The EU adopts its 20th sanctions package spanning energy, finance, trade, and new listings

On 23 April 2026, the EU adopted the 20th sanctions package. Originally anticipated to be adopted on the four-year mark of Russia's full-scale invasion of Ukraine, the package was delayed due to a veto exercised by Hungary and Slovakia.

As in all previous packages, the 20th sanctions package includes the designation of further individuals and entities subject to an asset freeze. This time, a total of 120 new individuals and entities has been targeted, focused in particular on the Russian military-industrial complex, but also including entities based in China (including Hong Kong), UAE, Uzbekistan, Kazakhstan, Türkiye, and Belarus. 

The new sanctions package combines extensions of existing prohibitions with entirely new prohibitions and mechanisms. Key examples of the amendments include, but are not limited to:

Sector-specific prohibitions targeting energy and maritime sectors

• 36 new listings (asset freeze) targeting both the upstream and downstream segments of the Russian energy sector, including exploration, extraction, refining, and transportation of oil.
• Introduction of a ban on the provision of maintenance and other services for Russian liquified natural gas (LNG) tankers and icebreakers, including transaction restrictions on specific ports and oil terminals in Russia.
• 46 vessels from the Russian shadow fleet have been added to the list of vessels subject to a port access ban and a prohibition on receiving a broad range of maritime services, bringing the total number of sanctioned vessels above 600. 11 vessels have been delisted.
• The shadow fleet oil price cap mechanism - introduced in earlier packages - has been further reinforced, and the groundwork has been laid for a potential future full maritime services ban on Russian crude oil and petroleum products, subject to a Council decision following G7 and Price Cap Coalition discussions.

Trade measures and services 

• The list of products subject to prohibitions on the sale, supply, transfer or export to Russia or for use in Russia is extended with further products, including e.g. chemicals, rubber, steel articles and metal production tools. 
• The list of products subject to prohibition on purchase, import or transfer from Russia is also extended, including metals, chemicals and minerals.
• A new transaction prohibition has been introduced targeting entities that have benefitted from, or operate in the same market sector as entities subject to, the Russian so-called "temporary management" decrees - i.e. the illegitimate expropriation of EU-owned assets in Russia. A separate transaction ban has also been introduced targeting entities that use intellectual property rights or trade secrets owned by EU operators without their consent pursuant to Russian legislation.
• Further, the service ban is extended to also include managed security services to Russian recipients, understood as services related to cybersecurity risk management, such as incident handling, penetration testing, security audits and consulting. This also applies to EU entities providing such services to Russian subsidiaries. 

Banking and finance

• A further 20 Russian banks are now subject to a transaction ban, bringing the total number of excluded banks to 70. Other third-country financial operators have also been listed, including banks in Kyrgyzstan, Laos, and Azerbaijan.
• Finance prohibitions also target cryptocurrencies and services (including Central Bank Digital Currencies/CBDCs), RUBx, a rouble-backed stablecoin, and the digital rouble currently under development, thus continuing the EU's targeted approach to the digital financial sector seen in earlier packages.

First-time activation of the anti-circumvention tool

• For the first time, the anti-circumvention tool has been activated, prohibiting the sale, supply, transfer or export of certain products - specifically machining centres (CN 8457 10) and data transmission apparatus (CN 8517 62) - to the Kyrgyz Republic.

• Further, 60 entities have been added to the list of entities identified as providing direct or indirect support to Russia's military industrial complex or engaged in sanctions circumvention. This includes 32 entities established in Russia and 28 in third countries (China, including Hong Kong, Türkiye, the UAE, and Thailand), a clear example of an extraterritoriality-inspired approach.

Continued focus on circumvention and third-country exposure

A recurring and increasingly prominent theme across the latest sanctions packages has been the EU's focus on sanctions circumvention through third-country intermediaries. The 20th package continues this trend, with new listings and enhanced restrictions targeting entities and individuals in a wide range of non-EU jurisdictions that are suspected of facilitating the evasion of EU sanctions. 

This also includes - as mentioned above - the first-ever activation of the so-called "anti-circumvention tool", prohibiting exports of certain products to the Kyrgyz Republic. In the recitals to the new sanctions package, the EU explicitly justifies this by the fact that imports of common high priority items to the Kyrgyz Republic were up 800% during the first ten months of 2025 compared to before Russia's war of aggression against Ukraine, with exports of common high priority items from the Kyrgyz Republic to Russia up by 1200% in the same period. 

Several of the prohibitions against Russia have also been mirrored towards Belarus. 

For Danish businesses, this reinforces the importance of conducting robust due diligence, including when trading outside of Russia, particularly where business is conducted in or through high-risk jurisdictions.

Need more information?

Read the official press release of the EU Commission.

The Danish Business Authority monitors sanctions developments. Read their newsletter on the 20th sanctions package (in Danish).

This newsletter is prepared for general information purposes only and does not constitute legal advice. Should you wish to discuss any of the topics covered or have questions specific to your business, please do not hesitate to contact one of our specialists.