20th package of EU sanctions: EU reaction to Russian invasion of Ukraine (regularly updated)

Since the Russian invasion of Ukraine in February and March 2014 and the subsequent annexation of Crimea and Sevastopol to the Russian Federation (Russia) on 16 March 2014, declared illegal also by the UN General Assembly (UNGA/11493, 27 March 2014), the EU has adopted, under articles 29 of the TEU and 215 of the TFEU, a series of restrictive measures against persons and entities for their role in actions threatening the territorial integrity, sovereignty and independence of Ukraine[1].

Following Russia’s recognition of the Luhansk and Donetsk People’s Republics’ independence on 21 February 2022 and its further invasion of Ukraine on 24 February 2022, the EU adopted a first package of sanctions.

In view of the gravity of the situation and in response to Russia’s continued military aggression against Ukraine, the EU has adopted a series of new restrictive measures.

More than four years after Russia’s invasion and war of aggression against Ukraine, on April 23, 2026, the EU adopted its 20^th package of sanctions against Russia, as well as further measures against Belarus mirroring some of those adopted against Russia.

The following are among the main measures implemented to restrict Russia’s access to battlefield technologies and its ability to wage war, to protect EU operators, and to crack down on Russia’s shadow fleet, thus cutting Russian energy imports and fighting against sanctions circumvention:

20^th package of sanctions

Council Regulation (EU) 2026/506 of 23 April 2026 amending Regulation (EU) 833/2014, and Council Decision (CFSP) 2026/508 of 23 April 2026 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine:[2]

Military industry:

• Addition of 60 entities to the list, set out in Annex IV to Decision 2014/512/CFSP, of those directly supporting Russia’s military and industrial complex and subject to tighter export restrictions regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector, including:
  • Entities in third countries other than Russia (i.e., Türkiye, UAE, China, Hong Kong, Thailand) that indirectly contribute to Russia’s military and technological enhancement by circumventing export restrictions, including those on computer numerical controlled (CNC) machine tools, microelectronics, components for unmanned aerial vehicles, microelectronic products, maritime equipment, and components for other vehicles and machinery.
• Extension of the list of restricted items which might contribute to Russia’s military and technological enhancement or the development of its defence and security sector (Annex VII to Regulation (EU) 833/2014), including:
  • Laboratory glassware;
  • Certain high performance lubricants and their additives;
  • Energetic materials.

• Further restrictions on imports of goods which generate significant revenues for Russia—worth over €570 million—as listed in Annex XXI to Regulation (EU) 833/2014, including restrictions on certain raw materials, metals, certain minerals, on scrap of steel and other metals, on chemicals, on articles of vulcanised rubber and on tanned furskins.
• Broadening of the transit ban through Russia of certain goods and technologies (Annex XXXVII to Regulation (EU) 833/2014) to minimise the risk of circumvention of restrictive measures.
• Further restrictions on exports of goods which contribute to the enhancement of Russian industrial capabilities, such as chemicals, rubber and articles of vulcanised rubber, articles of steel, tools for metal production and industrial tractors (as listed in Annex XXIII to Regulation (EU) 833/2014).
• Expansion of the existing broadcasting prohibition to include sites which disseminate or facilitate the broadcasting of the same content as the prohibited entities, thus circumventing EU measures.

In accordance with the Charter of Fundamental Rights, this measure does not prevent the listed media outlets from carrying out other activities in the Union than broadcasting, such as research and interviews.

Energy-related measures:

• Introduction of a prohibition on providing liquified natural gas (LNG) terminal services to Russian entities or to entities owned or controlled by Russian nationals or operators. The relevant contracts for the LNG terminal services concerned are to terminate automatically on 1 January 2027.
• Introduction of a legal basis (Article 3n, end of paragraph 6 of Regulation (EU) 833/2014) for a future full ban on maritime services for Russian crude oil and petroleum products, to be implemented in coordination with the G7 and the Price Cap Coalition.

• Obligation for importers of polished diamonds, including diamonds polished in third countries, to provide a due-diligence statement confirming that the diamonds were not mined, processed or produced in Russia.
• New listing mechanism for Russian companies benefiting from “temporary management” (i.e. de facto expropriation of EU‑owned assets in Russia), which are made subject to a transaction ban.

Financial measures:

• Transaction ban extended to fourfinancial institutions that enable the performance of international transactions to Russian entities through mechanisms such as netting, set-off or settlement arrangements that avoid any actual transfer of funds across Russia’s borders (i.e., “payment agents”), and so circumventing EU sanctions, as listed in part D of the new Annex XLV to Regulation (EU) 833/2014 and with effect from 14 May 2026:
  • Arneis;
  • Asia Import Group;
  • GPAgent;
  • Platejka.
• Prohibition of any transaction involving crypto-assets and central bank digital currencies, as listed in Annex LIII to Regulation (EU) 833/2014 (i.e., A7A5, RUBx, Digital rouble), or providing support to the development of such projects.
• Expansion of the list of crypto-assets the use of which is prohibited in transactions (addition of RUBx), as those crypto-assets pose a risk of circumventing prohibitions.
• Total sectoral ban on providers and platforms established in Russia that allow the transfer and exchange of crypto assets.
• Addition of 20 Russian financial institutions to the list of entities subject to a transaction ban (Annex XIV to Regulation (EU) 833/2014), bringing the total to 70.

The transaction ban targets selected Russian credit and financial institutions—and certain related entities—that are significant to Russia’s financial system. This includes major and regional banks, entities facilitating cross‑border payments, institutions operating in or supporting activities in occupied Ukrainian territories, banks servicing Russian military personnel, and entities already subject to EU or partner‑country restrictive measures.

Addition of some exceptions for: the reception of payments due pursuant to obligations performed before 24 April 2026; the payment of reasonable professional fees or the reimbursement of incurred expenses associated with the provision of legal services; the needs of state-funded intermediate organisations for the foreign cultural policy of the Member States in Russia.

• Extension of the existing prohibition on the provision of certain services to the Russian Federation, now including managed security services (an exception is made for the functioning of a consular or diplomatic representation of Russia located in a Member State).
• Extension of the existing prohibition on the acceptance of financing, donations or any other economic benefits or support from Russia, to a broad range of actors (and associated persons) that carry out research and innovation action (as defined in Regulation (EU) 2021/695), including public and private research institutions, universities, NGOs, public bodies, and companies of all sizes.

Accepting Russian public funding may entail direct or indirect support to Russian actors, as it can involve the transfer of knowledge, access to infrastructure, training, and other activities carried out in the context of research and innovation, or be used for influence campaigns and the promotion of disinformation.

• It is clarified that reporting obligations concerning information which would facilitate the implementation of EU restrictive measures should encompass the duty to report about persons that engage in attempts at circumvention schemes, or on transactions deemed suspicious.

Protection of EU operators:

• Modification of the forum necessitatis clause to enable Union courts to issue orders not to initiate or to discontinue legal proceedings (before Russian courts relating to contracts affected by EU restrictive measures), and to impose penalties, upon request of Union persons.
• Extension of the forum necessitatis clause to remedy possible situations of denial of justice allowing a court of a Member State, on an exceptional basis, to rule on a claim for damages brought pursuant to Article 11ca of Regulation (EU) 833/2014.
• Introduction of the possibility for EU operators to seek damages against actors seeking to enforce claims related to sanction-affected contracts in third countries other than Russia.
• New listing mechanism for persons or entities seeking or involved in the enforcement outside the Union of judgments related to sanction‑affected contracts or unlawful expropriations, as well as on those who own or control them, which are subject to a transaction ban (as listed in Annex LV to Regulation (EU) 833/20214), with the exception of lawyers and members of the judiciary.

• Addition of 46 vessels to the list of vessels set out in Annex XLII to Regulation (EU) 833/2014 (bringing the total of Putin’s shadow fleet of oil tankers to 632 vessels), which are banned from Member States’ ports and locks, as well as from receiving a broad range of services related to maritime transport.
• Tighter conditions on the sale of tanker vessels for the transport of crude oil or petroleum products listed in Annex XXV to third‑country operators:
  • Mandatory contractual clause prohibiting resale or transfer to Russia or for use in Russia;
  • Proportionate due diligence—such as screening all parties.
• Prohibition to provide technical, financial or brokering support to ice‑breaker or LNG tanker vessels that are Russian‑flagged, certified, owned, managed, operated in, or intended for use in Russia.
• Extension of the prohibition on satisfying claims related to sanction-affected contracts to include claims brought by third‑country entities (other than Russia and partner countries listed in Annex VIII to Regulation (EU) 833/2014) involved in prohibited trade under Regulation (EU) 833/2014, whether or not originating in the Union.
• Transaction ban on entities incorporated under Russian law that use without their consent the intellectual property rights of subsidiaries incorporated in Russia of Union companies.
• First application of the anti-circumvention mechanism (Article 12f to Regulation (EU) 833/2014), extending controls against Kyrgyzstan. The listings contained in Annex XXXIII to Regulation (EU) 833/2014 concern:
  • Machining centres for working metal;
  • Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus.
• Addition of Liechtenstein to the list of partner countries for importation of petroleum products exempted from the obligation to provide evidence of the country of origin of the crude oil (as listed in Annex LI to Regulation (EU)833/2014).
• Addition of three ports and locks that are used for the circumvention of the oil price cap by vessels practicing irregular and high-risk shipping practices, and subject to a transaction ban, as listed in Part A—for ports and locks in Russia—and Part C—for ports and locks in third countries other than Russia—of Annex XLVII to Regulation (EU) 833/2014:
  • Murmansk and Tuapse (Russia);
  • Karimun Oil Terminal (Indonesia).

Council Regulation (EU) 2026/511 of 23 April 2026 amending Regulation (EU) 269/2014, Council Decision (CFSP) 2026/504 of 23 April 2026 amending Decision 2014/145/CFSP, and Council Implementing Regulation (EU) 2026/509 of 23 April 2026 implementing Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine:[3]

• Addition of 37 persons and 80 entities responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine to the list of persons, entities and bodies subject to restrictive measures set out in Annex I to Regulation (EU) No 269/2014.
• Extension of the listing criteria targeting the “shadow fleet”, withgrounds for designation now including persons, entities or bodies owning, controlling, managing or operating vessels involved in certain activities or that otherwise provide material, technical or financial support to the operations of such vessels.
• Extension of the prohibition on satisfying claims related to sanction-affected contracts to include claims brought by third‑country entities (other than Russia and partner countries listed in Annex VIII to Regulation (EU) 833/2014)
• Introduction of the possibility for EU operators to seek damages against actors seeking to enforce claims related to sanction-affected contracts in third countries other than Russia.

Additional derogations:

• From the asset freeze for the work of state-funded intermediators for the foreign cultural policy of the Member States in Russia;
• To enable the release of frozen funds solely for the payment of costs of arbitral proceedings awarded against a listed persons;
• To enable the release of frozen funds of certain entities to reduce dependence on Russian crude oil;

In response to Belarus’s involvement in Russia’s unprovoked invasion against Ukraine, the EU has introduced the following new measures.

11th package of sanctions

Council Decision (CFSP) 2026/512 of 23 April 2026 amending Decision 2012/642/CFSP, Council Regulation (EU) 2026/513 of 23 April 2026 amending Regulation (EC) 765/2006, Council Implementing Decision (CFSP) 2026/503 of 23 April 2026 implementing Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, and Council Implementing Regulation (EU) 2026/505 of 23 April 2026 implementing Article 8a(1) of Regulation (EC) 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine (further mirror Belarus’ measures with the ones imposed on Russia):[4]

• Extension of the list of restricted items which might contribute to Belarus’s military and technological enhancement or the development of its defence and security sector, by listing items which have been used by Russia in its war of aggression against Ukraine and items which contribute to the development or production of Belarus’s military systems, including:
  • Laboratory glassware;
  • Certain high performance lubricants and their additives;
• Further restrictions on exports of goods which contribute to the enhancement of Belarusian industrial capabilities, such as chemicals, rubber and articles of vulcanised rubber, articles of steel, tools for metal production and industrial tractors.
• Broadening of the transit ban through Belarus of certain goods and technologies (Annex Annex XIVa to Regulation (EC) 765/2006) to minimise the risk of circumvention of restrictive measures.
• Extension of the existing prohibition on the provision of certain servicesto Belarus, now including
  • Managed security services;
  • Services directly related to tourism activities.
• An exception from the requirement for prior authorisation for services provided to Belarus is made for the functioning of a consular or diplomatic representation of Belarus located in a Member State.
• Further import bans on goods which allow Belarus to diversify its sources of revenue, including on certain raw materials, metals, certain minerals, scrap of steel and other metals, chemicals, articles of vulcanised rubber and tanned furskins.
• Extension of the prohibition on satisfying claims linked to sanction‑affected contracts to third‑country claimants.
• Possibility for EU operators to claim damages against parties seeking to enforce Belarusian decisions abroad.
• Prohibition of any transaction involving a Belarusian central bank digital currencies, or providing support to the development of such projects.
• Total sectoral ban on providers and platforms established in Belarus that allow the transfer and exchange of crypto assets
• Strengthening of anti‑circumvention tools, including possible transaction bans on actors facilitating sanctions evasion
• Addition of three legal persons (including a Chinese state-owned entity) related to the Belarusian military-industrial complex and the Lukashenka regime to the list of persons, entities and bodies subject to restrictive measures set out in Annex I to Regulation (EC) 765/2006.

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[1] Council Decision 2014/145/CFSP of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 16–21; and

Council Regulation (EU) 269/2014 of 17 March 2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L 78, 17.3.2014, p. 6–15;

Council Decision 2014/512/CFSP of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine OJ L229, 31.7.2014, p. 13–17; and

Council Regulation (EU) 833/2014 of 31 July 2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L 229, 31.7.2014, p. 1–11.

[2] Council Regulation (EU) 2026/506 of 23 April 2026 amending Regulation (EU) 833/2014 concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L, 2026/506, 23.4.2026; and

Council Decision (CFSP) 2026/508 of 23 April 2026 amending Decision 2014/512/CFSP concerning restrictive measures in view of Russia’s actions destabilising the situation in Ukraine, OJ L, 2026/508, 23.4.2026.

[3] Council Regulation (EU) 2026/511 of 23 April 2026 amending Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2026/511, 23.4.2026;

Council Decision (CFSP) 2026/504 of 23 April 2026 amending Decision 2014/145/CFSP concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2026/504, 23.4.2026; and

Council Implementing Regulation (EU) 2026/509 of 23 April 2026 implementing Regulation (EU) 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine, OJ L, 2026/509, 23.4.2026.

[4] Council Decision (CFSP) 2026/512 of 23 April 2026 amending Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2026/512, 23.4.2026;

Council Regulation (EU) 2026/513 of 23 April 2026 amending Regulation (EC) 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2026/513, 23.4.2026;

Council Implementing Decision (CFSP) 2026/503 of 23 April 2026 implementing Decision 2012/642/CFSP concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2026/503, 23.4.2026; and

Council Implementing Regulation (EU) 2026/505 of 23 April 2026 implementing Article 8a(1) of Regulation (EC) 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine, OJ L, 2026/505, 23.4.2026.