On 23 July 2026, the EU adopted the 21st sanctions package against Russia and Belarus. With 218 individuals and entities newly added to the sanctions lists, this is the most extensive single round of designations since 2022. The package continues the approach set out in previous legislative acts: a consistent fight against circumvention, extension to actors from third countries, and enhanced legal protection for European companies.
The measures were implemented through several legal acts: Implementing Regulations (EU) 2026/1843 (implementing Regulation (EU) No 269/2014 – Russia) and (EU) 2026/1817 (implementing Regulation (EC) No 765/2006 – Belarus) for the listings themselves, as well as the amending Regulations (EU) 2026/1844 (amending Regulation (EU) No 269/2014 – Russia), (EU) 2026/1848 (amending Regulation (EU) No 833/2014 – Russia) and (EU) 2026/1846 (amending Regulation (EC) No 765/2006 – Belarus) for the substantive changes.
Key elements of the 21st sanctions package relate to the following areas:
■ Listings of individuals and entities (EU Designated Parties – EUDPs),
■ sanctions relating to the energy sector (oil, LNG, shadow fleet),
■ sanctions against the financial sector (transaction bans on banks and the crypto sector),
■ extension of product and end-user controls, and
■ enhanced legal protection for EU economic operators.
New designations of individuals and entities (EUDPs)
One of the key components of the 21st sanctions package is the EUDP designations (European Designated Parties). Pursuant to Article 3 of Regulation (EU) No 269/2014, Implementing Regulation (EU) 2026/1843 adds 48 individuals and 168 entities to Annex I of Regulation (EU) No 269/2014 concerning Russia; Implementing Regulation (EU) 2026/1817 imposes sanctions on two entities – the Mozyr Oil Refinery and the European Trading Company (ETK), a subsidiary of the Belarusian Oil Company – in Annex I to Regulation (EC) No 765/2006 against Belarus. Consequently, a total of 218 new EUDPs are listed. They are all subject to the freezing of funds and economic resources within the EU, as well as the prohibition on making funds available, in accordance with Article 2 of Regulation (EU) No 269/2014 and Article 2 of Regulation (EC) No 765/2006 respectively.
The 218 EUDPs must be distinguished from the – legally distinct – end-user lists (export controls), transaction prohibition lists (financial sector) and vessel lists under Regulation (EU) No 833/2014 and 765/2006 respectively; these are not included in the 218 and are presented separately in the sections on financial, energy and product controls.
The sanctioned EUDPs are primarily from the banking and financial sector. In total, around 94 Russian banks – representing roughly half of the Russian banking sector – are now sanctioned as EUDPs and are thus completely excluded from trade with the EU; for the first time, the Moscow Stock Exchange has also been designated as an EUDP. The remaining EUDP designations predominantly concern the defence and drone industry (of the 56 designations directly targeting the military-industrial complex, 37 relate to the entire production and supply chain for long-range drones), the oil and energy sector and shipping.
Once again, the EUDP sanctions imposed as part of the sanctions against Russia and Belarus are not limited to individuals and companies in the two sanctioned countries, but also extend to individuals and companies in other states. The vast majority of the 218 EUDPs are based in Russia (or in occupied Ukrainian territories) or Belarus. Only a small number of the newly listed entities are based in third countries – almost exclusively shipping and oil trading companies associated with the shadow fleet: United Arab Emirates (3), India (2), Oman (1), China (1) and Singapore (1); in addition, there is one natural person of Indian nationality (ship registration).
Regulation (EU) 2026/1844 introduces four narrowly defined exemptions from the asset freeze and the prohibition on making funds available, without affecting the listings themselves:
■ Insurance payments (Article 6b(5a) of Regulation (EU) No 269/2014): The competent authorities may unfreeze funds to enable sanctioned persons or entities (or an insurer) to pay compensation or insurance benefits arising from liability to injured parties in the EU, the EEA, Switzerland or a partner country. This exemption applies only to entities sanctioned under Article 3(1)(k) of Regulation (EU) No 269/2014 which have been sanctioned for their activities in connection with the Russian shadow fleet.
■ Legacy put option (Article 6b(5l) of Regulation (EU) No 269/2014): This exemption allows for the settlement of a put option that was contractually agreed and exercised prior to 28 February 2022 – and thus prior to the listing. It was created to enable a credit institution established in the EU, acting as the counterparty, to execute a put option, even if this nominally results in a payment (the shares in question remain frozen) to the Alfa Group founders Petr Aven (entry 674) and Mikhail Fridman (entry 675), or to Alfa-Bank JSC (entry 198) and the AlfaStrakhovanie Group (entry 270).
■ Rail transport (Article 6g of Regulation (EU) No 269/2014): Exempted are funds and resources of JSC Russian Railways, insofar as they are necessary for the provision of rail transport of goods or passengers, or the associated infrastructure, between Russia and the Union, through the Union, between the Kaliningrad region and Russia, or within Russia, as well as for related maintenance and safety services.
■ Paks II nuclear power project (Article 6h of Regulation (EU) No 269/2014): Exemption for three newly listed equipment manufacturers (UZTM KARTEKS, Uralmashplant JSC, P.G. Korobkov IZ-KARTEX LLC), insofar as the funds are strictly necessary for the Hungarian Paks II project and nuclear safety; subject to reporting obligations via the competent Hungarian authority.
LNG. Under the previous legal framework, the 19th sanctions package had imposed a ban on the purchase, import and transfer of Russian LNG – including to third countries. The 21st package enshrines this ban in Article 3ra of Regulation (EU) No 833/2014 and supplements it with a temporary exemption for long-term existing contracts (concluded before 24 February 2022), the supply of which to third countries is capped at the volume supplied in 2025. This relaxation stems from concerns raised by Greece, whose shipping fleet operates specialised Arctic tankers for Russia. Another new provision is the ban on LNG terminal services (Article 3rb of Regulation (EU) No 833/2014), which will apply from 1 January 2027. Furthermore, the same due diligence obligations are introduced with regard to the sale of LNG carriers to third countries as those that have applied since the 20th sanctions package have applied to oil tankers pursuant to Article 3q of Regulation (EU) No 833/2014, although the introduction of a ban on the sale of LNG tankers to Russian buyers is subject to a decision by the Council of the EU (Article 3qa of Regulation (EU) No 833/2014).
Oil price cap. The import of Russian crude oil and Russian crude oil products remains, in principle, prohibited under Article 3m of Regulation (EU) No 833/2014. However, the oil price cap, which restricts the provision of services relating to trade in crude oil with third countries, has been set at a fixed level. Decision (CFSP) 2025/1495 had introduced a mechanism for the regular, market-price-based adjustment of the price cap on Russian crude oil. The 21st package suspends this automatic adjustment – from 24 July 2026 to 14 July 2027 (Article 3n(11a) of Regulation (EU) No 833/2014) – so that the cap (USD 44 per barrel) remains frozen for one year, rather than being automatically adjusted. For the Sakhalin-2 project, the exemptions for oil and LNG shipments to Japan and the Republic of Korea respectively are extended until 31 March 2028 (Annex XXIX to Regulation (EU) No 833/2014).
Shadow fleet. Until now, vessels could be designated for engaging in irregular practices, primarily due to the transport of Russian oil. The 21st package lists, via Article 3s of Regulation (EU) No 833/2014 41 further vessels in Annex XLII (entries 652–692) and, for the first time, explicitly extends the listing criteria to service providers who support shadow fleet vessels – for example, through bunkering or towing services – or carry out ship-to-ship transhipments with them (Article 3s(2)(h) and (i) of Regulation (EU) No 833/2014). In addition, a transaction ban is introduced in respect of certain refineries, whereby a refinery in a third country (Kulevi Oil Refinery, Georgia) as well as other ports and airports – including Moscow’s Sheremetyevo Airport – are subject to a transaction ban (Article 5ae of Regulation (EU) No 833/2014, Annex XLVII, Parts A, B and D).
In addition to the EUDP listings, the package imposes further transaction bans, which are set out in various annexes to Regulation (EU) No 833/2014:
■ Annex XIV (total ban on transactions with Russian credit and financial institutions): 33 additional Russian banks have been added (Article 5h of Regulation (EU) No 833/2014).
■ Annex XLIV (third-country credit and financial institutions): one institution is removed (Yelo Bank/Azerbaijan – following the submission of commitments) and one is newly added (CJSC Eco-Islamic Bank/Kyrgyzstan) (Article 5ac of Regulation (EU) No 833/2014).
■ Annex XLV (circumvention actors established outside the Union): 17 entries in Part A (financial/crypto-asset service providers and payment services, including the A7 network, Sberbank India and VTB India) and 5 entries in Part C (third-country organisations circumventing the prohibitions under Articles 3m, 3n and 3s) (Article 5ad of Regulation (EU) No 833/2014).
Crypto sector. The package specifically targets the A7 network, which is used for circumvention, and the associated rouble-pegged stablecoin A7A5. For the first time, the possibility is created to designate not only individual providers but entire third countries and to prohibit transactions with crypto service providers and platforms established there (Article 5bc of Regulation (EU) No 833/2014, Annex LVII). The ban on Russian ownership or control is also extended to all crypto service providers within the meaning of the MiCA Regulation (EU) 2023/1114 (Art. 5b(2a) of Regulation (EU) No 833/2014).
On the export side, the list of goods is expanded to include items with military applications, including nickel and beryllium powders, self-adhesive films for aerospace use, and goods specifically intended for unmanned aerial vehicles such as launch systems, servo motors, ground equipment and flight termination systems (Article 3k of Regulation (EU) No 833/2014, Annex VII) . 51 organisations are listed as end-users in Annex IV – alongside Russia (24, one of which is in the occupied territory of Ukraine), these are primarily from China (10), Hong Kong (4), Turkey (4), Kyrgyzstan (3), India (2), the UAE (2) and Kazakhstan (2). Applications for authorisation in which these persons are listed as end-users must be rejected by the competent authorities.
On the import side, new purchase and import bans are introduced for, amongst other things, copper, nickel, lead and precious metal ores, zinc in its raw form, alkaline-earth metals, zinc and chromium oxides, tall oil, glassware and car parts (Article 3i of Regulation (EU) No 833/2014, Annex XXI). For certain goods, transitional periods apply for the fulfilment of existing contracts until 25 October 2026.
Russian retaliatory measures – in particular legal proceedings before Russian courts under Art. 248.1/248.2 of the Russian Arbitration Code, which hold EU companies liable and whose judgments are in some cases enforced in third countries – had already prompted the EU legislator to expand legal protection in the 20th sanctions package. At that time, measures were introduced including the creation of a legal basis for anti-suit injunctions against abusive Russian proceedings, the extension of the ‘no-claims’ clause to certain third-country actors, and the introduction of claims for damages against actors enforcing Russian legal claims.
The 21st package further extends this protection: the right to compensation under Article 11a of Regulation (EU) No 833/2014 and Article 11a of Regulation (EU) No 269/2014 is being extended so that affected parties can claim compensation, including legal costs, before Member State courts for direct and indirect losses arising from third-country claims. The 21st sanctions package extends the right to compensation against third-country persons who assert claims against persons and companies in third countries subject to EU sanctions, which do not in fact exist as a result of the EU sanctions against Belarus and Russia. A new or strengthened obligation is imposed on Member States to not recognise or enforce judgements and decisions of Russian courts or authorities in connection with contracts affected by sanctions (Article 11c of Regulation (EU) No 833/2014; now also, for the first time, as a standalone Article 11c of Regulation (EU) No 269/2014). In addition, EU courts may order the discontinuance of abusive proceedings and require that they not be enforced in any jurisdiction (Article 11ca of Regulation (EU) No 833/2014).
In addition, numerous deadlines for an orderly withdrawal from Russia – withdrawal of investments, winding up of joint ventures and onward sales – have been extended until 31 December 2027 (Articles 5aa, 11(4) and 12b of Regulation (EU) No 833/2014).
The measures relating to Russia are largely mirrored in relation to Belarus via Regulation (EU) 2026/1846: four new end-user listings in Annex V (CHIP UND DIP LLC, OJSC Rogachev Plant Diaprojector, DISPLAY DESIGN BUREAU JSC, CJSC Hull Products Plant), the same restrictions on goods and imports (Article 1ra of Regulation (EC) No 765/2006, Annex XXVII), the extension of the crypto ban to MiCA service providers (Article 1u of Regulation (EC) No 765/2006) and extended legal protection (Article 8h of Regulation (EC) No 765/2006). In addition, Belarus – as in the case of the Mozyr Oil Refinery – remains on its own list.
As early as 24 July 2026 – one day after the package was adopted – China added 14 European entities to its own end-user list under Chinese export control law, as an immediate retaliation for the listing of 14 Chinese and Hong Kong-based companies. Chinese companies are no longer permitted to supply dual-use goods to the affected EU companies – reported to include, amongst others, Tatra Trucks (CZ), Lafert SpA (IT), Sindlhauser Materials (DE) and Cavok UAS (FR). The trade conflict surrounding the Russia sanctions is thus spreading to third countries.
The 21st package confirms the familiar trends: an increasingly global reach with a focus on circumvention networks in third countries, a behaviour-based approach with targeted new listings and the removal of compliant entities from the list, as well as creative new instruments – ranging from the naming of countries in the crypto sector to the possibility of seizing cargo on shadow fleet vessels.
Recommendation for action: Companies with links to Russia or Belarus should consistently update their sanctions screening and third-party due diligence – particularly along supply chains and with business partners in third countries – consistently update their sanctions screening and third-party due diligence, incorporate the new end-user and vessel listings as well as the expanded transaction bans into their compliance processes, and at the same time examine the new options for legal protection. In view of the Chinese countermeasures, it is also advisable to assess the potential impact of third-country export controls. Your contacts
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