On 23 April 2026, the 20th EU sanctions package was adopted, imposing numerous restrictions relating to 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) 2026/506 (the “Russia Regulation”), which is accessible here, and in Council Regulation (EU) 765/2006, as amended by Regulation (EU) 2026/513 (the “Belarus Regulation”), which is accessible here.
Below, we have summarised some of the most significant new restrictions.
Export restrictions to Russia have been tightened with new bans on goods and services, from rubber to tractors and various iron or steel articles such as screws, bolts, and hooks, as listed in Annex XXIII. Annex VII to the Russia Regulation has also been amended to include products such as explosives, lubricants and laboratory glassware – which are now subject to export restrictions. Only narrow exceptions apply, for example in cases of export for non-military use and for non-military end-users intended for health emergencies, events likely to seriously impact human health, safety, or the environment, or as a response to natural disasters.
New import bans have been introduced on metals, chemicals, and critical minerals, including copper, nickel, aluminium, salt, and specific types of silicones.This wide range of new products comprised by the export and import restrictions requires Danish (and other EU) companies to ensure that products being exported or imported are not comprised by the new product categories added to the annexes of the Russia Regulation. It should be noted that certain transitional rules apply to contracts concluded before 24 April 2026.
For certain products new transit prohibitions have also been adopted restricting transit of certain products through Russia.
Danish (and other EU) companies with subsidiaries in Russia should take note of the new cyber security service prohibitions.”Managed security services” has been added to the service prohibition in article 5n of the Russia Regulation. The prohibition on making such services available in Russia (without a license) will apply from 25 May 2026.
This means that Danish (and other EU companies) providing such services to subsidiaries in Russia must ensure that the provision of such services is covered by a software and service licence under article 5n.
“Managed security services” is defined as “a service provided to a third party consisting of carrying out, or providing assistance for, activities relating to cybersecurity risk management, such as incident handling, penetration testing, security audits and consulting, including expert advice, related to technical support”.
In addition, an already existing licensing option for the export of cyber security products has been tightened. Until now, it was possible for the competent authorities to authorise the export of dual-use products and technology, such as relevant cyber security products, for non-military use and non-military end-users when it was intended to ensure cyber security for persons, entities and bodies in Russia, except for its government or government-controlled entities. Instead, member states may now only authorise such sale, supply, transfer, or export, as well as related technical or financial assistance for non-military use and non-military end-users, when this is intended to ensure cyber security and information security for entities and bodies in Russia that are owned or solely or jointly controlled by an EU-incorporated entity.
The 20th sanctions package also includes certain provisions for the purpose of creating stronger legal safeguards for EU companies, including in order to protect them from violations of their IP rights or from unfair expropriation in Russia due to abusive court rulings in connection with sanctions, unfair expropriation in Russia, and abusive lawsuits before Russian courts .
From 1 January 2027, the prohibition on purchasing, importing or transferring crude oil or petroleum products originating in or exported from Russia – including the provision of technical assistance, brokering services, financing, financial assistance or any other services related to the trading, brokering or transportation thereof – will also apply to natural gas condensate from LNG production plants.
The regulation also introduces the possibility of a full ban on the provision of maritime services related to Russian crude oil and petroleum products, to be triggered by a Council decision on the price-cap exception. Such a ban would further reduce Russia’s energy revenues and make it more difficult to find buyers for its oil.
Currently, the price-cap exception still applies to the trade, brokering or transport of – including the provision of technical or financial assistance related to – crude oil or petroleum products originating in or exported from Russia to third countries. However, the regulation stipulates that the Council shall, on the basis of G7/Price Cap Coalition coordination, decide without undue delay on the application of the price-cap exception, with the result that a full ban on maritime services related to Russian crude oil and petroleum products could enter into force. Consequently, the Council will decide when the maritime services ban enters into force, considering an appropriate wind-down period. This would further reduce the total available capacity to transport Russian oil.
The regulation also introduces a ban on providing “LNG terminal services” (i.e. services provided by LNG system operators to customers) to Russian entities. The ban will be effective from 1 January 2027, from which point it will also be prohibited to maintain existing contracts concerning prohibited LNG services.
As a reminder the 19th sanctions package prohibits, as of 25 April 2026, the purchase, import or transfer of LNG (CN code 2711 11 00) if it originates in or is exported from Russia
The 20th sanctions package imposes further restrictions targeting the Russian shadow fleet. 46 vessels have been added to the shadow fleet, while 11 vessels have been removed, bringing the total to 632. However, the regulation introduces the possibility for Member States to authorise access to ports, anchorage zones and locks, as well as the provision of technical assistance and other services (including bunkering, ship supply, crew changes, cargo loading and discharge, fendering and tug services) for vessels of the Russian shadow fleet, provided that the vessel is intended to be recycled and the services are necessary for the vessel to proceed to the recycling facility, for any relevant activities of the recycling facility, or for payments related to the recycling.
It remains prohibited to sell or transfer ownership of tankers (directly or indirectly) to Russian entities or for use in Russia. Similarly, it is still required that the sale of a tanker be notified to the competent authorities.
However, this restriction has been tightened as it is no longer possible for the competent authorities in Europe to authorise the sale of tankers to a Russian person or for use in Russia. This was previously possible, provided that there were no reasonable grounds to believe that the tanker in question would be used to transport, or be re-exported to transport, certain crude oil or petroleum products originating in or exported from Russia for import or for transport to third countries at a purchase price per barrel above the price cap.
Furthermore, when selling tankers the seller must now ensure that they comply with the broadened due diligence obligations and new contracting obligations.
When it comes to due diligence, it has for a long time followed from the FAQ that the seller should carry out the necessary due diligence to establish whether the buyer is a Russian person or the buyer would use the vessel in Russia. However, it now follows directly from the regulation that the seller shall also take appropriate steps to identify and assess the risk of the vessel being retransferred to Russia or used in Russia. The risk assessments shall furthermore be documented and kept up to date. Besides widening the due diligence task, it appears that a seller of a tanker now also has an ongoing obligation to monitor what happens with the buyer and/or the vessel.
To comply with the due diligence requirements, the 20th sanctions package introduces an obligation for tanker owners to implement appropriate policies, controls and procedures to mitigate and manage the risk of the vessel being retransferred to Russia or used in Russia.
When it comes to the new contractual obligations, a seller of a tanker will be required to ensure that the memorandum of agreement contains a written contractual prohibition on further resale or transfer to Russia or for use in Russia (a “No Russia Clause”). Further, the seller must ensure that the buyer undertakes to include a similar No Russia Clause in any future resale/retransfer agreement, and that any future buyers include a No Russia Clause in their future resale/retransfer agreements.
The regulation also introduces a ban on providing technical assistance, brokering services, financing or financial assistance related to LNG tankers (CN code ex 8901 20) and ice-breaker vessels (CN code ex 8906 90), complementing the ban on LNG imports agreed under the 19th package and the RepowerEU Regulation.
For ice-breaker vessels, the ban is effective immediately.
In relation to LNG tankers, it is relevant to distinguish between vessels that are Russian owned/flagged or vessels that are in (or intended for) operation in Russia. For LNG tankers registered, certified, owned or managed in Russia or by Russian entities, the ban is effective from 25 April 2026. For other LNG tankers operating or intended for use in Russia, the ban is effective from 1 January 2027. A carve-out applies for vessels in emergency situations, natural disasters, etc.
Three new ports have been added to the list of ports with which transactions are prohibited: Murmansk (Russia), Tuapse (Russia) (with certain types of goods excepted) and – for the first time, a third-country port – the Karimun Oil Terminal (Indonesia), due to their connections with the shadow fleet and involvement in circumvention of the oil price cap.
20 more Russian regional banks have been listed in relation to the existing full transaction ban with certain Russian banks. Any transaction with these banks or any entity whose proprietary rights are directly or indirectly owned for more than 50% by these banks is prohibited from 14 May 2026. Four banks in Kyrgyzstan, Laos, and Azerbaijan assisting Russia in frustrating the sanctions have also been targeted. Danish (and other EU) companies doing business related to Russia should ensure that they are not transacting business with any banks comprised by the new listing.
The restrictions related to crypto currencies and crypto services have been further tightened. The 20th package includes a total sectorial ban on carrying out exchanges with any Russian crypto asset service provider as well as any decentralised platforms enabling crypto trading because of their use in circumvention as well as prohibitions on the use of (and support to) the cryptocurrency RUBx, a rouble‑backed stablecoin, as well as the digital rouble, a digital currency under development by the Central Bank of Russia.
To avoid sanctions evasion, the anti-circumvention tool has been activated for the first time, by introducing a prohibition to sell, supply, transfer, or export any computer numerical control machines and radios to Kyrgyzstan where there is a high risk that these products are re-exported to Russia.
The 20th sanctions package also includes several expansions of and clarifications to existing prohibitions, including:
Certain of the abovementioned measures towards Russia have been mirrored in the updated Belarus sanctions regulation (Regulation 765/2006). This includes the trade measures, legal protection, measures on crypto, and the provision of cyber security services.
Additionally, a ban on providing services directly related to tourism activities in Belarus has been introduced. Services directly related to tourism activities cover travel agency and tour operator services, tourist guide services, and related advertising services.
A total of 120 persons and entities have been listed under the 20th sanctions package. This is the largest number of listings in a single package in two years. All are subject to asset freezes. Of these, 117 are listed under the Russian sanctions regime, comprising 37 individuals and 80 entities responsible for actions undermining Ukraine’s territorial integrity, sovereignty, and independence. The remaining three entities are listed under the Belarusian sanctions regime and are connected to the Belarusian military and industrial complex and the Lukashenka regime.
Gorrissen Federspiel closely follows the developments of export controls and sanctions, and we can assist with interpretation of and compliance with applicable sanctions as well as 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 & Sustainability team.
For more information on the previous EU sanctions packages, please see Gorrissen Federspiel’s newsletters of 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.