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EU Adopts 21st Sanctions Package Against Russia

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On July 23, 2026, the Council of the European Union adopted its 21st sanctions package against Russia and parallel measures concerning Belarus. Across the two asset-freeze regimes, the package added 48 individuals and 170 entities. Beyond the new listings, the package also amends Regulation (EU) No 833/2014 and the corresponding Belarus sectoral regime, introducing new transaction bans, trade controls and other restrictions. The new asset-freeze listings and amendments to Regulation (EU) No 269/2014 took effect on July 23, 2026, and many of the principal sectoral amendments took effect on July 24, 2026, although several measures have later application dates.

Key Takeaways

  • The package adds 218 asset-freeze designations across the Russia and Belarus regimes, focusing particularly on finance, energy, the military-industrial complex and the shadow fleet.
  • New transaction bans cover additional banks, payment and crypto platforms, oil traders, a refinery, ports and airports, with application dates beginning in August 2026.
  • Trade controls expand through 51 new Annex IV entities, additional advanced-technology export controls and wider restrictions on Russian revenue-generating goods.
  • Energy measures affect the oil-price-cap mechanism, Russian LNG transfers and purchases, LNG terminal services and transfers of LNG tankers.
  • Businesses should re-screen counterparties and assets, review payment and contract chains, and implement the package’s staggered application, reporting and notification dates.

New Listings and Transaction Bans

Finance, payments and crypto-assets
The financial measures are among the package’s most extensive. The Council describes the new asset-freeze listings as including 94 banks and other major financial institutions, among them Moscow Exchange and a broad range of commercial and regional banks. Separately, 33 additional Russian credit and financial institutions become subject, from August 13, 2026, to the prohibition on engaging directly or indirectly in transactions with them.

The reach of those measures is not confined to Russian institutions. From August 13, 2026, transaction bans also apply to Eco-Islamic Bank in Kyrgyzstan, Chinggis Khaan Bank in Mongolia, Sberbank India and India VTB. In contrast, Yelo Bank of Azerbaijan is no longer subject to a transaction ban.

There is, however, a narrow exit route for certain account holders. Eligible EU, EEA and Swiss nationals and residents may seek authorization to withdraw funds or close accounts with newly transaction-banned persons. Applications must be made within three months after the relevant prohibition begins to apply, and the transaction must be strictly necessary to terminate operations, contracts or other agreements and transfer the funds to a permitted destination.

Beyond conventional banking channels, the package also targets the A7 cross-border payments network and its A7A5 stablecoin infrastructure. A7 Nigeria, A7 Africa and PilotFinance Ltd. become subject to transaction bans from August 13, 2026, followed by 11 crypto-asset and payment-service platforms from August 23, 2026. A new mechanism permits country-wide transaction bans on crypto service providers and exchange or transfer platforms in a third country that persistently fails to prevent sanctions circumvention; no country was listed when the package was adopted. From August 25, 2026, restrictions on Russian nationals and residents owning, controlling or holding governing-body positions in specified EU crypto businesses extend to a wider range of crypto-services, as defined in Regulation (EU) 2023/1114.

Energy, shadow-fleet and transport targets
Energy remains a central focus of the package. The asset-freeze measures include 18 entities and one individual in the oil sector, covering refineries, producers, traders and other energy companies, as well as PJSC Inter RAO UES. Five third-country oil traders become subject to transaction bans from August 13, 2026.

The measures also look beyond designated producers and traders. The package creates a framework for transaction bans on refineries in Russia or third countries that process, refine or blend Russian-origin oil or petroleum products, or facilitate sanctions evasion. The sole initial refinery listing is Kulevi Oil Refinery in Georgia. The ban is due to apply from January 25, 2027, and the Commission must report by October 25, 2026 on whether the listing should be maintained.

A further 41 vessels have been added to the EU’s vessel-specific measures, which include port-access and maritime-service restrictions. Significantly, the listing criteria now cover vessels providing bunkering, tug or similar support to listed vessels, or conducting ship-to-ship transfers with them. Eight entities and one individual involved in the wider shadow-fleet ecosystem were also designated. Maritime screening should therefore use IMO numbers and cover owners, operators, managers and service providers.

The focus is not confined to vessels and energy. Transaction bans now apply to the Russian ports of Olya and Vysotsk and to Sheremetyevo, Ulyanovsk-Vostochny, Rostov-on-Don Platov and Mineralnye Vody airports.

The package designates Oleg Belozerov, Director General and Chairman of the Executive Board of JSC Russian Railways, although Russian Railways itself is not listed. Separately, a new exemption disapplies the asset-freeze and making-available prohibitions for funds and economic resources necessary for specified rail transport, related infrastructure and associated services involving Russian Railways, despite Russian Railways not being listed. The Council states that the exemption is intended to enable the continued operation of necessary rail transport and that it does not prejudice any case-by-case assessment of whether a designated person controls a non-designated entity.

Other designations
Other listings target major Russian gold, diamond, mining, metals and equipment businesses, as well as 56 listings linked to the military-industrial complex, including 37 associated with long-range drone production and supply chains. Eight individuals were listed for spreading Russian state propaganda, and one Russian general was listed in connection with war crimes.

Trade Measures

Export and import restrictions
The trade controls are also being tightened. Fifty-one additional Russian and third-country entities have been added to Annex IV of Regulation (EU) No 833/2014, meaning they are subject to tighter restrictions on exports of dual-use and advanced-technology goods and technology. The entities are located in Russia and in third countries including China and Hong Kong, India, Kazakhstan, Kyrgyzstan, Türkiye and the United Arab Emirates. The listings focus on procurement or diversion of microelectronics, semiconductor-manufacturing equipment, CNC machine tools and other goods relevant to Russia’s defense and technology sectors.

Goods subject to export controls have also been expanded to cover further metal powders and alloys, specialized aerospace materials, UAV-related systems, jamming or interception equipment, servomotors and related software, firmware and components.

On the import side, the restrictions on Russian-origin revenue-generating goods now cover additional ores and concentrates, zinc and chromium oxides, tall oil, glass and glassware, metals, vehicle bodies and cabs, and vehicle parts and accessories. The existing furskin entry has been revised to exclude sable. For specified newly listed goods, a transition until October 25, 2026, permits the execution of contracts concluded before July 24, 2026, and ancillary contracts necessary for their execution.

Oil-price-cap and other energy measures
The package changes how the oil-price-cap mechanism will operate over the coming year, to ensure that Russia does not benefit from events that cause the price to rise, including the unrest in the Middle East. The automatic procedure for recalculating the Russian crude-oil price cap is suspended from July 24, 2026, to July 14, 2027. The Commission must report an interim calculation by January 15, 2027, after which the Council may amend the cap. In the absence of a decision, the existing cap remains and the automatic procedure resumes on July 15, 2027.

Alongside that change, the package adjusts several narrowly framed energy exemptions and authorization routes. These concern seized or confiscated Russian oil; evidence of origin for specified third-country-refined petroleum products destined for certain EU outermost regions or associated overseas territories; specified Sakhalin-2 crude-oil shipments to Japan and LNG shipments to Japan or the Republic of Korea through March 31, 2028; a Hungary-specific exemption for saturated acyclic hydrocarbons through December 31, 2026; and the Nord Stream and Nord Stream 2 authorization framework. Each is subject to measure-specific conditions.

LNG transfers, purchases, terminal services and tanker sales
The LNG provisions are among the package’s most detailed. A temporary, volume-capped exemption permits certain transfers of Russian LNG to third countries and related purchases where both are carried out under long-term contracts concluded before February 24, 2022, with a duration exceeding one year. The contracts must not have been amended after that date except in the limited ways specified in the Regulation.

Even where the exemption is available, its use is tightly constrained. The exemption is capped at the operator’s relevant 2025 annual volume. It applies until July 25, 2027, and then for successive one-year periods unless the Council decides otherwise following an annual review. Operators relying on it must report historical volumes and shipment-level information by August 25, 2026, and every three months thereafter, and so the history of both transfer and purchase arrangements should be reviewed before reliance on the exemption.

The LNG restrictions tighten materially from January 1, 2027. Purchases of Russian LNG not connected with a qualifying transfer by an EU operator are prohibited. Restrictions on providing LNG terminal services to persons or entities in Russia and to Russian-owned or controlled entities, including in third countries, apply from the same date. Although not binding, Recital 15 notes that the impossibility resulting from the prohibition on non-qualifying LNG purchases may be invoked as force majeure to terminate affected purchase obligations where those obligations cannot continue in connection with qualifying transfers. It does not make the same statement for LNG terminal-service contracts, and its practical effect will depend on the contract, governing law and dispute-resolution forum.

The package also creates a new compliance trigger for LNG tanker transactions. Any sale or other arrangement transferring ownership of specified LNG tankers by an EU person to a third country must be notified immediately to the relevant Member State authority. The Regulation also establishes a framework for possible future restrictions on tanker sales to Russia and related diversion controls, but a further Council act is required before those measures become operative. The Council is to review the position by October 25, 2026.

Other exemptions and licensing grounds
The package also introduces or extends several narrowly framed reliefs, beyond those already discussed.

New asset-freeze derogations address specified insurance payments and pre-existing put-option arrangements. The insurance provision permits authorization for certain indemnity or benefit payments to unlisted recipients where a listed person or entity is liable for the insured risk. The put-option provisions are limited to particular persons, entities and contractual arrangements agreed and exercised before February 28, 2022. Neither creates a general route for settling obligations owed to or involving designated persons.

For the Paks II civil nuclear project, a direct exemption permits funds and economic resources to be made available to three identified listed entities where strictly necessary for specified civil nuclear activities. Prior authorization is not required, but the relevant activity must be notified to the competent Hungarian authority within two weeks of commencing.

On the trade side, the package also broadens the civilian electronic-communications derogations under the Russia and Belarus regimes. The previous requirement that a qualifying network be “non-publicly available” has been removed, although networks owned by publicly controlled or majority publicly owned entities remain excluded. A separate exception permits the provision of computerized reservation systems notwithstanding the wider restriction on tourism-related services in Russia. Competent authorities may also authorize specified Russian financing or other support for the EuXFEL, FAIR and ESRF research institutions where based on relevant international agreements. Finally, several existing divestment and wind-down routes have been extended to December 31, 2027. These may permit specified transactions, transfers of controlled goods or rights, and otherwise prohibited services where strictly necessary for an eligible withdrawal from Russia, subject to specific conditions.

Litigation protections and visa measures
One of the package’s more notable non-trade elements is its response to sanctions-related litigation. The package strengthens protections for EU operators facing Russian or other third-country proceedings connected with contracts affected by EU sanctions. In defined circumstances, an EU operator may seek recovery in Member State courts of direct and indirect losses, including legal costs, where effective remedies are unavailable in the relevant third-country jurisdiction. Recovery may be sought from the claimant and, in specified cases, persons owning or controlling it.

Those protections are reinforced at the enforcement stage. Member States must not recognize, give effect to or enforce specified Russian court or administrative decisions connected with sanctions-affected contracts. EU courts may also restrain certain Russian proceedings or prohibit reliance on resulting decisions, including where proceedings breach an exclusive jurisdiction or arbitration clause, rely on Articles 248.1 or 248.2 of the Russian Arbitration Procedure Code or equivalent legislation, or frustrate EU restrictive measures.

The package creates a basis for requiring Member States to refuse short-stay visas to applicants who have served since February 24, 2022, in Russian armed, paramilitary or associated irregular groups and directly contributed to combat operations. The framework is not yet operational and contains limited humanitarian, national-interest, international-obligation, dissident and defector exceptions.

Belarus alignment
In parallel, the Belarus measures broadly align with the direction of the Russia package. They add European Trading Company LLC and OJSC Mozyr Oil Refinery to the asset-freeze list and four Belarusian entities to the enhanced export-control list. They also align parts of the Belarus regime with the new Russian trade, crypto-asset, litigation and anti-circumvention provisions.

Next Steps for Businesses
For businesses, the immediate challenge is to translate the package’s staggered application dates and measure-specific conditions into workable operational controls. Businesses could consider the following measures.

  1. Re-screen counterparties and assets. Re-screen customers, suppliers, owners and controllers, banks, payment and crypto providers, oil traders and refineries, vessels by IMO number, maritime service providers, ports and airports. Distinguish asset freezes from transaction bans and assess ownership, control and acting-on-behalf relationships.
  2. Be aware of the implementation timeline. Capture all relevant application, transition, review, reporting and notification dates, including August 13, 23 and 25, 2026; October 25, 2026; January 1 and 25, 2027; July 15 and 25, 2027; December 31, 2027; and March 31, 2028.
  3. Review payment chains and contracts. Identify exposure to newly restricted institutions across correspondent banking, settlement, trade finance, guarantees, payment services and crypto arrangements. Review pre-July 24, 2026 contracts, ancillary agreements, amendments and Russia-exit arrangements before relying on transition or wind-down provisions.
  4. Update LNG, trade and maritime controls. For LNG, reconstruct the relevant contract history, test amendments and calculate the 2025 volume ceiling. Map the new CN codes, Annex VII controls and Annex IV entities to product classifications, bills of materials and screening systems. Extend maritime controls to bunkering, tug, ship-to-ship and other support services.
  5. Prepare filings and preserve evidence. Identify the competent authority, deadline and evidential requirements for every exemption, derogation, authorization, report or notification. Retain screening results, ownership and control analyses, contracts, shipment records and evidence supporting any sanctions-related impossibility or litigation claim, and update relevant policies and training.

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