Implementation of the European Union’s 21st sanctions package

Among other things, the 21st sanctions package focuses on the following measures:

1. Financial Sector

Regulation (EU) 2026/1848 expands several annexes to Regulation (EU) 833/2014. In particular, 33 additional credit and financial institutions have been made subject to transaction bans, including Russian regional banks, institutions of importance for cross-border payments, and institutions linked to the Russian armed forces or the occupied territories of Ukraine.

The package also targets additional third-country financial institutions and service providers that support Russian payment infrastructures – including specialized financial messaging services – or otherwise facilitate the circumvention of EU sanctions.

2. Crypto-Assets

A key focus of the package is the crypto-asset sector. Four financial entities and 14 crypto-asset service providers have been added to the relevant annexes of Regulation (EU) 833/2014. The measures are primarily intended to target structures that enable Russian banks or listed persons to access cross-border payment and crypto-asset services. In addition, the new Article 5bc of Regulation (EU) 833/2014 introduces a mechanism for comprehensive transaction bans against crypto-asset service providers and crypto-asset platforms established in certain third countries. The mechanism may be activated where the Council determines that the relevant third country systematically and continuously fails to prevent the circumvention of Russia-related sanctions by such providers. The mechanism has not yet been activated, as the newly created Annex LVII does not currently list any third countries.

3. Export Controls and Trade

Regulation (EU) 2026/1848 expands the product-related annexes to Regulation (EU) 833/2014 regarding exports and imports. The measures particularly concern additional goods and technologies that may contribute to Russia’s technological or industrial development, as well as further products from which Russia derives substantial revenues.

Regarding exports, the newly restricted items include certain metals and alloys used for corrosion-resistant coatings of jet engines, beryllium powder used in fuels and high-performance alloys, self-adhesive films, tapes and strips, as well as goods specifically used for unmanned aerial vehicles (UAVs), such as ground support equipment, jamming and interception systems, launch systems, servomotors and flight termination systems.

Regarding imports, new restrictions apply to goods which generate significant revenues for Russia, such as copper ores, nickel ores, lead ores, precious-metals ores, unwrought zinc, alkaline-earth metals, zinc oxides and chromium oxides, glassware imitation pearls and car parts.
Similar sanctions have also been introduced in relation to Belarus.

In addition, 51 organisations have been added to Annex IV of Regulation (EU) 833/2014, including 29 organisations established in third countries. Exports of dual-use goods and certain advanced technologies to these entities are now subject to enhanced restrictions.  

4. Individual Sanctions

Implementing Regulation (EU) 2026/1843 adds 48 natural persons and 168 organizations and entities to Annex I of Regulation (EU) 269/2014. The legal act therefore introduces a total of 216 new listings. With respect to these persons, organizations and entities, the prohibition on making funds or economic resources available must now be observed. Their funds and economic resources are also subject to an asset freeze.
 

5. Energy and Shipping

A further 41 vessels have been added to Annex XLII of Regulation (EU) 833/2014. The vessels listed in Annex XLII are subject to the restrictions laid down in Article 3s of the Regulation, including port-related and service restrictions. Additionally, the scope of the measures has been expanded to cover, among other things, bunkering services, towage services and certain ship-to-ship transfer activities involving listed vessels.

New reporting obligations have been introduced for sales of LNG tankers to third countries. The legal framework also provides for the possibility of additional restrictions where LNG tankers are used in support of Russian energy interests.

The package further introduces a transaction ban relating to refineries listed in Annex XLVII, Part D. The measure targets refineries in Russia and third countries that process Russian crude oil or Russian petroleum products, or that are used to facilitate the circumvention of EU sanctions. Furthermore, the mechanism for the automatic adjustment of the crude oil price cap has been suspended until 15 July 2027.

6. Protection Against Russian Proceedings

The 21st sanctions package strengthens the legal protections available to EU persons under the EU sanctions regimes against Russia. The amendments broaden the ability to seek compensation before the courts of a Member State for losses arising from certain Russian legal proceedings relating to contracts or transactions affected by EU sanctions. Recoverable losses may include legal costs as well as damages resulting from Russian judicial or administrative decisions.

Article 11ca of Regulation (EU) 833/2014 further provides remedies against certain abusive Russian litigation and enforcement measures.
Article 11c of Regulation (EU) 833/2014 and Article 11c of Regulation (EU) 269/2014 prohibit the recognition, implementation or enforcement within the EU of certain Russian judicial and administrative decisions. The provisions particularly target decisions based on Russian rules asserting exclusive jurisdiction over disputes involving contracts or transactions affected by EU sanctions.

7. Conclusion and Outlook

With focus on the crypto- and finance sector, the 21st sanctions package once again targets newly emerging sanctions circumvention structures. Companies should take immediate action to review their sanctions screening procedures, ownership and control assessments, payment channels, crypto-asset service providers and classification of goods. It should also be noted that certain measures become applicable on different dates.

Special attention should be paid to complex transaction and settlement structures, including the possibility of indirect links to sanctioned service providers.

Given the immediate applicability of the new rules, businesses should ensure that the changes are incorporated into their compliance frameworks without delay. As sanctions circumvention techniques continue to evolve and regulatory requirements become increasingly complex, a comprehensive legal review of both existing compliance programmes and the implementation of the new measures is strongly recommended.

Council Regulation (EU) 2026/1848 of 23 July 2026 amending Regulation (EU) No 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine

Council Regulation (EU) 2026/1846 of 23 July 2026 amending Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

Council Regulation (EU) 2026/1844 of 23 July 2026 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Implementing Regulation (EU) 2026/1843 of 23 July 2026 implementing Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine

Council Implementing Regulation (EU) 2026/1817 of 23 July 2026 implementing Article 8a(1) of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine