20th Sanctions package against Russia: Further tightening and anti-circumvention measures

1. Additional measures in the energy sector

Within the energy sector, the Commission proposes a prohibition on maritime services related to the transport of Russian crude oil. In addition, 43 additional vessels are to be added to the so-called shadow fleet. Further restrictions are also envisaged for LNG tankers and icebreakers.

These measures aim to further restrict the export of Russian energy products and to address circumvention routes through alternative maritime structures.

2. Expansion of financial sanctions

In the financial sector, twenty additional regional Russian banks are to be brought under the sanctions regime. The proposal also includes measures targeting crypto transactions and banks in third countries that are involved in or contribute to sanctions evasion.

The objective is to further limit Russia’s access to the international financial system and to address indirect financing channels.
Once the list is published, we recommend assessing whether your supply chain is affected.

3. New im- and export restrictions

The proposal further introduces new import and export bans covering a wide range of goods, including raw materials, machinery, and related technologies. The exact scope of these restrictions will become clear upon publication of the final regulation.
For companies engaged in international trade, this development implies a further expansion of sanctions screening within existing compliance processes.

It is advisable to verify, on the basis of the final list, whether the goods in your product portfolio are affected by the new sanctions.

4. Application of the ‘anti-circumvention’ instrument

For the first time, the Commission proposes to apply the so-called anti-circumvention instrument. This instrument enables targeted export bans on countries where there is an increased risk of transit or re-export of sanctioned goods to Russia.

This development underscores the growing importance of supply chain transparency and careful assessment of re-export risks via third countries.

5. Adoption procedure and entry into force

The European Commission has expressed its intention to have the package adopted before 24 February 2026, the date marking the start of the Russian invasion of Ukraine. It is for the Council to approve the proposal at its meeting of 23 February 2026.

Once the sanctions package has been formally adopted and entered into force, we will provide a further update. Should you have any questions regarding the impact of these sanctions or the organisation of your sanctions and customs compliance, please do not hesitate to contact one of our advisors.

Full statement:  https://ec.europa.eu/commission/presscorner/detail/en/statement_26_318

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