EU Adopts 21st Package Of Sanctions Against Russia

On 23 July 2026, the European Union adopted its 21st package of restrictive measures against Russia. The package expands restrictions across the financial, energy, trade and military sectors while introducing new anti-circumvention measures aimed at limiting Russia’s ability to finance and sustain the war in Ukraine.

The package also contains the largest number of new listings in four years, adding 218 individuals and entities to the EU sanctions list, including banks, crypto platforms, military suppliers, energy companies and entities connected with Russia’s shadow fleet.

The 21st sanctions package introduces the following key measures:

Financial Services and Crypto Measures

One of the most significant aspects of the package is the expansion of restrictions affecting Russia’s financial sector.

The EU has imposed asset freezes on 94 banks and major financial institutions and extended transaction prohibitions to additional Russian credit institutions. Measures have also been introduced against several non-Russian financial institutions considered to be facilitating sanctions circumvention.

The package also considerably strengthens restrictions relating to crypto-assets by:

• extending transaction prohibitions to additional crypto platforms;
• introducing the possibility of imposing a full third-country ban on crypto-asset service providers facilitating sanctions evasion;
• extending restrictions on Russian nationals owning, controlling or serving on the boards of crypto-asset service providers; and
• targeting the A7 cross-border payment network used to facilitate sanctions circumvention.

These developments demonstrate the EU’s increasing focus on alternative payment systems and digital assets as potential sanctions evasion mechanisms.

Energy Measures

The energy sector continues to be a primary target. Some of the key restrictions introduced are:

• suspension of the automatic adjustment mechanism for the oil price cap until July 2027;
• new powers to prohibit transactions involving certain refineries processing Russian crude oil;
• additional restrictions relating to LNG tanker sales and transfers;
• designation of further Russian ports and airports; and
• new contractual obligations intended to reduce the risk of LNG tankers ultimately being supplied to Russia.

The package also targets companies operating within Russia’s oil, gold, diamond, mining and metallurgy sectors.

Expansion of Measures Against the Shadow Fleet

The EU has continued its campaign against Russia’s shadow fleet by adding 41 further vessels, bringing the total number of sanctioned vessels to over 670.

Importantly, the criteria for designation have been broadened to include vessels providing support services, such as bunkering operations, as well as companies and individuals assisting the operation of the shadow fleet.

Trade Measures

The package expands export restrictions on goods and technologies that may contribute to Russia’s military capabilities.

Newly restricted items include:

• specialised metal powders and alloys;
• materials used in aircraft engines;
• drone and UAV components;
• aerospace-related equipment;
• semiconductor processing equipment; and
• technologies used in electronic warfare and drone interception systems.

With regards to imports, additional restrictions apply to products generating significant revenue for Russia, including certain metal ores, zinc products, chromium oxides, glassware, imitation pearls and automotive parts.

Anti-Circumvention Measures

The EU continues to focus on sanctions evasion through third countries.

An additional 51 entities have been added to the export restriction list, including companies located in China (including Hong Kong), India, Kazakhstan, the United Arab Emirates, Kyrgyzstan, and Türkiye.

These entities are considered to have supported Russia’s military-industrial complex or facilitated the circumvention of EU sanctions.

Visa Restriction Measures

For the first time, the package establishes the legal basis for a comprehensive visa ban on Russian combatants and former combatants involved in Russia’s war against Ukraine. The Council will determine the date on which these measures enter into force following the adoption of the necessary implementing measures.

Measures for Protection of EU Businesses

The package introduces important legal protections for EU operators.

Among other measures, Member States are required not to recognise or enforce certain Russian court judgments linked to EU sanctions, and EU courts are empowered to grant remedies against abusive litigation initiated in Russia as retaliation for compliance with EU restrictive measures.

Practical Considerations for Businesses

Businesses operating within the scope of EU sanctions should review their compliance frameworks in light of the new measures. Particular attention should be given to:

• customer and counterparty screening, including newly designated individuals and entities;
• financial institutions and payment intermediaries;
• crypto-asset service providers;
• shipping and maritime counterparties;
• supply chains involving dual-use or restricted goods;
• transactions involving third-country intermediaries; and
• contractual protections addressing sanctions risks.

Organisations should also assess whether existing sanctions policies, transaction monitoring procedures and due diligence processes remain appropriate in light of the EU’s increasing focus on sanctions circumvention.

Conclusion

The 21st sanctions package represents a significant expansion of the EU’s existing restrictive measures against Russia. It significantly broadens existing sanctions across multiple sectors, including banking, crypto-assets, energy, trade, shipping and anti-circumvention measures. Businesses engaged in cross-border trade or financial services should ensure that their sanctions compliance programmes are updated to reflect these developments.

MK Compliance Limited can provide daily/weekly/monthly updates on sanctions, and AML regulatory developments. These updates ensure that you are kept informed about the latest regulatory changes, therefore ensuring comprehensive compliance.

In addition, we provide sanctions-related consulting services, including legal opinions, transaction reviews, screenings and background checks on your clients and related individuals/entities/counterparties, to ensure your business operations remain fully compliant with all applicable sanctions, mitigating the risk of breaches.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.