On 23 July 2026, the EU adopted its 21st sanctions package against Russia, introducing new derogations and strengthening measures targeting the energy and financial sectors, crypto-asset services, and Russia’s shadow fleet. The package also includes the largest batch of individual listings in four years. Certain measures are also reflected in the sanctions regime against Belarus.
What you need to know
- The package adds 216 persons (168 entities and 48 individuals) to the asset freeze list, the largest batch of individual listings in four years. New listings primarily target Russia's banking sector, along with its military-industrial complex, energy sector, shadow-fleet enablers, critical infrastructure, and war-propaganda actors.
- The EU introduces several new derogations and exemptions from asset-freeze and trade restrictions, including derogations relating to energy imports and divestment from Russia.
- The package suspends the automatic update mechanism for the Russian oil price cap until 14 July 2027, keeping the cap fixed at USD 44.10 per barrel pending a Commission review by 15 January 2027.
- The EU listed 33 Russian banks and several third-country financial institutions connecting to alternative Russian financial messaging services, as well as several third-country crypto platforms, now subject to a transaction ban.
- The EU further strengthens its protections for EU persons against third-country litigation linked to sanctions-affected transactions.
New listings subject to asset freezing sanctions
The package adds 216 persons (48 individuals and 168 entities) to the asset freeze list. This is the largest batch of individual listings in four years. The new listings focus primarily on the Russian banking sector but also target actors in the military-industrial complex, energy sector, shadow-fleet enablers, critical infrastructure and persons engaging in war propaganda. The most significant designations include:
In the finance sector
- 94 Russian banks and major financial institutions including MOEX, Rosselkhozbank and Bank DOM.RF.
- Four individuals and entities linked to the A7 network, a Russian cross-border payment system used to circumvent sanctions. A7 is co-owned by state-controlled PSB Bank and centres on the rouble-backed A7A5 stablecoin. The designations include A7A5 project director Leonid Shumakov, PSB Deputy Chairman Mikhail Dorofeev, and A7’s Russian subsidiaries A7 Agent and A71.
In the military and defence industry sector
- 56 Russian entities and individuals in the military-industrial sector engaged in the production and supply chain of long-range drones and military components (chemical, electronic, on-board software and testing systems). 37 designations connect directly to the Garpiya/Garpiya-A1 long-range attack-UAV supply chain.
- Individuals in Russia's military accused of serious human rights violations.
In the energy and maritime transport sector
- Several entities active in the oil and gas sector, which provide substantial revenue to the Russian Government. Designated non-Russian entities include Redwood Global Supply FZ-LLC, a UAE-based company identified as a significant trader of Russian seaborne crude oil and petroleum products.
- Several shipping, ship-management and technical-services companies owning or managing vessels transporting Russian crude oil or petroleum products while engaging in irregular and high-risk shipping practices, including AIS manipulation, ship-to-ship transfers and inadequate insurance coverage. Designated third-country operators include Peninsular Maritime India Private Limited (India), White Agate Marine SPC (Oman), Zulu Ships Management (UAE), Astute Maritime Services Private Limited (Singapore) and Hua Xia Shipmanagement Company Limited (China).
In critical infrastructure, mining and gold
- Individuals operating in Russia's critical infrastructure, notably the Director General and Chairman of the Executive Board of Russian Railways, Oleg Belozerov.
- Seven major Russian actors in the gold sector, a leading diamond company, as well as several entities active in the mining and metallurgy sectors.
Substantive amendments to the asset freeze regulation
The package adds several derogations and exemptions from the asset freeze obligations and the prohibition of making funds and economic resources available, including:
- A derogation for some specific designated persons operating or managing vessels transporting Russian crude oil or petroleum products while engaging in irregular and high-risk shipping practices for insurance payments.
- A derogation for specific designated persons for the fulfilment of contractual obligations arising from put options agreed upon before 28 February 2022.
- Two new exemptions relating to JSC Russian Railways and the Paks II Project.
New trade restrictions in the energy and related maritime transport sector
Crude oil and petroleum products import bans and service restrictions
The package introduces new authorisation-based derogations from the import ban on Russian crude oil and petroleum products, and on third-country petroleum products obtained from Russian crude oil. It also extends exemptions to the maritime-services restrictions that apply to transfers of Russian crude oil or petroleum products to third countries.
- Regarding the import ban on Russian crude oil and petroleum products, authorities may allow derogations for goods that have been seized, confiscated, or are under the effective control of an EU Member State.
- Regarding the import ban on third-country petroleum products obtained from Russian crude oil, authorities may exempt importers from providing evidence of the origin of crude oil used to refine petroleum products in a third country. This exemption only applies where the petroleum products are intended for an EU outermost region or associated overseas country or territory, there is a proven risk of serious supply disruption due to that region’s particular geographical or logistical constraints, and no economically and logistically viable alternative supply is available.
- Regarding the maritime service restrictions, the exemption to the oil price cap for the transport, by vessel, of crude oil originating in the Sakhalin-2 Project in Russia to Japan has been extended to 31 March 2028.
Oil price cap mechanism
While the 20th sanctions package introduced a legal basis to suspend the oil-price-cap exemption from restrictions on maritime services for Russian crude oil and petroleum products, the new measures do not activate that suspension. Instead, the EU has suspended the automatic procedure for updating the oil price cap from 24 July 2026 to 14 July 2027.
Previously, the legal framework provided for an automatic update procedure to modify the price cap for Russian crude oil depending on the average market price of Russian crude oil. Given the recent exceptional disturbances in the markets for crude oil and petroleum products the EU decided to suspend this mechanism. This means that the oil price cap remains fixed at USD 44.10 per barrel. The Commission will conduct an interim price assessment by 15 January 2027, on the basis of which the Council may decide to amend the cap. Unless the Council adopts such a decision, the cap will remain at USD 44.10 until 14 July 2027. The automatic adjustment mechanism will resume on 15 July 2027.
LNG-related measures
The new package introduces exemptions from the Russian LNG transfer ban to permit the transport by vessel and related services for LNG originating from the Sakhalin-2 Project destined for Japan and the Republic of Korea. The exemption expires on 31 March 2028. The new measures also allow for a temporary derogation for the transfer and linked purchases of Russian LNG to third countries in performance of contracts concluded before 24 February 2022 until 25 July 2027. After that date, the derogation is subject to an annual renewal review process.
The package clarifies the scope of the LNG-terminal-services ban introduced under the 20th sanctions package. From 1 January 2027, the ban prohibits LNG terminal services (and continuing related contracts) for Russian entities and any entity, including third-country entities, that Russian persons own more than 50% or control.
The new measures oblige sellers to notify competent authorities immediately of any sale or transfer of ownership of LNG tanker to third countries, providing the seller’s and buyer’s identity, the vessel’s IMO number and Call Sign. This obligation adds to the existing notification and due-diligence rules for selling tankers for the transport of crude oil or petroleum products.
Transaction bans in the energy sector
The new measures extend the transaction ban to listed Russian and third-country refineries that process, refine or blend Russian crude oil or products, or that facilitate circumvention of the restrictive measures. So far, the EU has designated only the Kulevi refinery, a newly commissioned facility near Georgia’s Kulevi oil terminal and port and connected to it by pipeline. The refinery has reportedly sourced 100% of its crude oil feedstock from Russia and exported oil products to the EU and USA through the port of Kulevi. The ban takes effect on 25 January 2027.
The EU banned transactions with two Russian ports (Olya and Vysotsk) and four airports (Sheremetyevo in Moscow, Ulyanovsk-Vostochny, Rostov-on-Don Platov and Mineralnye Vody) all used to transport goods and technology for the defence and security sector. The ban took effect on 24 July 2026.
Russia's "shadow fleet"
The EU added 41 new vessels and broadened its vessel-designation criteria to cover ships engaged in high-risk oil-transport practices (such as AIS manipulation, irregular ship-to-ship transfers and inadequate insurance) as well as ships that provide bunkering or towage services to already-designated vessels.
New trade restrictions in the finance sector
The EU further tightened restrictions on Russia's financial sector, again focusing on alternative payment channels:
- Transaction bans on Russian banks: The package adds 33 Russian banks to the existing transaction ban on Russian credit and financial institutions, effective 13 August 2026, including Energobank, Transcapitalbank, Unistream and Credit Ural Bank. The total number of Russian banks subject to transaction bans now reaches 103.
- Transaction bans on third-country banks connecting to alternative Russian financial messaging services: The EU extended the transaction ban to one third-country bank for connecting to the Russian System for Transfer of Financial Messages (SPFS) or equivalent specialised financial messaging services, namely CJSC Eco-Islamic Bank (Kyrgyzstan). The package also introduced a new derogation for transactions strictly necessary to withdraw funds or close accounts held with listed entities added on or after 24 July 2026, subject to specific conditions. The EU delisted Yelo Bank (Azerbaijan).
- Transaction bans on entities deemed to be frustrating EU sanctions: The EU also designated 22 credit and financial institutions as well as non-financial institutions for enabling the performance of international transactions that frustrate EU sanctions. These include 14 crypto platforms and crypto-linked firms located in Georgia, Panama, El Salvador, UAE, the Marshall Islands, and Belarus. Here too, a new derogation allows transactions strictly necessary to withdraw funds or close accounts held with entities listed on or after 24 July 2026.
- Transaction ban on third-country crypto asset services: EU persons are now banned from transacting with any crypto-asset service provider established in listed third countries. A third country may be listed where it has “systematically and persistently failed to prevent the provision of crypto-asset services, or to prevent platforms exchanging or transferring crypto-assets", thereby frustrating EU sanctions. To this date, no third countries have been listed. This ban adds to the transaction ban on Russian crypto-asset service providers which had been introduced with the 20th sanctions package.
- Prohibition to appoint Russian nationals on boards of crypto services companies: The package extends the existing ban for Russian nationals to directly or indirectly own, control or become a controlling member of any EU-based company that offers crypto-asset wallet, account, or custody services. The ban now also covers other crypto-asset services regulated under the Markets in Crypto-Assets Regulation (MiCA), such as exchanges and trading platforms, effective 25 August 2026. The prohibition applies as of 25 August 2026.
Other trade restrictions
- Import bans: The EU banned the import of various goods, including copper, nickel, lead and precious-metal ores; unwrought zinc; alkali and alkaline-earth metals; certain inorganic chemicals, including zinc and chromium oxides; tall oil; glassware; imitation pearls; and car parts.
- Export bans and restrictions: The EU listed additional items subject to export bans or restrictions, including nickel powders, metal, and alloys, used in corrosion resistant coating of jet engines; Beryllium powder used in propellants; and self-adhesive films, tapes, and strips used in the aerospace and defence sectors. The export controls on UAV components and counter-UAV systems have been aligned with the Iranian Missile and UAV Regime to eliminate inconsistencies, covering servomotors, launch systems, ground-support equipment, flight-termination systems, and related software, as well as jamming, interception, and spoofing equipment.
- New listing of entities subject to enhanced export controls: The EU added 51 entities to the list subject to export bans on dual-use and advanced technology items, including third-country entities active in microelectronics, CNC machine tools, and semiconductor equipment sectors, including entities established in third countries involved in circumvention operations, including in Türkiye, UAE, Hong Kong, China and India.
Derogation for divestments from Russia
The package extends the deadlines applicable to a series of derogations needed for divestments from Russia to 31 December 2027. This includes the derogation for transactions strictly necessary for the liquidation of joint ventures or similar arrangements concluded before 16 March 2022.
Protection of EU persons
The package adds legal safeguards for EU persons against claims of Russian and non-Russian counterparties and retaliatory actions by the Russian Government:
- The package expands EU persons’ right to compensation for damages suffered in connection with EU sanctions. EU persons may now seek compensation not only from individuals and entities directly subject to an EU asset freeze (or anyone acting through or their behalf), but also from persons or entities outside the EU that provide prohibited funds or economic resources to a designated party, its representative or proxy, and that have initiated proceedings against EU persons from outside the EU.
- The package bans Member States from recognising, implementing, or enforcing Russian judicial or arbitral decisions.
- The package expands EU courts’ authority to issue orders against legal proceedings against EU persons in relation to EU sanctions. Courts can now order to not seek to enforce, recognise or rely upon any injunction, order, relief, judgment, or other court decision, in any jurisdiction, that was obtained in those legal proceedings.
Other key contacts and authors: Emilia Etz, Senior Associate; Nina Schwartz, Associate
