On 23 July 2026, the EU adopted its 21st package of sanctions against Russia. With 216 new individual listings – 48 natural persons and 168 organisations in Annex I to Regulation (EU) No 269/2014 (Regulation 269/2014) – this represents the largest number of new listings in the past four years.
Further measures target the Russian financial and energy sectors, the circumvention of sanctions via third countries, and the Russian shadow fleet. At the same time, sanctions against Belarus have also been tightened.
The following article outlines the key changes for you.
New listings in Annex I to Regulation 269/2014
216 persons, organisations and entities have been newly listed in Annex I to Regulation 269/2014. In accordance with Article 2(1) of Regulation 269/2014, their assets within the EU are frozen. Under Article 2(2) of Regulation 269/2014, it is prohibited to make funds or economic resources available, directly or indirectly, to these persons, organisations and entities (POEs), or to allow them to benefit from such funds or resources.
Of particular significance is the fact that this list includes 94 Russian banks and financial institutions.
New exemptions
Regulation (EU) 2026/1844 has introduced new exemptions to Regulation (EU) No 269/2014:
Notwithstanding Article 2 of Regulation 269/2014, pursuant to Article 6b(5ea), the competent authorities of a Member State may, subject to conditions they deem appropriate, authorise the release or making available of certain frozen funds or economic resources belonging to the natural or legal persons or entities (POEs) listed in Annex I pursuant to Article 3(1)(k) in Annex I, to those natural or legal persons or entities in respect of certain insurance payments.
Under Article 6b(5l) of Regulation (EU) No 269/2014, by way of derogation from Article 2, the competent authorities of a Member State may, subject to conditions they deem appropriate, authorise the release or making available of certain frozen funds or economic resources belonging to the natural or legal persons listed in Annex I under the heading ‘Persons’ in entries 674 (Petr Olegovich Aven) and 675 (Mikhail Maratovich Fridman) in the ‘Persons’ section of Annex I:
(a) the sale or transfer of shares by a credit institution established in the Union pursuant to a put option contractually agreed before 28 February 2022, provided that the shares remain frozen;
b) the release of frozen funds to fulfil payment obligations arising from such put options towards EU credit institutions.
Pursuant to Article 6g(1) and (2), the freezing order and the prohibition on making funds available shall not apply to funds or economic resources of JSC Russian Railways (Russian Railways) which are necessary for the provision of rail transport of goods or passengers between Russia and the Union, through the Union, between the Kaliningrad region and Russia, or within Russia, including the associated rail infrastructure and services.
Under Article 6h(1), Article 2 does not apply to funds or economic resources of the organisations listed in Annex I under the heading ‘Entities’ in entries 975 (UK UZTM KARTEX LLC), 976 (Uralmashplant JSC) and 977 (P.G. Korobkov IZ-KARTEX LLC), provided that these are strictly necessary for the Paks II project for activities relating to civil nuclear capacity. Under Article 6h(2), there is an obligation to notify the competent Hungarian authority within two weeks.
Banks, financial services and crypto-assets
Transaction ban under Article 5h(1) of Regulation 833/2014
New listings
The transaction ban under Article 5h(1) of Regulation 833/2014 is extended to include a further 33 Russian credit and financial institutions, which will be added to Annex XIV of Regulation (EU) No 833/2014 with effect from 13 August 2026.
Exemptions
In the case of legal persons, organisations or entities (POE), the competent authorities of a Member State may, subject to conditions they deem appropriate in accordance with Article 5h(3) of Regulation (EU) No 833/2014, authorise transactions that are strictly necessary withdraw funds or close accounts owned or held by a national of an EU Member State, a country belonging to the EEA or Switzerland, or by a natural person holding a temporary or permanent residence permit in one of those states, provided that
(a) the transaction is necessary to enable the natural person in question to terminate business dealings, contracts or other agreements with a legal POE listed in Annex XIV,
(b) the authorisation is applied for no later than three months after the date of commencement specified in Annex XIV for the relevant legal person listed therein,
(c) the funds are transferred to a financial or credit institution established or registered under the law of an EU Member State, or to a financial or credit institution established under the law of a third country which is owned or controlled by a financial or credit institution established or registered under the law of a Member State.
Transaction prohibitions under Article 5ac of Regulation (EU) No 833/2014
New listings
The Kyrgyz bank (CJSC Eco-Islamic Bank) was added to Annex XLIV due to its connection to the Russian payment system SPFS and is therefore subject to the transaction ban under Article 5ac(2) of Regulation 833/2014. The Azerbaijani Yelo Bank, on the other hand, has been removed from this Annex.
Further new credit and financial institutions established outside the EU have been added to Annex XLV and are therefore subject to the transaction ban under Article 5ac(1) of Regulation (EU) No 833/2014 with effect from 13 or 23 August 2026.
Exception
The new Article 5ac(8) of Regulation 833/2014 contains an exception mirroring that in Article 5h(3) of Regulation 833/2014.
Amendment to Article 5b(2a) of Regulation (EU) No 833/2014
Under the revised version of Article 5b(2a) of Regulation 833/2014, it is prohibited, from 25 to be owners of, control or hold management positions in organisations established under the law of a Member State, where the organisation provides crypto-asset services within the meaning of Regulation (EU) 2023/1114; previously, the ban was limited to services relating to crypto-wallets, accounts and custody.
Prohibition on transactions with crypto-asset service providers and platforms in third countries, Article 5bc of Regulation 833/2014
Under the new Article 5bc(1) of Regulation 833/2014, it is prohibited to carry out, directly or indirectly, transactions with a legal person established in a third country listed in Annex LVII, organisation or entity established in a third country listed in Annex LVII, where that entity is an organisation providing crypto-asset services or a platform facilitating the exchange or transfer of crypto-assets.
However, Annex LVII is currently empty.
Oil price cap
The Council is suspending the automatic adjustment of the oil price cap mechanism. Pursuant to the newly inserted Article 3n(11a) of Regulation 833/2014, the procedure for amending the crude oil price cap – including the calculation of the average market price over a period of 22 weeks and the amendment of Annex XXVIII – is suspended from 24 July 2026 to 14 July 2027; from 15 July 2027, the original procedure will resume. The Commission must determine an updated average price for Russian crude oil by 15 January 2027 and submit it to the Council.
New provisions in Article 3m of Regulation 833/2014
Article 3m of Regulation 833/2014 contains prohibitions on the purchase, import and transfer of Russian crude oil and Russian petroleum products.
A new Article 3m(11) has been inserted, which allows the competent authorities to authorise such transactions on an exceptional basis if the petroleum products in question have previously been seized or confiscated by the authorities of a Member State.
New listings in Annex XLV and new transaction ban under Article 5ae(2a) and (2b) of Regulation 833/2014
Five oil traders have been newly listed in Part C of Annex XLV for circumventing the ban on the purchase of Russian crude oil and petroleum products and are therefore subject to the transaction ban under Article 5ad(1)(c) of Regulation 833/2014.
The newly inserted paragraph 2a of Article 5ae of Regulation (EU) No 833/2014 provides for a ban on transactions with refineries in Russia and in third countries that process Russian crude oil or Russian petroleum products or are used to circumvent the sanctions; this also covers access to the facilities and the provision of services. The refineries concerned are listed in the new Annex XLVII, Part D.
The first entry is the Georgian Kulevi Oil Refinery, for which the ban – following an assessment by the Commission to be carried out by 25 October 2026 – in accordance with Article 5ae(2b) of Regulation (EU) No 833/2014, from 25 January 2027.
Liquefied natural gas (LNG)
The newly inserted Article 3qa of Regulation 833/2014 provides for a reporting obligation for the sale of LNG tankers falling under CN code ex 8901 20 to third countries. Any sale or other transfer of ownership must be reported to the competent authority without delay, specifying the seller and buyer, the IMO ship identification number and the call sign. The seller has a duty of care to identify and mitigate the risk of the vessel being diverted to Russia; a contractual prohibition on resale to Russian persons or for use in Russia is mandatory, and the purchaser must also incorporate this prohibition into any subsequent contracts. On the basis of a Commission assessment, the Council shall review by 25 October 2026 whether a complete ban on sales pursuant to Article 3qa(4) to (9) should enter into force; the relevant historical sales volumes must be reported by 25 August 2026. Pursuant to paragraphs 4–9, from the date set by the Council in accordance with Article 3qa(10), it is prohibited to sell, directly or indirectly, LNG carriers falling under CN code ex 8901 20 to POEs in Russia or for use in Russia, or to otherwise transfer ownership thereof. In the case of sales or other transfers of ownership of such LNG tankers to purchasers in third countries, appropriate steps must be taken to identify and assess the risk of onward transfer to Russia or for use in Russia, and appropriate strategies, controls and procedures must be implemented to mitigate and effectively manage these risks.
Purchasers must provide all information necessary for the aforementioned risk identification and assessment. The risk assessment must take into account all relevant information available at the time of the sale or transfer.
Any sale or other transfer of ownership to a third country must include a written contractual prohibition preventing the resale or further transfer of the vessel to persons, organisations or entities in Russia or for use in Russia.
Furthermore, the contract must oblige the purchaser from the third country to pass on and comply with this prohibition in the event of subsequent resales or transfers, and to contractually bind subsequent purchasers to equivalent obligations (so-called ‘obligation to pass on’ along the chain of ownership).
The prohibition on the provision of LNG terminal services to Russian persons is set out in Article 3rb of Regulation (EU) No 833/2014 and applies from 1 January 2027.
Shadow fleet
The package lists a further 41 vessels belonging to the shadow fleet in Annex XLII.
In accordance with 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 use services relating to shipping from the operators of these vessels.
The new Article 3s(2)(h) of Regulation 833/2014 extends the listing criteria to vessels that provide services such as bunkering and towing to vessels already on the list. The new Article 3s(2)(i) of Regulation 833/2014 covers ship-to-ship transhipments involving listed ships. On this basis, vessels used exclusively for providing services were also listed for the first time, such as the bunkering and towing vessels KUMANA, BILAL BEY, BEBEK-E, LADY JASMINE and OCEAN FORTUNE 18.
The transaction ban under Article 5ae of Regulation 833/2014 has been extended to two Russian ports and four Russian airports:
In Annex XLVII, Part A (Ports and locks in Russia), the port of Olya and the port of Vysotsk are added with effect from 24 July 2026.
In Annex XLVII, Part B (Airports), Sheremetyevo Airport, Ulyanovsk-Vostochny Airport, Rostov-on-Don Platov Airport and Mineralnye Vody Airport will be listed with effect from 24 July 2026.
Export ban under Article 2a of Regulation (EU) No 833/2014, extension of Annex VII
The package extends Annex VII to Regulation 833/2014.
Newly covered are nickel powder, nickel metal and nickel alloys with a nickel purity of at least 50 per cent by weight for corrosion-resistant coatings on jet engines (Item X.C.IX.019) and beryllium powder with a purity of at least 50 per cent by weight for propellants and high-performance alloys (Item X.C.IX.020).
Also included are self-adhesive sheets, films, tapes and strips for the aerospace and defence industries with a maximum operating temperature above 140 °C and a minimum operating temperature below minus 40 °C, which, in accordance with ASTM E595, have a total mass loss (TML) of no more than 1.0 per cent and a collected volatile condensable material (CVCM) content of no more than 0.10 per cent (Item X.C.IX.018).
Specific aeronautical equipment for unmanned aerial vehicles is covered: servo motors with a torque-to-weight ratio of at least 0.16 (Item X.A.VII.004), launchers for UAVs (Item X.A.VII.005), ground support equipment for UAVs (Item X.A.VII.006) and systems for terminating flight, including encrypted operating modes and specially designed components (Item X.A.VII.007); the associated user software is controlled by Item X.D.VII.003. In addition, radio frequency systems and equipment are included which are designed or modified to control UAVs or to deliberately jam, blocking or jamming radio frequency signals used for UAV control (Item X.A.III.101(j)).
Extension to Annex IV
A further 51 organisations have been added to Annex IV of Regulation 833/2014. This also includes organisations in third countries, amongst others in China (including Hong Kong), India, Kazakhstan, Kyrgyzstan, Turkey and the United Arab Emirates.
When deciding on applications for authorisations pursuant to Article 2(4) and (5) and Article 2a(4) and (5) of Regulation 833/2014, no authorisation shall be granted if the end-user is listed in Annex IV.
Furthermore, Article 2b of Regulation (EU) No 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, organization or entities (POEs) listed in Annex IV, as well as the provision of related ancillary services.
To further restrict Russia’s sources of revenue, additional goods have been included in Annex XXI to Regulation 833/2014. These include, amongst others, copper ores and their concentrates (CN code 2603), nickel ores and their concentrates (2604), lead ores and their concentrates (2607), and precious metal ores and their concentrates (2616). These are joined by zinc oxide and zinc peroxide (2817), chromium oxides and hydroxides (2819), tall oil (3803) and zinc in its unwrought form (7901). The glass sector is also comprehensively covered by CN codes 7001, 7002, 7003, 7004, 7006, 7008, 7009, 7011, 7013, 7014, 7015, 7016, 7017, 7018 and 7020, ranging from cullet and glass mass to insulating glazing and mirrors, right through to glassware, glass beads and laboratory glassware. Finally, car bodies for motor vehicles falling under headings 8701 to 8705 (CN code 8707), as well as parts and accessories therefor (8708), are included. With regard to goods falling under CN codes 2603, 2604, 2607, 2616, 2817, 2819, 3803, 7001, 7002, 7003, 7004, 7006, 7008, 7009, 7011, 7013, 7014, 7015, 7016, 7017, 7018, 7020, 7901, 8707 and 8708, the prohibitions set out in Article 3i(1) and (2) of Regulation 833/2014 shall not apply until 25 October 2026 to the performance of existing contracts concluded before 24 July 2026, or to ancillary contracts necessary for their performance.
Under the amended Article 11a(1) of Regulation 833/2014, affected persons may claim damages, including legal costs, before the courts of the Member States for any direct or indirect loss caused to them by Russian POEs or other POEs within the meaning of Article 11 (1)(a), (b), (c) or (d) of Regulation 833/2014 or in connection with sanctioned contracts or transactions before courts in third countries, provided that the person concerned does not have effective access to legal remedies in the relevant jurisdiction.
Such compensation may be claimed from POEs referred to in Article 11(1)(a), (b), (c) or (d) of Regulation 833/2014, which have brought their claims before courts in the third country, or by their owners or controlling POEs.
Under the revised Article 11c(1) of Regulation 833/2014, judicial decisions made pursuant to or in conjunction with Article 248.1 or Article 248.2 of the Russian Arbitration Procedure Code (unfortunately, the German version of Article 11c still refers to the ‘Arbitration Rules’, even though they concern Russian state commercial courts and not arbitral tribunals) of the Russian Federation or by a Russian court under other Russian legal provisions, and which relate to sanctioned contracts, shall not be recognised, enforced or executed in any Member State.
In addition, the revised Article 11ca provides for the possibility of obtaining injunctions against abusive Russian proceedings, the non-compliance with which is subject to proportionate financial penalties in favour of the aggrieved EU person.
Exception regarding prohibited tourism services
For tourism services prohibited under Article 5n(2) of Regulation (EU) No 833/2014, the newly inserted Article 5n(2a) of Regulation (EU) No 833/2014 provides for a specific exemption: The prohibition on the provision of services does not apply to the provision of a computerised reservation system within the meaning of Regulation (EC) No 80/2009.
Exception to ensure internet infrastructure
Under the revised version of Article 2(4)(e) and Article 2a(4)(e) of Regulation 833/2014, civilian electronic communications networks that do not belong to an organisation under public control or in which the public holds more than a 50 per cent stake are covered. In addition, pursuant to the amended Article 3k(5g), authorise the export and transfer of goods listed in Annex XXIII under CN codes 8517 62 and 8523 52 for such civilian networks.
Exceptions for certain research institutions
For certain research institutions, the newly inserted Article 5t(3a) of Regulation (EU) No 833/2014 creates a strictly limited exemption from the ban on accepting funding and grants from Russia, namely for the European X-ray laser project (EuXFEL), the Facility for Antiproton and Ion Research in Europe (FAIR) and the European Synchrotron Radiation Facility (ESRF), provided that the grants are based on international agreements with the Government of the Russian Federation.
Extension of the deadlines for divestment – exemptions
The deadlines for divestment exemptions have been extended: pursuant to the amended Articles 11(4), 5aa(3) and 12b of Regulation (EU) No 833/2014, the competent authorities may authorise certain transactions that are strictly necessary for the orderly withdrawal of investments from Russia until 31 December 2027.
Regulation (EU) No 2026/1846 amending Regulation (EC) No 765/2006 (Regulation 765/2006) has also amended the sanctions provisions against Belarus.
In the trade sector, import bans are being introduced on goods used by Belarus to diversify its sources of revenue, including copper, nickel, lead and precious metal ores, zinc, zinc oxides, chromium oxides, tall oil, glassware and car parts; the relevant CN codes (2603, 2604, 2607, 2616, 2817, 2819, 3803, 7001 to 7020, 7901, as well as 8707 and 8708) have been included in Annex XXVII to Regulation 765/2006 and are therefore subject to the import ban into the EU pursuant to Article 1ra of Regulation 765/2006. A transitional arrangement applies to existing contracts concluded before 24 July 2026 until 25 October 2026 (Article 1ra(9f) of Regulation 765/2006).
The export bans have been extended to cover goods related to the defence industry – including nickel and beryllium powders, UAV components and radio frequency systems – through their inclusion in Annex Va, Part A of Regulation (EC) No 765/2006.
Four new organisations have been added to Annex V, including CHIP UND DIP LLC and OJSC Rogachev Plant Diaprojector.
The cryptocurrency regulations have also been aligned with the sanctions regulations concerning Russia: Pursuant to Article 1u(3) of Regulation (EC) No 765/2006, the ban on the provision of services will be extended from 25 August 2026 to cover all crypto-asset services within the meaning of Regulation (EU) 2023/1114 (MiCAR).
Finally, Articles 8h and 11 of Regulation 765/2006 also provide for an extended right to damages against claims by Belarusian claimants and the non-recognition of Belarusian judgments in connection with sanctioned contracts.
The inclusion of third-country banks, crypto-platforms and refineries, as well as suppliers to the military-industrial complex in China, India, Turkey and other countries, demonstrates that the EU is increasingly aligning its sanctions architecture with actual circumvention routes. For affected companies, this – as is also the case with the further measures, including the many newly listed Russian banks and financial institutions – means a further increase in compliance costs.
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