This content was last updated on 24 April 2026
Since 23 February 2022, the EU has progressively imposed sanctions against Russia in response to Russia’s violation of Ukraine’s sovereignty and territorial integrity. Below we provide an overview of the twentieth sanction package against Russia.
On 23 April 2026, the Council of the European Union adopted the twentieth package of restrictive measures against Russia in response to its continued war of aggression against Ukraine. This package introduces a comprehensive and enforcement-focused set of measures, with a clear emphasis on cutting Russian energy revenues, disrupting logistical and financial circumvention structures including crypto assets, and increasing pressure on actors in third countries enabling the Russian war economy.
Cutting Russian oil revenues and shadow fleet operations
The package introduces additional measures aimed at restricting Russian oil export and related transport infrastructure. Key measures include:
- 36 newly designated energy sector entities, covering exploration, extraction, refining and transportation of oil.
- 46 additional shadow fleet vessels listed, now subject to EU port access bans and broad prohibitions on maritime service such as insurance, financing and brokering.
- Transaction bans relating to the Russian ports of Murmansk and Tuapse, and the Karimun Oil Terminal in Indonesia, listed as a third-country port facilitating circumvention.
- Safeguards on tanker sales, including:
- Enhanced due diligence obligations
- Mandatory contractual “no Russia-clauses”
- A new scrapping clause to enable permanent exit of vessels from the shadow fleet
- A legal basis for a future ban on maritime services for the transport of Russian crude oil and petroleum products, to be activated at a later stage in coordination with the G7.
First use of the EU anti-circumvention instrument
For the first time, the EU has operationalized its anti-circumvention tool. This includes:
- Export bans on specific goods to high-risk third countries, notably:
- Certain machine tools
- Radio communication equipment
- The aim is to prevent indirect exports to Russia via third-country supply chains.
- EU exporters are expected to take increased responsibility for end-use and downstream risk assessments.
Financial sector and crypto restrictions
The twentieth package further isolates Russia from financial markets. Key developments include:
- Additional transaction bans on Russian banks involved in sanctions circumvention.
- A sector-wide prohibition on engaging with Russian crypto asset service providers, closing an important alternative payment channel.
- Listing of financial institutions in third countries that facilitate prohibited transactions involving Russia.
Trade controls and military-industrial targeting
Trade and industrial measures have been expanded to weaken Russia’s military capabilities. These include:
- New listings of entities active in drone production and electronics and materials used for explosives.
- Extended export bans on goods and services critical to the Russian war effort, including cybersecurity services, and certain chemicals, rubber and steel products.
- Additional import restrictions on metals, minerals and chemical products.
- Introduction of a quota regime for ammonia imports.
Listing and accountability measures
The Council adopted 120 new individual and entity listings, the largest listing exercise in almost two years. Targets include:
- Actors connected to the energy sector and military industry.
- Propaganda networks.
- Individuals and entities involved in the unlawful transfer of Ukrainian children and cultural property.
In conclusion
The twentieth sanctions package marks a shift towards tighter enforcement and a stronger focus on circumvention, third-country involvement and non-traditional financial channels such as crypto assets. Companies active in energy, shipping, finance, trade and complex supply chains should reassess their sanctions exposure and compliance frameworks in light of these developments.
For detailed information on the previous 19 packages of restrictive measures against Russia, please see: EU sanctions measures against Russia.
This publication is provided for your convenience and does not constitute legal advice.
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