EU Adopts “Mini” Sanctions Package Against Russia

On 15 June 2026, the European Union adopted a “mini” sanctions package targeting Russia, delivering on the European Commission’s announcement that it would now impose sanctions on a “rolling” basis to increase their effectiveness. This initiative is separate from the more comprehensive 21st sanctions package, which was presented by the European Commission on 9 June 2026, and is still under discussion between Member States.

The mini package is essentially limited to new designations under asset freeze measures and prohibitions to make assets available, but also introduced an important derogation allowing EU operators to wind down or phase out their relationships with Yangzhou Yangjie Electronic Technology Co., Ltd (“Yangjie”), a Chinese chip trader notably supplying the automotive and defence industries, designated under the 20th Russia sanctions package on 23 April 2026.

While limited in scale compared to previous packages, new designations illustrate again the European Union’s willingness to tackle circumvention through sanctions designations, and its readiness to go after third-country operators. Listings targeting entities established in Azerbaijan, Belarus, China, Hong Kong, Liberia, Türkiye, and the UAE illustrate that transactions outside any EU nexus are not necessarily risk-free.

New asset freeze designations: The package targets 40 individuals and 47 entities linked toRussia’s military-industrial complex, shadow fleet ecosystem, propaganda and disinformation campaigns, and human rights violations, as well as destabilization operations in Moldova:

• Contribution to Russia’s military-industrial complex (listing under Regulation 269/2014): 7 individuals and 21 entities (including one from Belarus and two from China).
• Contribution to Russian energy revenues, notably through Russia’s shadow fleet (listing under Regulation 269/2014): Two individuals (one Azerbaijani national and one Russian-Israeli national) and 24 entities (including one entity from Azerbaijan, two from Hong Kong, one from Liberia, three from Türkiye and five from the UAE).
• Pro-Kremlin propaganda (listing under Regulation 2024/2642): 10 individuals (including military correspondents, media personalities, directors of newspapers or public relations agencies, writers, journalists, a church member) and one Russian foundation.
• Alexei Navalny-related human rights violations (listing under Regulation 2024/1485): 15 individuals (including judges, prosecutors, law enforcement, state security and medical personnel).
• Russia-backed destabilization operations in Moldova: Six individuals (four Moldovan nationals and two Russian nationals).

The new designations were adopted under four different regimes, through the following texts:

• Decision 2026/1364 and Regulation 2026/1361 under the main asset freeze regime targeting Russia (Decision 2014/145 and Regulation 269/2014);
• Decision 2026/1351 and Regulation 2026/1356 under the Russian hybrid threat regime (Decision 2024/2643 and Regulation 2024/2642);
• Decision 2026/1363 and Regulation 2026/1362 under the Russia-specific human rights regime (Decision 2024/1484 and Regulation 2024/1485); and
• Decision 2026/1357 and Regulation 2026/1358 under the Moldova sanctions regime (Decision 2023/891 and Regulation 2023/888).

Introduction of a new derogation specific to Yangjie: To address supply chain disruption caused by the designation of Yangjie, the package introduces a new derogation, which enables national competent authorities to authorize transactions with Yangjie that are necessary for:

• Terminating by 31 December 2026 operations, contracts or other agreements concluded with the sanctioned company before its designation on 23 April 2026, provided the transaction is completed by that date; or
• Industry purchases of critical components manufactured by the sanctioned company, until 16 March 2027, to enable a transition to alternative suppliers.