The European Union has adopted its 20th package of sanctions against Russia, which has been in force since 24 April 2026. The measures cover several sectors simultaneously, in particular energy, trade and financial transactions, and, for the first time, also include the activation of an anti-circumvention mechanism.
First use of the anti-circumvention mechanism
A new development is the application of the so-called anti-circumvention mechanism under Article 12f of Regulation (EU) No 833/2014. This allows for the designation of third countries which, in the Council’s assessment, do not take sufficient measures to prevent sanctioned goods from reaching Russia. This provision was invoked for the first time by listing Kyrgyzstan for certain categories of goods (CN codes 8457 10 and 8517 62). This results in a comprehensive ban on the export, supply or transfer of these goods to that country.
Tighter measures in the energy sector and maritime transport
Measures are also being extended in the energy sector. A further 46 vessels from the so-called Russian shadow fleet have been added to the sanctions list and are now subject to a ban on port access and the provision of services, whilst some entries have been removed. Furthermore, the new Decision 2026/508 lays the groundwork for a potential complete ban on maritime transport of Russian crude oil and petroleum products. In addition, stricter requirements such as mandatory due diligence checks and a ‘No-Russia clause’ for certain transactions have been introduced.
Extended trade restrictions
In the area of trade restrictions, additional export bans have been introduced, including explosives, laboratory equipment, lubricants and agricultural machinery. At the same time, new import bans apply to metals, chemicals and minerals. A temporary import quota has been set for ammonia. Existing contracts concluded before the measures came into force may continue to be fulfilled under certain conditions.
Focus on the financial sector
The financial sector is also affected: the existing ban on transactions has been extended to include a further 20 Russian banks. In addition, four banks from third countries – specifically from Laos, Kyrgyzstan and Azerbaijan – are now also covered by the restrictions. The EU is thus stepping up its measures against potential circumvention schemes in international payments.
Source: GTAI (in German)
