On 23 July 2026, the Council of the European Union adopted the 21st package of restrictive measures against Russia and Belarus.
The measures are set out in several regulations and decisions accessible in the Official Journal here. The main restrictions are set out in Council Regulation (EU) 833/2014, as amended by Regulation (EU) 1848/2026 (the “Russia Regulation”), which is accessible here, and in Council Regulation (EU) 765/2006, as amended by Regulation (EU) 1846/2026 (the “Belarus Regulation”), which is accessible here.
Below, we have summarised some of the most significant new restrictions.
Further export restrictions are introduced on items and technologies used by the Russian military industry. These include additional types of metals and alloys used in the aerospace and defence sectors, such as certain metal powders, metal and alloys used in for coatings in jet-engines, and propellants. An export ban is also introduced on drone-related equipment, including ground support equipment and jamming/interception and launch systems.
For imports, a ban is introduced on a number of goods, such as certain metals and metal ores, including nickel lead, zinc as well as car parts, a number of glass products, including glassware and laboratory articles of glass, as well as imitation pearls.
The transaction ban is extended to cover an additional 33 Russian banks and financial institutions. In addition, a transaction ban is introduced against a Kyrgyz bank in connection with the SPFS (System for Transfer of Financial Messages) ban and three non-Russian banks are also listed for circumventing the sanctions.
Moreover, certain third countries entities, including banks, crypto firms or platforms, based in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan, and Belarus have been targeted.
The possibility of making a full ban on third-country crypto-assets service providers has been introduced. Not yet in practice, this new instrument will enable the EU to ban any transaction between an EU operator and any crypto provider used by Russia.
The existing oil price cap includes a built-in adjustment mechanism designed to follow market developments. However, due to the current situation in the Strait of Hormuz, the adjustment mechanism is suspended until 14 July 2027.
A major focus of this sanctions package is Russia’s export of Liquefied Natural Gas (“LNG”). The 21st sanctions package now introduces a temporary exemption to the prohibition on the purchase, import and transfer of LNG (CN code 2711 11 00) originating in or exported from Russia that has been in place since 25 April 2026. This prohibition shall not apply until 25 July 2027 to transfers of LNG to third countries carried out under long-term contracts concluded before 24 February 2022.
The exemption is capped at the total volume of Russian LNG transferred in 2025. EU operators transferring or purchasing Russian LNG for third countries must therefore report historical volumes to their competent authority by 25 August 2026 and per-shipment data every quarter thereafter.
The ban on providing LNG terminal services to Russian entities, introduced in the 20th package, has been clarified, so that indirect ownership/control is also covered. Hence, the ban covers terminal services to entities that are more than 50% owned or controlled, directly or indirectly, by a Russian citizen or a Russian entity regardless of where those entities are incorporated.
Finally, with effect from 25 January 2027, the regulation introduces a new framework enabling transaction bans on refineries in Russia and in third countries that process or refine Russian crude oil or petroleum products, or that are used to circumvent EU sanctions.
LNG is also the focus under the shipping-related provisions. Similar to the existing reporting obligations applying when selling tankers vessels, the newly inserted Article 3qa requires that EU sellers of LNG tanker vessels (CN code ex 8901 20) immediately notify the competent authorities of their Member State upon any sale or transfer of ownership to a third country.
Furthermore, following a Commission assessment due 25 October 2026, the Council may introduce a prohibition on EU persons selling or transferring ownership of LNG tanker vessels, directly or indirectly, to any person or entity in Russia or for use in Russia.
If such a prohibition enters into force, EU sellers of LNG tankers to third countries will be subject to due diligence obligations. Sellers must take appropriate measures to assess the risk of onward diversion to Russia and implement procedures to manage that risk effectively. Furthermore, the memorandum of agreement must contain a written prohibition on resale to Russia or for use in Russia (a “No Russia Clause”). The buyer must further commit to including a No Russia Clause in any future resale and to obliging all subsequent buyers to do the same.
An additional 41 vessels connected to the Russian shadow fleet have been listed, bringing the total number of sanctioned vessels to 673. Notably, for the first time, some of the listed vessels are not part of the Russian shadow fleet itself but are targeted for assisting it, for example by providing bunkering, tug and other services to designated vessels. Vessels carrying out ship-to-ship transfers with designated vessels may also now be listed.
Two new Russian ports have been added to the list of sanctioned ports. The port of Olya has been listed due to its use for the transfer of UAVs and missiles, and the port of Vysotsk due to its use for maritime transport of Russian crude oil and petroleum products. Access to these ports and any related services are now prohibited.
The Georgian Kulevi Oil Refinery is the first refinery listed under the new refinery transaction ban framework described under Energy above. All transactions with the refinery are prohibited from 25 January 2027. The refinery has been listed because it is used for the processing or refining of Russian crude oil and petroleum products and has been used to facilitate circumvention of EU sanctions.
The EU introduces the basis for a comprehensive visa ban for combatants and ex-combatants of the Russian armed forces and other proxy groups, participating in the Russian war of aggression in Ukraine.
Measures have also been introduced which seek to strengthen the legal protection for EU operators in litigation stemming from EU restrictive measures by allowing EU courts and member states to not recognise or enforce any court decision obtained in legal proceedings lodged in Russian courts.
Furthermore, the deadlines applicable to certain derogations needed for divestments from Russia have been extended to 21 December 2027. In this regard, it is also noteworthy that the recitals to Regulation (EU) 2026/1848, amending the Russia Regulation, encourage EU operators to take all possible steps to wind down their business activities in Russia and refrain from initiating new business activities there.
The Russian trade restrictions described above have generally been mirrored in the Belarusian sanctions regime.
Gorrissen Federspiel closely follows developments in export controls and sanctions. We can assist with interpretation of and compliance with applicable sanctions, as well as with the implementation of measures to ensure that sanctions are observed. If you have any questions, please feel free to contact a member of our Compliance or Shipping team.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel’s newsletters of 24 April 2026, 24 October 2025, 23 July 2025, 21 May 2025, 25 February 2025, 19 December 2024, 25 June 2024, 27 February 2024, 19 December 2023, 26 June 2023, 27 February 2023, 19 December 2022, 7 October 2022, 8 June 2022, 11 April 2022, 16 March 2022, 10 March 2022, 2 March 2022, 28 February 2022, and 24 February 2022.