On 23 July 2026, the Council of the European Union adopted the 21st sanctions package against Russia and Belarus [1]. It primarily affects the finance (I, II) and energy (III) sectors. In addition, it expands import and export bans (IV.), strengthens legal protection against Russian court decisions (V.) and extends the approval options for Russia exits (VI.). The sanctions against Belarus were amended at the same time (VII.).

I. Financial sector: extended transaction bans

A further 33 Russian credit and financial institutions have been added to Annex XIV to Regulation (EU) No 833/2014 and will fall under the transaction ban in Article 5h from 13 August 2026. Nationals of an EU Member State, an EEA State or Switzerland may apply for authorisation to withdraw funds from the newly listed institutions in order to end their business relationships with them. The request must be submitted within three months of the relevant date of application, and the funds must be transferred to an institution governed by the law of a Member State or controlled by such an institution. Equivalent exemptions apply to the transaction bans in Articles 5ac and 5ad.

Annex XLV now includes 17 additional entries, mostly crypto-asset service providers but also some financial institutions, including Chinggis Khaan Bank, Sberbank India and India VTB. These entities are subject to the transaction ban in Article 5ad of Regulation (EU) No 833/2014.

The new Article 5bc of Regulation (EU) No 833/2014 allows the EU to prohibit all transactions with crypto-asset service providers and crypto platforms established in third countries listed in a new Annex LVII. Third countries may be listed if they systematically and persistently fail to prevent EU sanctions from being circumvented via providers based in their territory.

The ban on Russian nationals and persons resident in Russia owning or controlling EU companies with a crypto-asset element, or serving on their management bodies, under Article 5b(2a) of Regulation (EU) No 833/2014 will apply from 25 August 2026 to all crypto-asset services within the meaning of Regulation (EU) 2023/1114 (MiCA).

II. Persons subject to financial sanctions: banks’ assets fully frozen

Annex I to Regulation (EU) No 269/2014 has been expanded by 48 natural persons and 168 entities. They are subject to an asset freeze and a prohibition on making funds or economic resources available to them.

A significant proportion of the newly listed entities are credit and financial institutions, which are therefore no longer subject merely to a transaction ban, but to a full asset freeze. The Council cites as the reason for the listing the fact that the banking sector generates substantial revenue for the Russian government. Among those listed are Rosselkhozbank, MTS Bank, Bank ZENIT, BCS Bank, Ozon Bank and Wildberries Bank. Further listings concern the Moscow Exchange PJSC (PJSC Moscow Exchange MICEX-RTS). Its infrastructure subsidiaries, the National Settlement Depository, which was already listed, and the National Clearing Centre, are identified in the listing statement as systemically important financial market infrastructure but are not themselves newly listed. Other newly listed persons and entities include the energy company PJSC Inter RAO UES, several gold producers, including Susumanzoloto, GV Gold, Pavlik, Yuzhuralzoloto and Nordgold, the First Diamond Company, the machinery group Uralmash/UZTM-KARTEX and the stablecoin network A7/A7A5.

The package also newly introduces narrowly framed exemptions. These include authorisation possibilities for certain insurance services and for the exercise of a put option agreed before 28 February 2022, as well as statutory exceptions for the necessary rail transport services of JSC Russian Railways between Russia and the Union, in transit through the Union, between the Kaliningrad region and Russia and within Russia under Article 6g and for the Paks II nuclear project under Article 6h.

III. Energy: refineries, oil price cap, shadow fleet and LNG

The new Article 5ae(2a) of Regulation (EU) No 833/2014 prohibits any transaction with listed refineries in Russia and in third countries where they are used to process or refine Russian crude oil or petroleum products or to circumvent sanctions. So far, only the Kulevi refinery in Georgia has been listed, so the ban applies from 25 January 2027.

The mechanism for adjusting the oil price cap will be suspended from 24 July 2026 to 14 July 2027. The Commission will calculate a new average price by 15 January 2027 and, on that basis, the Council may adjust the cap. If the Council does not act, the existing cap will remain in place.

A further 41 vessels have been included in Annex XLII. The listing criteria now also cover vessels that provide listed ships with services such as tug assistance or ship-to-ship transfers. The transaction ban has also been extended to two further Russian ports, Olya and Vysotsk, and to four Russian airports, including Sheremetyevo.

The new Article 3qa of Regulation (EU) No 833/2014 introduces a notification requirement for the sale of LNG tanker vessels to third countries. Sale contracts must contain a contractual prohibition on resale to Russia, which must be passed on in any onward sale chain. EU sellers are subject to a risk-based due diligence obligation. On the basis of the information notified, the Council will decide by 25 October 2026 whether to bring a sales ban into force. The ban on the transfer of Russian LNG to third countries is supplemented by a temporary exemption limited to 2025 volumes for long-term contracts concluded before 24 February 2022, together with quarterly reporting obligations. The exemptions for supplies from the Sakhalin-2 project to Japan and, newly, South Korea apply until 31 March 2028. The ban on LNG terminal services for persons in Russia applies from 1 January 2027.

IV. Import and export bans: ores, glass, motor vehicle parts and UAV technology

Annex IV to Regulation (EU) No 833/2014, which lists the entities subject to stricter export restrictions on dual-use items and listed technology, has been expanded by 51 entries, numbered 922 to 972. In addition to Russian companies, it now includes entities from Hong Kong, Türkiye, China, the United Arab Emirates, Kyrgyzstan, Kazakhstan and India, including AAA China Limited, Shenzhen Wanma International Freight Forwarding and Dalian Unimatic Trading.

The goods list in Annex VII has been expanded to include radio systems for taking over or disrupting UAVs, launch devices and ground equipment for UAVs, flight termination systems, servomotors with a torque-to-weight ratio of at least 0.16, certain self-adhesive films and tapes, as well as nickel powder, nickel metals and nickel alloys and beryllium powder with a purity of at least 50% each.

The import bans under Article 3i (Annex XXI to Regulation (EU) No 833/2014) now also cover copper, nickel, lead and precious metal ores, zinc in crude form, zinc and chromium oxides, tall oil, glassware, and motor vehicle bodies and parts under HS headings 8707 and 8708. A transitional period applies to existing contracts covering the newly listed goods until 25 October 2026.

V. Legal protection against Russian court decisions

Under Article 11ca of Regulation (EU) No 833/2014, EU courts can now order affected companies not only to refrain from or end abusive proceedings before Russian courts, but also to refrain from enforcing, recognising or relying on any decision obtained in such proceedings in any jurisdiction; breaches are penalised by financial penalties payable to the affected company. Member States are not permitted to recognise or enforce decisions of Russian courts or authorities linked to sanctions-affected contracts, whether those decisions are based on Articles 248.1 or 248.2 of the Russian Commercial Procedure Code or on any other part of Russian law. A corresponding prohibition on recognition has also been added to Regulation (EU) No 269/2014. The right to claim damages before Member State courts has also been extended to cover damage caused by proceedings brought in other third countries.

VI. Russia exits: authorisation options extended

The authorisation options relating to withdrawal from the Russian market have been extended again. Authorisations under Article 12b of Regulation (EU) No 833/2014 may now be granted until 31 December 2027; the same applies to the winding up of joint ventures under Article 5aa and to authorisations to satisfy claims under Article 11(4) of Regulation (EU) No 833/2014.

VII. Belarus: parallel adjustment

Regulation (EU) 2026/1846 largely aligns the Belarus sanctions under Regulation (EC) No 765/2006 with the Russia regime. The import bans now cover the same goods as in the Russia regime, including ores, zinc in crude form, zinc and chromium oxides, tall oil, glassware and motor vehicle bodies and parts. A transitional period applies until 25 October 2026 for existing contracts covering certain newly listed goods. The list of goods in Annex Va has been expanded to include the same UAV and materials technology as in Annex VII to Regulation (EU) No 833/2014. Four Belarusian entities (CHIP AND DIP LLC, OJSC Rogachev Plant Diaprojector, Display Design Bureau JSC and CJSC Hull Products Plant) have been added to the list of entities subject to stricter export controls on dual-use items. The ban on Belarusian nationals and persons resident in Belarus owning or controlling EU companies with a crypto-asset element, or serving on their management bodies, will apply from 25 August 2026 to all crypto-asset services within the meaning of the MiCA Regulation. The right to claim damages before Member State courts has also been extended to cover damage caused by proceedings brought in non-EU countries.

VIII. Outlook

Almost at the same time, China announced countermeasures against European defence and technology companies, including restrictions on the export of dual-use items to Rheinmetall, Tatra and IHC Merwede. Affected companies should, in particular, update their screening lists and Russia-related payment flows. Where natural persons hold funds at newly listed institutions, they should observe the three-month deadline for applications for withdrawal authorisations.

[1] For Russia, the EU has adopted Regulation (EU) 2026/1848, which updates Regulation (EU) No 833/2014, as well as Regulation (EU) 2026/1844 and Implementing Regulation (EU) 2026/1843, which update and apply Regulation (EU) No 269/2014. For Belarus, the EU has adopted Regulation (EU) 2026/1846, which updates Regulation (EC) No 765/2006.