

• As from August 25, 2026, the prohibition on Russian nationals and residents owning, controlling, or holding positions in the governing bodies of EU crypto-asset service providers will apply to all crypto-asset service providers regulated under the EU’s Regulation 2023/1114 on markets in crypto-assets (MiCAR).[9]
• Introduction of the possibility to prohibit all transactions with entities providing crypto-asset services, or operating platforms enabling the exchange or transfer of crypto-assets, that are established in designated third countries.[10] Although no third countries are currently listed under the ban, the new provision acts as a deterrent and prompts third countries to take action to prevent their jurisdiction from being used for circumvention via crypto.
• Listing of numerous financial institutions and entities providing crypto-asset services, which are subject to a full transaction ban, including: 33 Russian banks;[11] three third-country banks based in India and Mongolia; 14 crypto-asset service providers based in Belarus, Georgia, Kyrgyzstan, the UAE, the Marshall Islands, Panama, and Nigeria that significantly frustrate sanctions;[12] and one third-country bank established in Kyrgyzstan, as a result of its connection to the Russian System for Transfer of Financial Messages (SPFS).[13]
• Designation under asset-freeze sanctions of the Moscow Exchange (PJSC Moscow Exchange MICEX‑RTS or MOEX) and PJSC Bank Derzhava, a major market maker for Russian government debt on the Moscow Exchange. The designation of MOEX aligns the EU sanctions regime with measures already adopted by other partners, including the United States and the United Kingdom.
• Removal of a third-country bank established in Azerbaijan from the list of entities subject to a transaction ban.[14] The delisting is evidence that the EU sanctions policy aims at triggering a behavioral change in third countries to align with EU measures. When such a change occurs, the Council can unanimously remove a designation.

The EU also introduced a derogation allowing competent authorities of Member States to authorize EU, EEA, and Swiss nationals and residents to withdraw funds or close accounts held with credit and financial institutions, or entities providing crypto-asset services or payment services newly added to Annexes XLIV, XLV, and XIV, where strictly necessary to terminate existing operations, contracts, or other arrangements with those entities.[15] The authorization must be requested no later than three months after the application date indicated in the respective Annex for the relevant legal person. The authorization is valid for a maximum of three months.

Trade restrictions

 The new sanctions package introduces a number of additional trade restrictions targeting Russia, including the following measures:

• The list of items, which are subject to export restrictions due to their ability to contribute to Russia’s military and technological enhancement or to the development of its defense and security sector, has been expanded to include nickel powders, nickel metals and nickel alloys used in corrosion-resistant coatings for jet engines; beryllium powders used in propellants and in high-performance alloys; self-adhesive films, tapes and strips used in the aerospace and defense sectors; aviation items specific to unmanned aerial vehicles (UAVs), such as ground support equipment, jamming and interception systems, launch systems and servomotors; and flight termination systems for UAVs or missiles.[16]
• Extension of import restrictions to additional goods which generate significant revenues for Russia, such as copper ores, nickel ores, lead ores, precious-metal ores, unwrought zinc, alkaline-earth metals, zinc oxides and chromium oxides, tall oil, glassware and car parts.[17] These new restrictions further reflect the EU’s broader policy objective of limiting trade in metals originating in Russia.
• Listing 51 new entities, which are part of or support Russia's military-industrial complex or enable the circumvention of EU sanctions. This includes 24 entities established in Russia and 27 in third countries, 14 in China (including 4 in Hong Kong), 4 in Türkiye, 3 in Kyrgyzstan, 2 in India, 2 in Kazakhstan, and 2 in the United Arab Emirates.  Tighter export restrictions apply to these entities.[18]

Additional restrictive measures and other amendments

The 21st sanctions package introduces several restrictive measures and targeted amendments, including:

• The imposition of a transaction ban on two Russian ports (Port of Olya and Port of Vysotsk) and four Russian airports used for the transfer of UAVs, missiles, goods and technology used in the defense and security sector, or the maritime transport of Russian crude oil and petroleum products.
• Listing of 7 major actors in the gold sector, a leading diamond company, as well as several entities active in the mining and metallurgy sector.
• Clarification of the scope of the prohibition on the provision of services directly related to tourism activities in Russia by expressly excluding computerized reservation system services from its application.[19]
• Introduction of visa restrictions targeting Russian combatants, under which Member States will be required, once the measure enters into force, to refuse short-stay visas to individuals who have served since February 2022 in the Russian Armed Forces or affiliated armed groups and have directly contributed to combat operations in Ukraine.[20]
• Introduction of derogations under the EU asset freeze sanctions against Russia allowing, under specific conditions:
• • The release of frozen funds or economic resources to facilitate insurance-related indemnity payments owed by certain listed persons or entities to recipients established in the EU, EEA, Switzerland, or specified partner countries.[21]
  • The exercise by an EU credit institution of a put option contractually agreed and duly exercised before February 28, 2022, including the release of frozen funds and the transfer of shares strictly necessary to satisfy the resulting payment obligations.
• Introduction of targeted exemptions from the EU asset-freeze measures applicable to:

• • JSC Russian Railways, permitting the use and making available of funds and economic resources strictly necessary for the provision of rail transport services and related railway infrastructure between Russia and the EU.
  • Three Russian entities involved in the Paks II nuclear project in Hungary, permitting the use and making available of funds and economic resources strictly necessary for the establishment, operation, maintenance, fuel supply, fuel retreatment, safety, design, construction, commissioning, and completion of the project’s civil nuclear facilities, subject to notification requirements.
• Reinforced legal safeguards for EU operators, particularly in response to Russian countermeasures and related judicial proceedings:
  • Extension of the right to recover direct and indirect damages before Member States’ courts to claims brought by non-Russian and non-Belarusian persons and entities in third countries for having suspended or terminated their contracts to comply with sanctions, as well as related judicial decisions rendered in those countries.[22]
  • EU Member States are prevented from recognizing, giving effect to, or enforcing any Russian court or administrative decision relating to a contract or transaction affected by EU sanctions where that decision imposes liability on an EU operator or gives effect to claims, rights, or alleged obligations against it.[23]
  • EU operators are also entitled to obtain court orders from Member State courts requiring counterparties to discontinue sanctions-related proceedings before Russian courts and to refrain from seeking the enforcement, recognition, or reliance on any resulting Russian judgment in any jurisdiction, including non-EU countries (“anti-enforcement injunctions”).[24]
• Lastly, the package extends until December 31, 2027, a number of derogations supporting divestment from Russia and the wind-down of Russia-related business activities, including in relation to joint ventures, certain claims, restricted goods and technologies, and specified services.

Impact on business

EU operators should assess the impact of the 21st sanctions package on their business activities, including any newly introduced exemptions and derogations.

EU operators should also assess the increased risk of transacting with the financial, energy, or metals and mining sector, and carefully review their supply chain and involvement of third country entities connected to Russia as the EU is increasingly willing to designate such entities.

The EU’s continued listing of third-country entities and service providers highlights the need for more robust due diligence on the broader network of parties involved in Russia-related or high-risk transactions, including intermediaries, traders, banks, logistics providers, vessel operators, refineries, and crypto-asset platforms that may have Russian links or may be used to facilitate circumvention. When affected by listings, companies should also review existing arrangements to determine whether any exemptions, derogations, transitional periods, or deferred application dates are available, and should develop contingency plans and alternative supply-chain options where key counterparties, routes, or inputs may be affected.

The 21st sanctions package also strengthens the legal protections available to EU operators, providing businesses with additional tools to mitigate the impact of Russian countermeasures, protect their contractual rights, and manage the legal and financial risks arising from sanctions-related disputes. These new measures expand the extraterritorial reach of prior EU measures by allowing EU operators to bring claims before EU courts against non-Russian counterparties that pursue proceedings outside the EU in response to the suspension or termination of contracts for sanctions-compliance reasons. They also empower EU courts to issue “anti-enforcement injunctions” aimed at preventing the recognition or enforcement of such claims in non-EU jurisdictions and require Member States to refuse recognition or enforcement of certain Russian court decisions.

[1] Annex to Council Implementing Regulation (EU) 2026/1843.

[2] Annex to Council Implementing Regulation (EU) 2026/1817.

[3] Article 3n of Regulation (EU) 833/2014.

[4] Article 5ae of Regulation (EU) 833/2014.

[5] Article 3qa of Regulation (EU) 833/2014.

[6] Article 3s of Regulation (EU) 833/2014.

[7] Part C of Annex XLV of Regulation (EU) 833/2014.

[8] Article 3rb of Regulation (EU) 833/2014.

[9] Article 5b of Regulation (EU) 833/2014

[10] Article 5bc of Regulation (EU) 833/2014

[11] Annex XIV to Regulation (EU) 833/2014.

[12] Part A of Annex XLV to Regulation (EU) 833/2014.

[13] Annex XLIV to Regulation (EU) 833/2014.

[14] Annex XLV to Regulation (EU) 833/2014.

[15] Articles 5ac, 5ad and 5h to Regulation (EU) 833/2014.

[16] Annex VII to Regulation (EU) 833/2014. 

[17] Annex XXI to Regulation (EU) 833/2014. 

[18] Annex IV to Regulation (EU) 833/2014. 

[19] Article 5f of Regulation (EU) 833/2014.

[20] Article 5f of Council Decision (CFSP) 2026/1849.

[21] Article 6b Regulation (EU) 269/2014.

[22] Article 11a of Regulation (EU) 833/2014 and Regulation (EU) 269/2014, and Article 8h of Regulation 765/2006.

[23] Article 11c of Regulation (EU) 833/2014 and Regulation (EU) 269/2014.

[24] Article 11ca of Regulation (EU) 833/2014.