On the 23 April 2026 the EU Commission adopted the 20th sanctions package extension against Russia under the existing European sanctions framework. The implementation is complete via amendments to existing regulations:
- Regulation EU 2026/506 amending Regulations EU No 833/2014) – now includes sectorial measures targeting energy, shipping and trade.
- Regulation EU 2026/511 amending Regulation EU No 269/2014 – introduces amendments to the existing asset freeze measures.
- Implementation of Regulation EU 2026/509 – adding new individuals and entities to the existing asset freeze and travel ban list
The new sanctions restrictions cover a broad spectrum of services and industries –
- Energy sector amendments are introduced via Regulation EU 2026/506
- Ban on LNG terminal services (in effect from 1st January 2027) directly or indirectly
- Prohibition on maintenance for Russian LNG tankers and icebreakers
- Establishes a legal framework for the implementation of maritime services ban – broadening the scope of the existing oil and petroleum products ban. The full prohibition is agreed in principle, however not put into effect yet.
- Two Russian ports (Murmansk, Barents Sea & Tuapse, Black Sea) and Karimun Oil Terminal in Indonesia, off the coast of Singapore (Annex XVI)
- Tanker ship sales to Russia (required to conduct documented risk assessments of retransfer to Russia, implement proportionate controls to mitigate those risks, and notify the competent authority of the relevant Member State immediately upon any sale (providing seller and purchaser identities, incorporation documents, IMO number and call sign))
- Listing of additional shadow fleet vessels
- Financial sanctions amendments are implemented through Regulation EU 2026/506
- A number of new banking service providers were listed – Russian, Chinese and Central Asian. (Annex XV)
- Cryptoasset trading – Article 5ba – prohibition on transactions
- Russian based crypto-asset service providers are banned form engaging in transactions with EU persons, effective 24 May 2026
- Transactions involving Russian digital ruble and 2 other crypto-assets (listed under Annex LIII)
- Legal protections for EU based entities
- EU Courts permitted to issue orders parties to cease initiating legal proceedings before Russian courts, asserting jurisdiction over disputes affected by EU sanctions. (In response to Arbitration Procedure Code of the Russian Federation enabling legal persons to file a claim before Russian courts, asserting jurisdiction over disputes with EU companies)
- EU legal persons may claim damages before Member state courts from parties seeking to enforce Russian court administrative decision in third countries.
Regulation EU 2026/509 – adding new individuals and entities to the existing asset freeze and travel ban list
- Asset Freeze designations include smaller scale Russian oil producers – Bashneft and Slavneft, specific oil refineries, Gazprom Subsidiaries not listed directly in the past and UAE based companies linked to shadow fleet support.
- Expanding existing listings to include entities linked to shadow fleet activities. (paragraph 3)
- Derogation on limited release of funds for payment of arbitration costs, where arbitral proceedings were initiated by a listed person and costs are awarded to a non-listed, non-Russian party. (paragraph 6)
- EU persons may now recover damages from persons seeking enforcement of Russian decisions in third countries.
- Additional changes in derogation rules in very limited circumstances. (cultural policy organisations using frozen funds)
