EU adopts 21st package of sanctions against Russia

Article28.07.20267 mins read

Key takeaways

EU’s 21st sanctions package

Introduces highest number of designations in four years.

Shadow fleet

41 vessels listed in addition to the 632 already designated.

Oil price mechanism

Automatic adjustment paused until 15 July 2027.

On 23 July 2026, the EU Council adopted the 21st package of restrictive measures against Russia in response to the Ukraine/Russia war.

This latest package imposes the highest number of sanctions designations in the four years since the invasion of Ukraine, introducing 218 new listings that include 48 individuals and 170 entities.

The latest sanctions follow on from an announcement on 13 July 2026 that the UK and the EU had agreed their first joint cyber sanctions package that targeted 24 individuals and entities said to be behind cybercrime linked to the Russian Intelligence Service. This action was taken, in part, as a result of the cyber attack on Poland’s energy grid in December 2025 that the UK and EU have attributed to Russia’s Federal Security Service.

In this article, we summarise the key developments regarding the 21st package, with a particular focus on those of greatest interest to the maritime industry.

Maritime and energy

41 vessels in the shadow fleet have been designated, in addition to the 632 already listed. The latest measures target non-EU tankers that form part of the shadow fleet and that are circumventing the oil price cap mechanism or are transporting military equipment or stolen Ukrainian grain.

The EU has also designated one individual and eight entities active in the shadow fleet network, including companies operating on behalf of Russia’s oil majors. For the first time, a crewing agency providing support to the shadow fleet has also been designated.

The EU has paused the automatic adjustment of the oil price cap mechanism until 15 July 2027 in order to limit Russia's profits from oil sales, notwithstanding the negative effect that the closure of the Strait of Hormuz has had on the market. The EU plans an interim review of the suspension to make sure that the mechanism remains necessary and proportionate.

There is now also a notification obligation for the sales of LNG tankers and the possibility of introducing new restrictions on the sale of LNG tankers to Russian citizens and companies. Furthermore, the EU has introduced other contractual obligations to mitigate the risk of reselling to Russia or for use in Russia.

The EU has targeted 18 entities and one individual in the oil sector, including three Russian refineries, a Belarusian oil refinery, as well as a company created to sell Belarusian petroleum products within Russia.

Under the latest package, there is the possibility to prohibit transactions with listed refineries in Russia and in third countries which process or refine Russian crude oil and petroleum products. As part of that framework, the EU is imposing a transaction ban that will enter into force in six months on a Georgian refinery trading and processing Russian oil in Kulevi.

The EU has also added five oil traders to the entities subject to a transaction ban for frustrating the prohibition on purchasing Russian crude oil and petroleum products.

Trade

The existing export ban has been extended to include a number of items and technologies used by Russia's military industry.

There are also further restrictions on the import of goods that generate revenues for Russia of over €60 million, such as copper ores, nickel ores, lead ores and precious-metal ores etc.

Measures have also been imposed on Belarus that are intended to mirror those imposed on Russia; in particular, trade measures (import bans on goods generating significant revenue for Belarus as well as export restrictions related to the military industry) and legal protection.

Financial services and crypto

There are new asset freezes and a prohibition to make funds available to 94 banks and major financial institutions and one individual from Russia’s banking establishment. The transaction ban is extended to 33 additional Russian credit and financial institutions, as well as against a Kyrgyz bank connected with the SPFS (System for Transfer of Financial Messages) and three other non-Russian banks for circumventing sanctions.

The EU has also added four designations related to the cross-border A7 network, including its new links to Africa. It is also extending the transaction ban to 14 crypto-related service platforms based in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan and Belarus.

For the first time, the EU has introduced the possibility of a full third-country ban for crypto-asset services in order to deter countries hosting platforms that help Russia evade EU sanctions. This new instrument is intended to enable the EU to ban any transaction between an EU operator and any crypto provider used by Russia.

Legal protection for litigators

The EU has strengthened the legal protection for EU operators in litigation stemming from EU restrictive measures by allowing EU courts and member states not to recognise or enforce any court decision that was obtained in legal proceedings lodged in Russian courts.

Other measures

There are further sanctions targeting persons and companies involved in Russia’s military industrial complex. There are also additional entities subject to tighter export restrictions on dual-use goods and technologies. These include entities located in third countries (including the UAE, Turkey, China and India).

Comment

It remains to be seen what approach the UK’s new Prime Minister and Foreign Secretary will take to the introduction of further sanctions against Russia. However, both have so far been vocal in their support for Ukraine and indications are that they will maintain the stance taken by their predecessors.

Our Sanctions team advises on complex, multi-jurisdictional sanctions issues. Please get in touch to discuss how we can support you.

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