The measures specifically target strategic sectors underpinning Russia's military and economic resilience, including the energy sector, financial services (notably with an expansion on crypto-asset restrictions), international trade networks, and the military-industrial complex. These sanctions aim to further isolate Russia from global markets, restrict access to vital resources and revenue streams, and close critical compliance gaps exploited via third countries. These regulations will require global compliance frameworks to evolve in several critical areas.

Energy revenues and the shadow fleet

The new measures include 36 designations across the Russian energy sector, covering everything from oil extraction to transport.

Key updates include:

• Shadow fleet bans: An additional 46 vessels face port access and service bans, bringing the total restricted shadow fleet to 632 vessels.
• LNG and port restrictions: The package bans maintenance services for Russian LNG tankers and ice-breakers. It also blocks transactions with specific ports used to bypass the oil price cap, including Murmansk, Tuapse, and the Karimun Oil Terminal in Indonesia.
• Maritime services: The framework lays the groundwork for a future ban on maritime services for Russian crude oil and petroleum products.

Financial services and digital assets

The EU has extended its transaction ban to 20 Russian banks, bringing the total number of excluded Russian financial institutions to 70.

Furthermore, the measures impose transaction bans on four financial institutions in third countries, including Kyrgyzstan, Laos, and Azerbaijan, identified as facilitating the circumvention of EU sanctions or supporting the Russian System for Transfer of Financial Messages. Given Russia's increasing reliance on cryptocurrencies for international transactions the package implements a total sectoral ban on exchanges and transactions with any Russian crypto asset service provider, as well as decentralised platforms enabling crypto trading.

The package enforces new crypto measures including:

• A total sectoral ban on crypto-asset service providers and exchanges established in Russia.
• Designation of a Kyrgyz entity operating a platform used to trade the government-backed stablecoin A7A5 (previously prohibited under the 19th package), and a prohibition on the RUBx digital currency pegged to the rouble.
• A complete ban on EU support for the development of the Russian digital rouble.

Trade limits and the military-industrial complex

The EU has designated 58 companies and individuals involved in producing military goods, such as drones. Additionally, 16 entities based in third countries including China, the UAE, Uzbekistan, Kazakhstan and Belarus now face restrictions for supplying dual-use goods. New export bans to Russia on goods, from rubber to tractors, worth over EUR 365 million.

Furthermore, a new restriction prohibits the provision of cybersecurity services to Russia.

Unprecedented anti-circumvention measures

For the first time, the EU activated its dedicated anti-circumvention tool. Authorities applied this mechanism directly against Kyrgyzstan to stop the re-export of critical telecommunications equipment and computer numerical control machines. The package also lists 60 entities as providing direct or indirect support to Russia's military industrial complex or engaged in sanctions circumvention.

Accountability and legal protections

Beyond economic controls, the package targets severe human rights and legal violations. The EU added 120 new individual and entity listings across multiple categories. Among these, the package specifically targets individuals enabling the forced transfer of Ukrainian children, the looting of cultural heritage, and the spread of state propaganda.

These sanctions are complemented by new legal safeguards bolstering the protection of EU companies from illegitimate expropriation, abusive litigation, and intellectual property infringements brought before Russian courts or enforced in third countries. The measures empower Member State courts to impose fines on Russian entities that initiate abusive lawsuits and enable EU businesses to seek damages arising from enforcement of such judgments in jurisdictions outside Russia.

Belarus

Certain provisions of the package have been mirrored in the Belarus sanctions regime, including trade, finance, services, and legal protection measures. For the first time, a Chinese state-owned entity has been designated under the Belarus sanctions regime for its role in the production of Belarusian military goods. The Belarus sanctions regime has been extended by the EU Council until 28 February 2027.

The European Council’s press release can be found here and the European Commission’s press release here