On July 23, 2026, the Council of the European Union adopted the twenty-first package of restrictive measures against the Russian Federation, further strengthening the EU sanctions regime in response to Russia’s ongoing military aggression against Ukraine.
The new measures not only add a further 216 individuals and entities to Annex I of Council Regulation (EU) No 269/2014, but also introduce significant changes across a number of strategic areas, including financial services, the energy sector, crypto-assets, international trade, dual-use goods and technologies, and measures aimed at preventing the circumvention of EU sanctions.
Rather than simply expanding the list of designated persons and entities, the 21st sanctions package confirms the evolution of the EU’s approach towards a sanctions regime increasingly focused on disrupting the international networks that facilitate sanctions circumvention.
The package was adopted through a series of Council Regulations and Decisions published in the Official Journal of the European Union on 23 July 2026, including Council Regulation (EU) 2026/1848, amending Regulation (EU) No 833/2014, and Council Regulation (EU) 2026/1844, amending Regulation (EU) No 269/2014, together with the corresponding CFSP Decisions and Implementing Regulations introducing the new listings.
Here are the key measures:
The package significantly expands restrictions on the Russian financial system through the designation of additional banks and major financial institutions (94 banks and financial institutions), as well as the extension of transaction prohibitions to further credit institutions and financial intermediaries.
Particular attention is also given to entities established in third countries that facilitate the circumvention of EU sanctions. New restrictions target financial institutions and operators involved in alternative payment systems used to bypass the EU sanctions regime.
Among the most noteworthy developments is the strengthening of the framework applicable to crypto-asset service providers.
In addition to introducing new listings of platforms operating in third countries, the Council has created a new legal basis enabling the prohibition of transactions with crypto-asset service providers established outside the European Union where they are involved in activities aimed at circumventing EU restrictive measures.
This represents a significant expansion of the Union’s enforcement toolbox to address sanctions evasion through the use of digital assets.
The 21st package also introduces additional measures targeting the energy sector.
Among the key developments are strengthened measures against the so-called “shadow fleet”, including the designation of 41 additional vessels, as well as expanded restrictions targeting operators involved in the logistical and commercial support of Russian oil transportation.
The Council has also introduced new restrictions affecting refineries and oil sector operators, together with specific notification obligations for certain transactions involving LNG carriers transporting liquefied natural gas (LNG).
In addition, the automatic adjustment mechanism for the Russian oil price cap has been suspended until 15 July 2027.
The new package further expands export restrictions on goods and technologies capable of contributing to the development of Russia’s military and industrial capabilities.
The new measures cover, among other items, advanced electronic components, industrial machinery, technologies used in drone manufacturing, and other strategic goods.
At the same time, import restrictions have been extended to additional categories of products considered capable of generating significant revenues for the Russian economy.
The package also expands the list of entities—including entities established in third countries—subject to the restrictions set out in Annex IV to Regulation (EU) No 833/2014, which identifies persons subject to export restrictions relating to dual-use and advanced technology items. An additional 51 legal persons have been listed for their involvement in supporting Russia’s military-industrial complex.
Alongside the economic and trade-related measures, the 21st package introduces significant procedural safeguards for EU operators.
The EU legislator has strengthened the legal instruments available to protect Union operators against decisions issued by Russian courts in connection with the application of EU restrictive measures, introducing additional mechanisms aimed at preventing the recognition and enforcement of such decisions within the Member States.
Among these measures, the amendment to Article 11b(1) of Regulation (EU) No 269/2014 extends the right to recover both direct and indirect damages—including legal costs—incurred as a result of proceedings brought before courts of third countries concerning contracts or transactions affected by EU restrictive measures.
Furthermore, the newly introduced Article 11c of Regulation (EU) No 269/2014 prohibits the recognition, implementation or enforcement within the Member States of injunctions, orders, judgments and other judicial or administrative decisions issued pursuant to Articles 248.1 or 248.2 of the Arbitration Procedure Code of the Russian Federation, equivalent Russian legislation, or other provisions of Russian law. These provisions target decisions that hold EU persons or entities liable—whether in contract, tort or on any other legal basis—or otherwise give effect, directly or indirectly, to claims or alleged obligations arising from contracts or transactions whose performance has been affected, in whole or in part, by EU restrictive measures.
In addition, the newly introduced Article 11ca of Regulation (EU) No 833/2014 enables Union operators to seek an anti-suit injunction before the courts of the Member States. Such relief may require a party to refrain from initiating legal proceedings, discontinue pending proceedings, or refrain from seeking the recognition or enforcement of injunctions, orders, judgments or other judicial decisions obtained—or that may be obtained—in any jurisdiction, with the possibility of financial penalties in the event of non-compliance.
These amendments demonstrate the European Union’s increasing focus not only on ensuring the effectiveness of its sanctions regime, but also on protecting European businesses exposed to cross-border litigation arising from the application of EU restrictive measures.
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The 21st sanctions package confirms an increasingly well-established trend: compliance with international sanctions requires a more sophisticated approach that can no longer be limited to screening Russian counterparties directly involved in commercial transactions.
Companies are expected to strengthen their due diligence procedures by extending their assessments to financial intermediaries, crypto-asset service providers, logistics operators, and business partners established in third countries, in order to identify potential risks associated with sanctions circumvention.
Against this background, the continuous enhancement of internal control systems and sanctions compliance procedures has become increasingly important in managing the legal and reputational risks arising from international business activities.
The growing complexity of the international sanctions landscape requires specialist expertise and continuous monitoring of regulatory developments. Through a dedicated team, Campa Avvocati advises Italian and international companies on sanctions compliance, assisting them in assessing regulatory risks, interpreting and applying international sanctions legislation, and supporting their cross-border operations and relationships with international counterparties.