21° SANCTIONS PACKAGE
On 23 July 2026, the 21st package of restrictive measures against Russia was adopted. This package includes Regulation 1844/2026 amending Regulation 269/2014, Regulation 1846/2026 amending Regulation 765/2006 and Regulation 1848/2026 amending Regulation 833/2014.
A) Energy sector
The Regulation suspends the automatic procedure for amending the crude oil price cap until 14 July 2027. During this period, the Council may still decide to amend the price cap on the basis of a Commission report. In the absence of such a decision, the current price cap will remain in force until the original amendment procedure resumes on 15 July 2027.
In addition, the Regulation introduces a notification obligation for sales or transfers of ownership of LNG tankers (CN code ex 8901 20) by EU nationals, EU residents or EU-established entities to third countries. Such transactions must also include a contractual prohibition on any further resale or transfer of the vessel to any natural or legal person, entity or body in Russia or for use in Russia.
The Regulation further introduces a temporary exemption, applicable until 25 July 2027 and renewable for successive one-year periods for certain transfers of LNG to third countries and related purchases executed under long-term contracts concluded before 24 February 2022. From 1 January 2027, it will also be prohibited to provide LNG terminal services to any natural or legal person, entity or body in Russia, or to any legal person, entity or body that is more than 50% owned or controlled by a Russian citizen or by a legal person, entity or body in Russia.
B) Financial sector
The Regulation expands the scope of the transaction ban by adding credit and financial institutions.
It also introduces a prohibition on transactions with entities providing crypto-asset services or platforms enabling the exchange or transfer of crypto-assets that are established in the third countries listed in Annex LVII.
C) Trade sector
The Regulation expands existing export and import restrictions by adding further goods and technologies to the relevant annexes. The new export restrictions cover, among other items, certain metal powders and alloys, as well as technologies including jamming equipment.
The Regulation also introduces additional import restrictions on certain goods, including metal ores, by extending the list of products subject to import prohibitions.
D) Legal protection of EU operators
The Regulation introduces new measures to strengthen the legal protection of EU operators against actions linked to the enforcement of Russian restrictive measures.
These include the possibility for EU operators to seek compensation from non-Russian contractual counterparties before the courts of Member States, the availability of injunctions to prevent the enforcement of certain Russian judgments in third countries as well as an obligation on Member States not to recognise or enforce specified Russian judgments related to EU restrictive measures.
E) Anti-circumvention measures
The Regulation adds 51 entities to the list of natural or legal persons, entities and bodies associated with Russia’s military and industrial complex or involved in the circumvention of EU restrictive measures.
The new listings comprise 24 entities established in Russia and 27 established in third countries, including China (and Hong Kong), Türkiye, Kyrgyzstan, India, Kazakhstan and the United Arab Emirates.
F) Extension of measures to Belarus
The Regulation mirrors certain trade-related restrictions and measures for the protection of EU operators under the Belarus sanctions regime with those applicable to Russia.
It also extends the prohibition on Belarusian nationals owning, controlling or holding positions in the governing bodies of providers of crypto-asset services incorporated under the law of a Member State.
