EU’s 21st Sanctions Package Against Russia: What Companies Need to Know Now

On 23 July 2026, the Council of the European Union adopted the 21st sanctions package against Russia. Regulation (EU) 2026/1848 once again comprehensively amends Regulation (EU) No. 833/2014 (the Russia Embargo Regulation). For internationally active companies, the package brings far-reaching new compliance obligations—though also a limited number of relief measures. This briefing provides an overview of the key changes.

Key Changes Under the 21st Sanctions Package

Energy and Oil Sanctions

The energy sector remains—alongside the banking sector—at the center of the new sanctions measures. Notably, the automatic adjustment mechanism for the oil price cap has been suspended until 15 July 2027. Special reporting obligations now apply to sales of LNG tankers to Russian entities under Article 3qa of the Russia Embargo Regulation. Based on the reported information, the EU may impose further measures, including outright sales prohibitions, in the fall of 2026.

Certain exemptions are now available for prohibitions on LNG transfers. These exemptions are capped at the annual volume transferred in the 2025 calendar year. Accordingly, thorough documentation by affected companies is essential.

Banking Sector and Crypto Assets

Transaction prohibitions now extend to additional Russian credit and financial institutions as well as banks in third countries. Furthermore, crypto-related platforms based in third countries have been sanctioned. This systematically cuts off alternative payment channels that Russia has used to circumvent the embargo.

Import and Export Restrictions

Annex VII to the Russia Embargo Regulation (the controlled goods list) has been expanded to include additional equipment, particularly for unmanned aerial vehicles (UAVs). These goods are now subject to prohibitions on sale, supply, transfer, export, and delivery. In addition, the import restrictions under Article 3i of the Russia Embargo Regulation have been supplemented.

Divestment Exemptions (Russia Exit)

The deadlines for utilizing divestment exemptions have been extended until 31 December 2026. This is particularly relevant for the wind-down of joint ventures.

Additional Sanctions Listings

A further 218 persons, organizations, and entities have been designated. In addition, Russia’s shadow fleet as well as refineries, ports, and airports have been listed, with corresponding transaction prohibitions. The increasing designation of, for example, third-country banks and crypto platforms underscores that economic actors outside of Russia are also becoming sanctions targets.

How Should Companies Respond?

The EU has once again confirmed its commitment to maintaining the embargo regime despite political disagreements. Trade compliance therefore remains an ongoing process that requires continuous adaptation to the evolving regulatory landscape. We recommend the following measures for companies with international trade exposure:

• Update sanctions screening tools: The new goods lists must be incorporated into sanctions list screening systems without delay.
• Review contracts and business relationships: Existing contractual relationships must be assessed for compliance with the new sanctions.
• Update internal compliance programs: Policies and standard operating procedures should be revised as necessary.
• Expand red flag indicators: Red flag indicators should be enhanced, particularly with respect to payment channels and the handling of crypto assets.
• Strengthen KYC/KYT practices: A robust know-your-customer and know-your-transaction framework is more important than ever to adequately respond to the designation of third-country companies, organizations, and entities.
• Verify transport routes and logistics partners: The use of any ports, airports, or vessels appearing on sanctions lists must be strictly excluded.
• Execute Russia exit: Companies should urgently take all legally available steps to wind down their business activities in Russia and refrain from entering into any new business there.

Please do not hesitate to contact us—we are happy to advise you on all matters relating to trade and customs law.