EU adopts 20th Russia sanctions package: key changes for companies

Insights|May 5, 2026

On 23 April 2026, the EU adopted its 20th package of sanctions against Russia, comprising Council Regulation (EU) 2026/506 amending Regulation (EU) No 833/2014 on sectoral measures, alongside parallel amendments to Regulation (EU) No 269/2014 on asset freezes and travel bans, and corresponding amendments to the Belarus sanctions regime. The package introduces the broadest set of structural legal changes since the sanctions framework was established, combining new trade and financial restrictions with significantly strengthened legal protections for EU operators.

Article 11 of Regulation 833/2014: anti-suit injunctions, extended damages and forum necessitatis

Three changes materially alter the litigation protection framework under Regulation 833/2014.

New Article 11ca enables EU operators to apply to a Member State court for an order requiring a Russian claimant to discontinue or refrain from initiating proceedings in Russian courts brought in breach of an exclusive jurisdiction or arbitration clause, including proceedings under Articles 248.1 and 248.2 of the Russian Arbitration Procedure Code. Non-compliance triggers financial penalties payable to the affected EU operator.

Articles 11a and 11b are extended to cover damages arising from enforcement of Russian court or expropriation decisions pursued in third countries outside Russia, including through intermediaries. The recitals confirm that the Russian Federation itself falls within Article 11(1)(b) and may be treated as having waived immunity where it brings claims in connection with sanctions-affected transactions.

Article 11(1)(d) extends the prohibition on satisfaction of claims to third-country persons selling, supplying or transferring goods, technology or services prohibited under Regulation 833/2014 to Russian-connected persons or for use in Russia, closing the gap where claims are brought by third-country intermediaries rather than Russian persons directly.

Article 11d is updated so that the forum necessitatis provision covers all claims under the expanded Article 11 framework, including anti-suit injunction applications.

Expansions of existing restrictions

Energy, LNG and maritime. The package lists 46 additional shadow fleet vessels, bringing the EU total to 632, all subject to port access and service bans. Two Russian ports, Murmansk and Tuapse, and the Karimun Oil Terminal in Indonesia are listed for shadow fleet connections and oil price cap circumvention. The package establishes the legal basis for a future full ban on maritime services related to Russian crude oil and petroleum products, with the Council to decide the entry into force date in coordination with the G7 and Price Cap Coalition (Article 3n(6)). Natural gas condensate from LNG production plants (CN 2709 00 10) is brought within both the import prohibition and the oil price cap regime from 1 January 2027 (Articles 3m(2a) and 3n(6c)). Rewritten Article 3q inserts safeguards on tanker sales to third countries: EU sellers must conduct documented due diligence, include a mandatory no-Russia contractual clause with cascading mirror obligations, and notify the competent authority immediately. A seller who has performed appropriate due diligence and obtained the required commitments will not be liable for a subsequent breach by the buyer.

Trade. New export bans valued at over €365 million cover chemicals, rubber, steel articles, tools for metal production, industrial tractors, explosives, laboratory glassware and high-performance lubricants. New Article 3k(1b) adds pipeline tubes, drilling equipment and certain offshore vessels to the energy-sector export ban. New import bans valued at over €530 million cover metals, chemicals and minerals not previously restricted, alongside a volume quota on ammonia imports (Article 3i(3h)). The traceability obligation for diamonds is extended to polished diamonds processed in third countries (CN 7102 39 00) from 24 April 2026 (Article 3p(10)).

Financial services and crypto-assets. Twenty additional Russian banks are added to the transaction ban, bringing the total to 70 Russian banks excluded from the EU internal market, alongside banks in Kyrgyzstan, Laos and Azerbaijan assisting the Russian war effort. Five previously listed third-country entities are delisted following compliance commitments. Article 5ad(1)(d) extends restrictions to non-bank operators offering netting, set-off, reconciliation or settlement services enabling international transactions from Russia in circumvention of sanctions. The list of prohibited crypto-assets is expanded to include RUBx and the digital ruble, a central bank digital currency designed in part to shield Russian persons from the effects of EU restrictive measures (Article 5ba), and a general prohibition on engaging with any crypto-asset service providers or exchange platforms established in Russia applies from 24 May 2026 (Article 5bb).

Services, research and media. Managed security services are added to the list of prohibited services from 25 May 2026 (Article 5n(1)(i)). The prohibition on accepting Russian public funding is extended to universities, research organizations, NGOs and enterprises carrying out Horizon Europe research and innovation actions (Article 5t). The broadcasting prohibition is extended to online mirror entities replicating the content, branding or infrastructure of already-listed outlets (Article 2f).

Anti-circumvention and listings. The Kyrgyz Republic becomes the first country against which the EU has activated its anti-circumvention tool, following evidence of EU-origin Common High Priority item imports running approximately 800% above pre-war levels and onward exports to Russia approximately 1,200% above pre-war levels, targeting machining centers (CN 8457 10) and data transmission equipment (CN 8517 62) used in drone and missile manufacturing. The package adds 116 listings under Regulation 269/2014, 33 individuals and 83 entities subject to asset freezes and travel bans, including oligarchs, persons involved in the abduction of Ukrainian children, propagandists and persons responsible for looting cultural heritage. A further 60 entities are added under Regulation 833/2014 for supporting Russia’s military-industrial complex, 28 of which are established in third countries including China, Hong Kong, Turkey, the UAE and Thailand.

New prohibitions

LNG terminal services and vessels, Articles 3rb and 3sa. From 1 January 2027, provision of LNG terminal services to Russian entities or EU-established entities more than 50% owned or controlled by Russian persons is prohibited, with existing contracts required to terminate by that date. Technical assistance, brokering and financing for Russian-flagged, owned or managed icebreakers and LNG tankers are prohibited from 25 April 2026, extending to LNG tankers merely operating in Russia from 1 January 2027. A new derogation (Article 3s(3a)) facilitates the recycling of listed shadow fleet vessels.

Expropriation, IP theft and enforcement, Articles 5ai, 5aj and 5sa. A transaction ban applies to entities benefitting from Russia’s “temporary management” expropriation of foreign-owned assets (Article 5ai, Annex LIV) and to persons seeking or cooperating in the enforcement of Russian court or expropriation decisions outside the Union (Article 5aj, Annex LV), with an exception for lawyers and members of the judiciary. A separate transaction ban targets Russian entities using, without consent, intellectual property rights or trade secrets of EU companies’ Russian subsidiaries under Presidential Decree No 122/2024 or Government Resolution No 1767/2021, legislation that permits compulsory use where Russian persons own more than 75% of the relevant entity’s share capital, with only symbolic compensation paid into a ruble account (Article 5sa). Affected EU right holders must notify the competent authority of any such use.

Belarus. Corresponding amendments mirror the trade, financial services and legal protection provisions of this package into the Belarus sanctions regime.