The EU is preparing its 20th sanctions package

As in previous years, the EU is preparing a new sanctions package to be adopted around the anniversary of the full-scale Russian invasion of Ukraine. 

The final content and details of the 20th sanctions package still remain subject to Council negotiations and adoption; however, President von der Leyen's statement in a recent press release reveals in broad terms what EU companies can expect.

Below are highlighted the expected key elements of the proposed package and some initial take-aways for areas requiring attention by Danish businesses.

Energy and maritime sanctions

The EU Commission proposes a full ban on maritime services linked to transporting Russian crude oil, with the aim of further reducing Russia's oil revenues and complicate sales and logistics. The Commission has indicated that this should be coordinated with G7 partners given the global nature of shipping and related services.

The proposal further includes the addition of 43 more vessels linked to Russia's "shadow fleet" (bringing the total to 640).

Finally, the proposal adds comprehensive prohibitions on maintenance and other services for LNG tankers and icebreakers, intended to curtail Russian LNG export projects.

Companies providing shipping, brokering, technical management, crewing, marine insurance, classification-related support, port agency services, and maritime services should anticipate increased compliance obligations, expanded screening requirements, and heightened risk of exposure through indirect service provision via counterparties.

Financial sanctions

The Commission proposes listing 20 more Russian regional banks and targeting banks in third countries suspected of facilitating sanctions evasion or trade in sanctioned goods.

The proposal also includes measures against crypto, entities trading crypto and platforms facilitating crypto transactions, explicitly framed as closing circumvention routes.

Companies conducting business in Russia or neighbouring jurisdictions should closely monitor whether any banks involved in daily transactions are newly designated, e.g. by reassessing (i) payment routing and settlement chains; (ii) counterparty bank screening, including regional Russian banks; and (iii) crypto-related exposure.

Trade measures

The proposal introduces tightened export restrictions through new bans on goods and services "from rubber to tractors and cybersecurity services".

Additionally, the Commission proposes new import bans on metals, chemicals and critical minerals not yet under sanctions, and imposes a quota on ammonia to cap existing imports.

Further, export restrictions are proposed for items and technologies used for Russia's battlefield effort, including materials used to produce explosives.

Exporters and importers should map exposure across product classification (CN codes) and end-use and end-user controls. Consistent with previous developments, more scrutiny on "dual-use adjacent" items and indirect routes via third countries is to be expected.

First-ever activation of the EU “anti-circumvention tool” 

A notable and novel step in the proposal is the Commission's plan to activate the EU anti-circumvention tool for the first time through the prohibition of exports of CNC (computer numerical control) machines and radios to jurisdictions considered high-risk for re-export to Russia.

While the exact design has yet to be revealed, businesses using distributors/resellers outside the EU should expect to consider, inter alia, distributor due diligence and diversion/red flag monitoring. 

Proposed legal safeguards for EU companies: IP and expropriation risk

The Commission proposes "stronger legal safeguards" to protect EU companies from intellectual property rights violations or unfair expropriation in Russia, referencing abusive court rulings connected to sanctions.

While the precise scope of these safeguards remains to be clarified, they may be particularly relevant for companies with legacy assets, trademarks, licences, or technology footprints in Russia.

What’s next?

EU Member States are expected to commence discussions on 9 February 2026. The timing of adoption will depend on the outcome of negotiations; however, based on prior practice, the package is expected to be adopted around 23–24 February 2026, coinciding with the anniversary of the Russian full-scale invasion of Ukraine.

Need more information?

Read the statement by President von der Leyen on the 20th package of sanctions against Russia