Main elements of the 20th sanctions package
Sectoral sanctions
The list of goods subject to expanded export and transit restrictions has been broadened
The new sanctions package includes additional goods whose export to Russia or transit through Russia is prohibited, as they can be used to support the enhancement of Russia’s military and technological capabilities.
The export ban will apply to goods such as natural and synthetic rubber, iron or steel screws, and other cast iron or steel articles, etc.
First-time application of an export ban on goods to third countries
Observing a rapid increase in trade flows of high-priority goods in certain neighbouring countries of Russia, which may indicate sanctions circumvention through the use of import or export bans, a regulatory framework was introduced prohibiting the export of goods to third countries.
With the adoption of the 20th sanctions package, for the first time within this framework, specific goods have been designated that are prohibited for export to a particular third country.
Going forward, it is prohibited to export to the Kyrgyz Republic goods under CN code 8457 10 (multi-purpose machine tools for working metal) and CN code 8517 62 (machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus), taking into account the potential risk of re-export to Russia.
Within this restriction, additional goods and third countries may be added in the future, where the export of such goods would also be prohibited.
New import bans
The list of goods prohibited for import from Russia has been expanded, as these goods generate significant revenue for Russia, thereby enabling it to carry out activities that destabilize the situation in Ukraine.
Under the new sanctions package, the import ban will apply to goods such as salt, pebbles, gravel, crushed stone, iron ore concentrates, anhydrous ammonia, as well as various copper and aluminium products, etc.
The EU identifies persons supporting Russia’s defence and security sector
60 legal entities have been added to the sanctions list for activities that contribute to strengthening Russia’s military and technological capabilities, thereby directly supporting the development of its defence and security sector. The listed entities include both Russian and third-country persons.
New prohibition on the provision of services to the Russian government
It is now prohibited to provide services to the Government of Russia and to persons established in Russia that could contribute to its technological development. In particular, the provision of managed security services is prohibited.
Managed security services include activities related to cybersecurity risk management or support, such as incident response, penetration testing, security audits and consulting, including expert advice related to technical support.
Restriction on the re-publication of Russian propaganda media content
In the EU, not only the broadcasting of content produced by media outlets supporting Kremlin narratives listed under Council Regulation (EU) No 833/2014 will be prohibited, but also its real-time re-publication (mirroring), in order to prevent circumvention of the restrictions.
Restrictions on transactions involving ports used to circumvent oil price cap measures
The list of ports and locks with which any transactions are prohibited has been expanded, adding two ports located in Russia and one in a third country.
Energy sector
Shadow fleet
Under the new sanctions package, vessels may be classified as part of the “shadow fleet” not only if they transport crude oil and petroleum products of Russian origin, but also if they carry mineral products, such as natural raw materials required for industrial use, including salt, potassium carbonate, and others.
An additional 46 shadow fleet vessels have been identified under the 20th sanctions package and included in the sanctions list.
Liquefied natural gas (LNG) related service bans
As of 1 January 2027, a ban will enter into force on the provision of liquefied natural gas (LNG) terminal services to Russian companies or entities owned or controlled by Russian persons. The ban includes services such as loading, unloading, storage, bunkering, and others.
A new prohibition is also introduced on providing technical assistance, brokerage, or financial services to LNG tankers and icebreakers operating in Russian waters, flying the Russian flag, or owned or operated by Russian persons. Icebreakers may be actively used to strengthen the shadow fleet in Russia’s northern region.
Measures to reduce the potential sale of tankers to Russian persons
Tankers intended for the transport of crude oil and petroleum products are prohibited from being sold or transferred to Russian persons or for use in Russia.
To reduce the risk that a third-country buyer of a tanker from an EU entity subsequently resells or transfers it to a Russian person, the vessel owner must, prior to sale, identify potential risks and establish an internal compliance system to mitigate the risk of the vessel ending up in Russia.
The purchase agreement must include a clause prohibiting the resale of the tanker to a person in Russia or for use in Russia.
Targeted financial sanctions
The Annex I to Council Regulation (EU) No 269/2014 has been amended to include:
Inclusion in Annex I to Council Regulation (EU) No 269/2014 entails an obligation to freeze all funds and economic resources belonging to, owned, held, or controlled by these persons, entities, or bodies.
In addition, it is prohibited to directly or indirectly make funds or economic resources available to or for the benefit of these persons, entities, or bodies.
Financial sector
Four third-country banks have been identified that use the Russian Central Bank’s SPFS system or otherwise significantly hinder the achievement of the EU sanctions objectives
Persons residing in the EU are prohibited from engaging in cooperation or carrying out any transactions with banks that use the Russian Central Bank’s SPFS system, provide crypto-asset services supporting Russia’s military aggression, or significantly impede the objectives set out in the sanctions framework.
Under the new sanctions package, four additional such third-country financial institutions have been added. The list of financial institutions subject to transaction bans has also been expanded by adding 20 financial institutions.
Additional restrictions targeting crypto-assets
In addition to the previously established restrictions on the crypto-asset A7A5, the new sanctions package introduces a prohibition on transactions related to two additional crypto-assets still in the implementation phase - RUBx and Digital Rouble, the digital currencies of the Russian Central Bank.
A prohibition is also introduced on any transactions with legal persons established in Russia that provide crypto-asset or exchange services.
Furthermore, it is prohibited to engage in transactions with legal persons established outside the EU that are not financial institutions but provide crypto-asset or payment services enabling international transactions that could be used to circumvent restrictive measures.
Ban on receiving donations from the Russian research sector
It is prohibited to receive donations or other forms of financial support from Russian public or private research organisations, higher education institutions, as well as companies engaged in research or innovation development.
Impact of sanctions on Belarus
With the 20th sanctions package, new restrictive measures have been adopted against Belarus for supporting Russia’s aggression against Ukraine.
The introduced measures are similar to those imposed on Russia. The list of prohibited services has been expanded to include a ban on the provision of tourism services and a ban on the provision of managed security services.
Stricter restrictions have also been introduced in relation to crypto-assets, and new categories of goods subject to import and export bans have been defined.
The export ban will now apply to goods such as various rubber products, metal wires, and certain types of agricultural machinery, while the import ban will apply to salt, anhydrous ammonia, iron ore, and other materials that can generate significant revenue for Belarus.
The targeted financial sanctions lists have also been expanded, adding three legal entities.
In addition, the requirement to obtain prior authorisation from the competent authority before providing services to parts of the governments of Russia and Belarus will no longer apply to Russian and Belarusian diplomatic and consular representations.
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