Key takeaways
EU maritime services ban
The proposed maritime services ban on Russian crude oil and petroleum products will be coordinated with the G7.
Shadow fleet
An additional 46 vessels have been added to the list, making the total number of designated vessels 632.
Tanker sales
The sanctions introduce mandatory due diligence checks and a “no Russia” clause for sale contracts, as well as a shadow fleet scrapping clause.
On 23 April 2026, the European Council adopted the EU’s 20th package of sanctions against Russia. The EU Commission has welcomed the adoption of these latest restrictive measures, which are key to the EU’s ongoing efforts to pressure Russia into ending the war in Ukraine.
This latest package introduces 120 additional sanctions designations, including 33 individuals and 83 entities, who will be subject to an asset freeze and a prohibition on making funds and economic resources available to them. The individuals will also be subject to a travel ban.
Significantly for the maritime sector, however, the anticipated full maritime services ban on Russian crude oil and petroleum products did not form part of the agreed measures at this stage. There was no unanimity across the 27 Member States on implementing this prohibition, which would have prevented EU companies from providing any maritime-related service, such as insurance, shipping or port access, to vessels carrying Russian crude oil. It was agreed instead that such a ban would be introduced in due course in conjunction and coordination with the G7 and the price cap coalition.
We summarise below other key measures introduced by the 20th package, with a focus on those most relevant to the maritime sector.
Maritime and energy sector
Shadow fleet. An additional 46 vessels have been designated and now face a port access ban and a ban on the provision of a broad range of services related to maritime transport. These are vessels considered to be part of Russia’s shadow fleet. The total number of designated vessels is now 632.
Tanker sales. Mandatory due diligence checks have been introduced for the sale of tankers from the EU, as well as a mandatory ’no Russia’ clause for sale contracts. This is aimed at preventing Russian end-use and the expansion of the shadow fleet. There is also a shadow fleet scrapping clause aimed at encouraging the recycling of vessels and their exit from the shadow fleet.
Port infrastructure ban. The Russian ports of Murmansk and Tuapse, and the Indonesian port of Karimun Oil Terminal have been designated due to their connection with the shadow fleet and circumvention of the oil price cap.
Maintenance services. EU operators are prohibited from offering maintenance services to Russian LNG tankers and icebreakers.
LNG terminal services. EU operators may terminate any long-term contracts with Russian operators.
Energy listings. There are 36 listings extending to both the upstream and downstream parts of the Russian energy sector, including the exploration, extraction, refining, and transportation of oil.
Trade
There are new bans on export to Russia on a range of goods worth over €360 million, as well as export restrictions on items and technologies that can be used for Russia’s military actions.
There are new import bans on metals, chemicals and minerals worth over €530 million.
There is also a new quota on ammonia to cap imports, as well as a restriction on the provision of cybersecurity services to Russia.
Finance
Russian banks. 20 additional Russian banks have been added to the list of those with whom EU operators cannot do business except with regard to humanitarian transactions. There are now 70 Russian banks excluded from access to the EU market.
Third country financial operators. There is a transaction ban on four additional banks, in Kyrgyzstan, Laos, and Azerbaijan, assisting Russia in bypassing sanctions.
Russian crypto services and cryptocurrencies. There is a total 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. There is also a prohibition on using the cryptocurrency RUBx, a rouble backed stablecoin, as well the digital rouble, a digital currency being set up by the Central Bank of Russia to enable sanctions circumvention.
Payment services. There is a ban on transactions with agents in Russia and other third countries that offer to facilitate international transactions from Russia to bypass EU sanctions.
However, the Council did delist five third-country financial entities because they have committed not to engage in prohibited activities.
Anti-circumvention measures
The EU activated its “anti-circumvention tool” for the first time, making it clear that it would not overlook instances of EU sanctions being systematically circumvented by exporters in third countries that re export sanctioned EU goods to Russia. The EU activated its anti circumvention tool against the Krygzy Republic for its repeated and continuing failure to prevent the sale, supply, transfer, or export to Russia of high-risk items imported from the EU and used for the manufacturing of drones and missiles in Russia.
60 entities have been added to the list of those providing direct or indirect support to Russia's military industrial complex or engaged in sanctions circumvention.
There have already been calls to the UK foreign secretary from MPs and peers to similarly take action against institutions and individuals in the Krygzy Republic that are allegedly facilitating large-scale Russian sanctions evasion, including by hosting infrastructure that supports the cryptocurrency A7A5. A7A5 is sanctioned in the UK, EU and US and it is linked to the UK-sanctioned Russian bank Promsvyazbank. It is a stablecoin that is pegged to the rouble and is said to have facilitated more than $100bn in transactions.
Belarus
The latest sanctions also include measures against Belarus, including trade measures, measures on cryptocurrency and exchanges and restrictions on the provision of cybersecurity services.
Legal safeguards
The latest sanctions package introduces additional legal protection for EU firms against retaliatory actions by Russia in allowing Member State courts to fine Russians that launch abusive lawsuits before Russian Courts. The measures also allow EU firms to claim damages in case of enforcement of abusive judgments in third countries other than Russia and the EU Council can impose a transaction ban on third country firms and individuals cooperating with the enforcement of such actions.
Comment
It will be interesting to see if the UK introduces any new sanctions measures in tandem with the EU, including designating additional shadow fleet vessels, and what the UK’s position will be on bringing in the maritime services ban, which it has fully supported.
For advice on sanctions, explore our Sanctions practice and see how our team supports businesses and individuals navigate complex international compliance requirements while protecting against serious risks.
