Following a long delay, the 20th EU sanctions package against Russia was published on 23 April 2026, and EU sanctions against Belarus were amended accordingly. We outline the key changes and their implications below.
The 20th sanctions package also consists of several regulations and implementing regulations:
A total of 117 natural and legal persons have been newly added to Annex I of Regulation 269/2014. Pursuant to Article 2(1) of Regulation 269/2014, their assets within the EU are frozen. Pursuant to Article 2(2) of Regulation 269/2014, it is prohibited to make funds or economic resources available to, or for the benefit of, these persons, organisations and entities (POEs), whether directly or indirectly.
Oil price cap
Article 3n(6)(b) and (c) of Regulation 833/2014 are deleted.
The end of Article 3n(6) of Regulation 833/2014 now reads: On the basis of full consultation within the Council and taking into account the discussions within the Coalition for a Price Cap and the G7, the Council shall, on a joint proposal from the High Representative and the Commission, decide without delay on the application of the exemption from the prohibitions referred to in paragraphs 1 and 4 in respect of crude oil or petroleum products traded at prices below the price cap.
New listing of ports and vessels
The ports of Murmansk and Tuapse are now subject to a transaction ban under Article 5ae(1) of Regulation 833/2014 following their listing in Annex XLVII, Part A. The same applies to the Karimun oil terminal in Indonesia following its listing in Annex XLVII, Part C.
Furthermore, a further 46 vessels from the Russian shadow fleet have been listed in Annex XLII, whilst 11 vessels have been removed from the list. Pursuant to Article 3s of Regulation 833/2014, vessels listed in Annex XLII are, amongst other things, prohibited from entering EU ports. Furthermore, European companies may no longer offer, provide or accept from the operators of these vessels any services related to shipping.
Tankers, LNG bans
Article 3q(1) of Regulation 833/2014 now provides for a ban on the sale or other transfer of ownership, directly or indirectly, of tankers intended for the carriage of crude oil or petroleum products as defined in Annex XXV and classified under HS Code ex 8901 20, whether or not originating in the Union, to natural or legal persons in Russia or for use in Russia. Furthermore, nationals of a Member State, natural persons resident in a Member State and legal persons established in the Union who sell tankers for the transport of crude oil or petroleum products as listed in Annex XXV, classified under HS code ex 8901 20, sell them, directly or indirectly, to legal entities in a third country or otherwise transfer ownership thereof to such entities, irrespective of whether those products originate in the Union or not, in accordance with Article 3q(2) of Regulation 833/2014
(a) take appropriate steps, proportionate to the nature and scale of the risks, to identify and assess the risks associated with the export to Russia and the export for use in Russia of such goods or technologies, and ensure that these risk assessments are documented and kept up to date; and
b) implement appropriate strategies, controls and procedures, commensurate with their nature and scale, to mitigate and effectively manage the risks of re-export for use in Russia.
Pursuant to paragraph 4, sales of tankers to third countries are also subject to a reporting obligation, specifying the identity of the buyer and seller, and, where applicable, the incorporation documents of the seller and the buyer — including the ownership structure and management — as well as the IMO ship identification number and the call sign.
For the sale or any other agreement to transfer ownership of tankers for the carriage of crude oil or petroleum products as listed in Annex XXV, classified under HS Code ex 8901 20, to a third country, Article 3q( 5 of Regulation 833/2014, a written contractual prohibition on the resale or transfer of the vessel to natural or legal persons in Russia or for use in Russia is now required.
The prohibition on the purchase, import and transfer set out in Article 3m(1) and (2) of Regulation 833/2014 for Russian crude oil and petroleum products listed in Annex XXV, including the prohibition on the provision of technical assistance, brokering services, financing or financial assistance relating thereto, is extended by a new Article 3m(2a) from 1 January 2027 also extends to natural gas condensate originating from LNG production facilities with CN code 2709 00 10.
Likewise, the prohibitions under Article 3n(1) (technical assistance, brokering services, funds or financial assistance in connection with trade with third countries involving, or the brokering or transport to third countries of, crude oil and petroleum products listed in Annex XXV that originate in Russia or have been exported from Russia) and Article 3n(4) (prohibition on trading in, brokering or transporting to third countries crude oil falling within CN code 2709 00 or petroleum products falling within CN code 2710 listed in Annex XXV which originate in Russia or have been exported from Russia) pursuant to a new Article 3n(6c) of Regulation 833/2014 for natural gas condensate falling under CN subheading 2709 00 10, which originates from facilities for the production of liquefied natural gas.
Exceptions to the prohibitions in Article 3n(1) and (4) apply, inter alia, to crude oil and petroleum products listed in Annex XXV, provided that these goods originate in a third country and are merely loaded in Russia, depart from Russia or transit through Russia, provided that the goods are of non-Russian origin and are not owned by Russia.
The new Article 3rb of Regulation 833/2014 prohibits the provision, directly or indirectly, of LNG terminal services where the recipient is a natural or legal person in Russia or a legal person established in the Union that is more than 50% owned or controlled by a Russian citizen or a Russian legal person in Russia.
A newly inserted Article 3sa(1) of Regulation 833/2014 prohibits the direct or indirect provision of technical assistance, brokering services, funds or financial assistance in connection with icebreakers falling under CN code ex 8906 90 or LNG carriers falling under CN code ex 8901 20, if the vessel is registered under the Russian flag, is certified by the Russian Shipping Register, is owned or managed by Russian natural or legal persons, or is operated in Russia or intended for use in Russia.
Annex XIV to Regulation 833/2014 lists 20 additional Russian banks, which are therefore subject to the transaction ban under Article 5h(1) of Regulation 833/2014.
Annex XLV A and B list further credit and financial institutions established outside the Union, which are thus subject to the transaction ban under Article 5a of Regulation 833/2014. At the same time, five banks have been removed from Annex XLV Part A. A further listing relating to the transaction ban under Article 5ac of Regulation 833/2014 was included in Annex XLIV.
With regard to cryptocurrencies, the wording of the transaction ban in Article 5ba of Regulation 833/2014 has been extended to include digital central bank currencies and the support of the development of listed crypto-assets or digital central bank currencies. In addition, a further crypto-asset and the digital rouble have been listed in Annex LIII.
Article 5ad(1)(d) of Regulation 833/2014 now prohibits direct and indirect transactions with a legal entity established outside the Union that facilitate the execution of international transactions, including payments from accounts in countries other than Russia, netting, offsetting, reconciliation or settlement that frustrate the purpose of the prohibitions contained in Regulation 833/2014 or Regulation 269/2014 in accordance with Annex XLV, Part D of Regulation 833/2014. This is intended to prevent payment settlements via these listed payment agents.
A new Article 5ai of Regulation 833/2014 prohibits, directly or indirectly, transactions with a legal entity referred to in Article 11(1)(a), (b) or (c) of Regulation 833/2014, which – including through their activities in the same market sector – are subject to a decision pursuant to Decree of the President of the Russian Federation No. 302 of 25 April 2023, as amended, pursuant to Federal Law No. 470-FZ of 4 August 2023, as amended, or pursuant to related or equivalent Russian legislation as set out in Annex LIV. Annex LIV is currently empty.
The new Article 5aj(1) of Regulation 833/2014 prohibits, directly or indirectly, transactions with a natural or legal person listed in Annex LV, Part A, which seeks to enforce judgments for the satisfaction of claims pursuant to Article 11a(1) outside the Union or is involved in such enforcement, or with natural or legal persons who own or control such legal POEs, with the exception of lawyers and members of the judiciary.
Article 5aj(2) of Regulation 833/2014 prohibits, directly or indirectly, transactions with a natural or legal person or entity listed in Annex LV, Part B, which seeks to enforce decisions pursuant to Article 11b(1) outside the Union or is involved in such enforcement, or with natural or legal persons or entities who own or control such legal entities, with the exception of lawyers and members of the judiciary.
Annex LV has not yet been published.
Pursuant to Article 5sa of Regulation 833/2014, a transaction ban applies to legal entities listed in Annex LVI that are using or have used, without authorisation, intellectual property rights or trade secrets belonging to EU companies or Russian subsidiaries of such companies. Annex LVI is currently unlisted.
Extension of Annexes IV and VII to Regulation 833/2014
Following the extension of Part A, Categories VIII and IX, and Part B of Annex VII to Regulation 833/2014, laboratory glassware, hygienic or pharmaceutical glassware, including items with scales or calibration marks, are now also subject to the ban on sale, supply, transfer and export under Article 2a of Regulation 833/2014.
Further organisations have been added to Annex IV of Regulation 833/2014; these include, alongside Russian organisations, those from third countries such as Turkey, the UAE, China, Hong Kong and Thailand.
Since the 16th sanctions package, Article 2b of Regulation 833/2014 prohibits the direct or indirect sale, supply, transfer or export of dual-use goods and goods and technologies listed in Annex VII to natural or legal persons listed in Annex IV, as well as the provision of related ancillary services.
Extension of Annexes XXIII et al., amendment to Article 3k of Regulation 833/2014
Pursuant to Article 3k(1) of Regulation 833/2014, it is prohibited to sell, supply, transfer or export goods listed in Annex XXIII, whether or not originating in the EU, directly or indirectly to natural or legal persons in Russia or for use in Russia.
Annex XXIII has been expanded again to include, amongst other things, rubber and certain rubber goods, screws, bolts, nuts and certain tractors with an engine power exceeding 130 kW. Two entries have been deleted.
For goods listed in Annex XXIIIH, a grandfather clause applies to the fulfilment of contracts until 25 July 2026, provided they were concluded before 24 April 2026.
For goods falling under CN codes 3920431099, 3925 90 10, 3925908000 or 8302 41 50, which are strictly necessary for the sale of windows, an exemption may now be granted in accordance with the new Article 3k(5a)(g) of Regulation 833/2014, provided that these goods or the associated technical or financial assistance are required for personal use in the household by natural persons in Russia. The same applies to goods falling under CN codes 3916 20, provided they are strictly necessary for the sale of PVC floor coverings or windows.
In addition, a new Article 3k(1b) of Regulation 833/2014 has been inserted: Notwithstanding Article 3k(1) of Regulation 833/2014, it is hereby prohibited to export goods listed in Annex XXIII under CN codes 7304 11 00, 7304 19 10, 7304 19 30, 7304 19 90, 7304 22 00, 7304 23 00, 7304 29 10, 7304 29 30, 7304 29 90, 7305 11 00, 7305 12 00, 7305 19 00, 7305 20 00, 7306 11, 7306 19, 7306 21 00, 7306 29 00, 8207 13 00, 8207 19 10, 8413 50, 8413 60, 8413 82 00, 8413 92 00, 8430 49 00, 8431 39 00, 8431 43 00, 8431 49, 8705 20 00, 8905 20 00 or 8905 90 10, directly or indirectly, to natural or legal persons in Russia, including its exclusive economic zone and continental shelf, or for use in Russia, including its exclusive economic zone and continental shelf. The goods in question are primarily pipes and drilling equipment. The wording makes it clear that Russia’s exclusive economic zone (EEZ) and continental shelf are also expressly covered by these listed goods, and thus clearly targets offshore/marine applications. The ancillary service prohibitions under Article 3k(2) of Regulation 833/2014 have been extended accordingly.
The transit ban through Russia under Article 3k(1) of Regulation 833/2014 now also applies to goods falling under CN code 3403 (prepared lubricants (including cutting oils, preparations for loosening screws or bolts, prepared rust-preventive or anti-corrosive agents, and prepared mould and release oils, based on lubricants) and preparations of a kind used for the oil or grease treatment of textiles, leather, fur skins or other materials, excluding preparations containing 70% or more by weight of petroleum or oil from bituminous minerals as a basic component).
Article 3i(1) of Regulation 833/2014 prohibits the direct or indirect purchase, import into or transfer to the Union of goods listed in Annex XXI if they originate in Russia or are exported from Russia. Annex XXI has been expanded and now covers, among other things, further raw materials, metals and certain chemicals. For certain goods, a grandfathering provision applies to the fulfilment of contracts concluded before 24 April 2026 until 25 July 2026, Article 3i(3be) of Regulation 833/2014. For refined copper in its raw form (CN code 7403 19), a grandfathering provision applies to the fulfilment of contracts concluded before 24 April 2026 until 25 January 2027, Article 3i(3bf) of Regulation 833/2014. An import quota of 688,000 tonnes per year applies to ammonia.
For the first time, the EU is using the so-called instrument to combat circumvention practices in accordance with Article 12f of Regulation 833/2014 in conjunction with Annex XXXIII. It is now prohibited to supply machining centres for working metals (CN code 8457 10) and equipment for the reception, conversion and transmission or regeneration of sound, images or other data, including equipment for switching and routing (CN code 8517 62), to the Kyrgyz Republic.
The prohibition on the provision of non-ancillary services to the Russian Government and Russian legal entities in Article 5n(1) of Regulation 833/2014 is extended to include managed security services with effect from 25 May 2026.
The prohibition on the fulfilment of claims in connection with contracts affected by the restrictive measures also applies, pursuant to Article 11(1)(d) of Regulation 833/2014, to POEs in third countries that sell, supply, transfer or export EU-sanctioned goods, technologies or services to Russia.
Pursuant to a new Article 11ca of Regulation 833/2014, where a person referred to in Article 11(1)(a), (b) or (c) of Regulation 833/2014 is involved in proceedings before a Russian court in connection with contracts or transactions whose performance or execution has been affected, directly or indirectly, in whole or in part, by the measures imposed pursuant to Regulation 833/2014 or Regulation 269/2014, in breach of an exclusive jurisdiction clause or an arbitration clause or otherwise in accordance with Article 248.1 or Article 248.2 of the Code of Civil Procedure of the Russian Federation or equivalent Russian legislation, against a natural or legal person, entity or body referred to in Article 13 of Regulation 833/2014, with a view to obtaining a judicial decision, that natural or legal person, entity or body referred to in Article 13 of Regulation 833/2014 shall have the right to seek a court order in proceedings before the competent courts of a Member State confirming the exclusive jurisdiction clause or the arbitration clause and directing the opposing party not to seek legal proceedings or to discontinue such proceedings. Failure to comply with this court order shall result in financial penalties.
Regulation 765/2006 has also been amended accordingly, with further POE listed and the restrictions on goods and services extended.
Despite its considerable delay, the comprehensive 20th sanctions package shows that increasing sanctions pressure and restrictions on trade are still to be expected. Due to the complexity of the regulations, the requirements for internal corporate sanctions compliance are rising.
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