June 2026 Blog

New sanctions against Russia: Further listings of individuals, organisations and entities

On 15 June 2026, new sanctions against Russia were published, apparently as an anticipated part of the 21st sanctions package, and existing EU Regulations were amended accordingly.

The package contains new listings of persons, organisations and entities under several existing EU sanctions regimes, with a focus on energy, disinformation, the military-industrial complex and human rights violations, as well as a specific temporary derogation in relation to the listed Chinese company Yangzhou Yangjie Electronic Technology Co., Ltd.

In detail
 

Legal bases

The package is based on the following legal acts:

  • Implementing Regulation (EU) 2026/1356 implementing Regulation (EU) 2024/2642,
  • Implementing Regulation (EU) 2026/1361 implementing Regulation (EU) No 269/2014,
  • Implementing Regulation (EU) 2026/1362 implementing Regulation (EU) 2024/1485,
  • Regulation (EU) 2026/1336 amending Regulation (EU) No 269/2014.

Content

In total, 81 new listings of natural and legal persons and entities were made.

New listings in Regulation (EU) No 269/2014

By virtue of the amendments, a further 54 natural and legal persons and entities were included in Annex I to Regulation (EU) No 269/2014.

The new listings concern, in particular, actors supporting the Russian conduct of war and its financing, as well as the Russian military-industrial complex in the areas of mechanical engineering, armaments, aerospace, electronics, logistics and other areas relevant to the Russian war economy.

In addition, further listings were made in connection with the Russian shadow fleet. Covered are, inter alia, operators of selected vessels as well as insurance brokers in the field of marine insurance.

For the persons, organisations and entities listed pursuant to Regulation (EU) No 269/2014, the following applies in particular:

Pursuant to Article 2(1) of Regulation (EU) No 269/2014, all funds and economic resources belonging to, owned, held or controlled by the natural or legal persons, entities or bodies listed in Annex I shall be frozen.

Pursuant to Article 2(2) of Regulation (EU) No 269/2014, no funds or economic resources shall be made available, directly or indirectly, to or for the benefit of the natural or legal persons, entities or bodies listed in Annex I.

New listings in Regulation (EU) 2024/2642

The new listings in Regulation (EU) 2024/2642 concern ten natural persons and one entity.

Covered are, in particular, actors to whom propaganda, coordinated information manipulation, interference or other activities are attributed which may undermine or threaten democratic processes, the rule of law, stability or security in the European Union, its Member States or third countries.

New listings in Regulation (EU) 2024/1485

Fifteen natural persons and one entity were included in the sanctions regime under Regulation (EU) 2024/1485. This regime concerns restrictive measures in view of the situation in Russia and is directed against those responsible for serious human rights violations, the repression of civil society and democratic opposition, as well as the undermining of democracy and the rule of law in Russia.

The new listings are connected, in particular, with the poisoning of Alexei Navalny.

Temporary derogation for Yangzhou Yangjie Electronic Technology Co., Ltd. 

Regulation (EU) 2026/1336 introduces new temporary authorisation possibilities for derogations from the obligation to freeze funds or economic resources and from the prohibition on making funds or economic resources available in respect of Yangzhou Yangjie Electronic Technology Co., Ltd., listed under entry No 692 in Annex I, by inserting a new Article 6b(5l) into Regulation (EU) No 269/2014.

Accordingly, the competent national authorities may authorise, under such conditions as they deem appropriate, the following:

a) Winding-down of existing business relationships:

The release of frozen funds or economic resources or the making available of funds or economic resources to Yangzhou Yangjie Electronic Technology Co., Ltd. may be authorised, provided that this is strictly necessary for the termination of operations, contracts or other agreements concluded before 23 April 2026.

A prerequisite is that the release or making available is completed by 31 December 2026.

b) Industrial purchases of critical components:

An authorisation may also be granted for industrial purchases of critical components manufactured by Yangzhou Yangjie Electronic Technology Co., Ltd., including related payments, in order to enable a transition to alternative sources of supply. In this case, the release or making available of funds or economic resources must be completed by 16 March 2027.

Pursuant to recital 3 of Regulation (EU) 2026/1336, the economic operators concerned are expressly expected to establish and implement appropriate diversification plans before the expiry of the respective derogation in order to enable a transition to alternative sources of supply. The derogations therefore serve exclusively to manage the transition, and not the permanent maintenance of existing business relationships.

Outlook

Further goods-related parts of the 21st sanctions package have already been prepared, so that a significant tightening of goods-related sanctions and, in particular, amendments to Regulation (EU) No 833/2014 can likely also be expected in the near future.

Anastassiya Malkova
Rechtsanwältin

Nils Baumann
Wissenschaftlicher Mitarbeiter

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