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Questions and Answers on the 20th package of sanctions against Russia
LISTINGS
Who have you targeted?
The 20th package of EU sanctions adds 120 listings of individuals (37) and entities (83) to the list of natural and legal persons subject to asset freezes and the prohibition to make funds and economic resources available to them. The new listings chiefly aim to disrupt Russian energy revenues and military capacity.
They include 36 designations encompassing both the upstream and downstream segments of the Russian energy sector, including the exploration, extraction, refining, and transportation of oil. Revenues from Russian oil exports are further suppressed through listings focusing on the shadow fleet ecosystem, including entities operating in third countries, as well as a significant maritime insurer.
The 20th package further constrains the Russian military-industrial complex by designating 58 companies and associated individuals involved in the development and manufacture of military goods, such as drones. In addition to denying Russian military enterprises valuable EU technologies, this package also addresses Russia's reliance on third countries for the provision of critical high-tech items. Specifically, the EU has now designated 16 entities based in China, the United Arab Emirates, Uzbekistan, Kazakhstan, and Belarus that have provided dual-use goods or weapons systems to the Russian military-industrial complex.
The package also includes 6 additional listings related to the deportation, forcible transfer, indoctrination or military re-education of Ukrainian children.
Additionally, the EU is targeting those promoting propaganda and the looting of Ukrainian cultural heritage. With these additions, the number of individual listings exceeds 2,700.
Why is the EU adopting further listings related to the deportation, forcible transfer, indoctrination or military re-education of Ukrainian children?
As part of the 19th package, the EU had already listed over 100 individuals and entities responsible for the deportation, forcible transfer, indoctrination or military re-education of Ukrainian children. It is one of the most heinous crimes committed by Russia since the beginning of the war of aggression. Our commitment to this topic remains absolute.
The EU is a member of the International Coalition for the Return of Ukrainian Children, and we will co-host a High-Level meeting of the Coalition with its co-chairs Ukraine and Canada on 11 May. The EU was also active in the adoption of the UN General Assembly Resolution from 3 December 2025 stressing the imperative need to step-up work on the return of Ukrainian children. Accountability for crimes committed by Russia is key to just and lasting peace.
ENERGY MEASURES
Constraining Russia's energy revenues has consistently been - and will remain - a top priority for the EU, as it weakens Moscow's ability to wage its illegal war of aggression against Ukraine. Maintaining the sanctions regime is critical for limiting windfall revenues, which is especially important given that persistently high oil prices could provide a boost to the recently cooling Russian economy. Russia should not benefit from the war in Iran and therefore pressure should be kept on Russia through sanctions.
The 20th sanctions package introduces the basis for a maritime services ban on Russian oil and petroleum products, in full coordination and discussion with the G7 and the Price Cap Coalition (G7 members and other participating countries). The Council will decide when the Maritime Services Ban will enter into force, considering an appropriate wind-down period. This would further reduce the total available capacity to transport Russian oil.
How would the Maritime Services Ban work?
In practical terms, the introduction of a maritime services ban would prohibit the transport of Russian oil and ban related services like financing or insurance to vessels transporting Russian oil. The new ban is expected to greatly reduce Russia's energy revenues and make it more difficult to find buyers for its oil.
How would the maritime services ban discourage shippers from shifting jurisdictions?
The ban will apply to EU operators and owners of vessels, whether they operate vessels under an EU flag or a third country flag. In addition, under maritime international conventions, vessels are obliged to have reliable P&I (Protection and Indemnity) insurance, which is arranged for longer periods, such as a year, rather than for each voyage. If an owner engages in sanctioned trade, P&I insurers in sanctions-applying jurisdictions will refuse to issue insurance. Operators will therefore have to choose whether to continue legitimate trade covered by reliable insurers, or to shift into shadow trade, losing legitimate business.
The 20th package introduces 36 designations encompassing both the upstream and downstream segments of the Russian energy sector, including the exploration, extraction, refining, and transportation of oil. Revenues from Russian oil exports are further suppressed through listings focusing on the shadow fleet ecosystem, including entities operating in third countries, as well as a significant maritime insurer.
FINANCIAL MEASURES
The Russian financial banking sector is a vital tool of its government to fund its aggression against Ukraine. That is why the pressure applied by the EU and G7 countries on it has increased. The 20th package therefore adds pressure on Russian banks while targeting additional third-country banks providing alternative payment channels. In addition, to prevent circumvention the package clamps down on transactions involving Russian cryptocurrency operators and decentralised platforms.
Which banks in Russia are targeted?
The 20th package includes 20 additional Russian banks under a transaction ban because of their systemic or regional relevance, or their role in facilitating cross-border payments that bolster the Russian economy. Some Russian banks have also been listed because they provide financial services over the occupied territories of Ukraine or offer financial services to military personnel in the Russian armed forces.
Which third country banks are listed and why?
The 20th package adds four banks in third countries engaged in activities that frustrate sanctions, or which are connected to the Russian financial messaging system, namely the System for Transfer of Financial Messages (SPFS). This includes entities in the Kyrgyz Republic, the Lao People's Democratic Republic, and the Republic of Azerbaijan.
The Russian financial sector, which is now entirely devoted to financially supporting the war, is struggling under the weight of EU and G7 sanctions. As a result, Russian banks are desperately seeking to establish banking channels via other countries. Additionally, some banks in other jurisdictions see this as a business opportunity.
While EU sanctions are not extraterritorial, the EU does not remain passive when third-country operators enable the circumvention of our measures. That is why it is vital to target financial operators in third countries that provide a lifeline to Russia's war economy. In essence, EU operators are prohibited from doing business with banks under the transaction ban.
What are the new measures concerning crypto currencies?
In response to the sanctions on the banking sector Russia is seeking alternative financial and payment channels. In the 19th package, the Council prohibited any engagement with the A7A5 cryptocurrency and listed a cryptocurrency exchange from Paraguay under a transaction ban.
In the same package, several third-country banks were the target of a transaction ban due to their connection with the Russian financial messaging system or their involvement in circumvention schemes. Today's package builds on these extensive measures, by adding a total sectorial ban on interacting with any Russian crypto-asset service provider, as well as any decentralised platforms enabling crypto trading.
It also bans the use of (and support to) the stablecoin RUBx, which is pegged to the Rouble and developed by Russian players and the Digital Rouble, a central-bank digital currency under development by the Central Bank of Russia.
What are the new measures concerning “payment services”?
As sanctions implemented by the EU and like-minded partners have isolated Russia from international financial markets, “payment agents” have emerged as a primary alternative for Russian companies. These intermediaries, often in logistics or import/export, help move funds to foreign suppliers while staying 'under the radar'.
The new measures prohibit transactions with specific agents in Russia and third countries that facilitate cross-border payments for Russian entities. This covers schemes using third-country companies and the use of mirror accounts, inside and outside Russia, to settle payments through “netting” or “set-off”, where debts are balanced against credits and no funds actually cross the Russian border.
By targeting the most widespread method of cross-border payment circumvention, this measure places further strain on the Russian war machine.
ANTI-CIRCUMVENTION MEASURES
This package adds to Annex IV 60 new entities providing direct or indirect support to Russia's military industrial complex or engaged in sanctions circumvention. This includes 32 entities established in Russia and 28 based in third countries (China, incl. Hong Kong, Türkiye, UAE, and Thailand). Annex IV lists companies which are military end-users, part of, or have close links to, the Russian military-industrial complex and to which it is prohibited to supply certain dual-use goods and technologies listed in the Regulation.
Anti-circumvention tool:
What is the anti-circumvention tool?
The EU introduced the anti-circumvention tool with the 11th package of sanctions against Russia. The anti-circumvention tool allows the EU to restrict the sale, supply, transfer, or export of specified sanctioned goods and technology to certain third countries whose jurisdictions are continued and particularly high risk of circumvention. The tool enables the EU to prohibit the export of specific high-risk EU goods to the countries which are used to circumvent EU sanctions. The tool also prohibits the provision of associated services.
Why is the EU using the “anti-circumvention tool” for the first time?
Addressing sanctions circumvention is a top priority for the EU. The EU will not ignore cases of sanctions being systematically circumvented using third country jurisdictions to re-export sanctioned EU goods to Russia. Today, the EU activated this tool due to systematic and persistent failure by the Kyrgyz Republic to prevent the sale, supply, transfer, or export to Russia of specific high-risk EU goods. In particular, this concerns certain machine tools, and certain telecommunication equipment used for drones and missiles exported from the Union. So far, insufficient action has been taken by the Kyrgyz Republic to effectively stem this re-exportation.
Is the EU imposing sanctions against a third country?
No. This does not mean the EU is imposing sanctions against third countries or their governments. The objective is to ensure that sanctioned EU goods do not end up in Russia. We continue to count on the cooperation of the Kyrgyz Republic and are providing guidance and technical assistance on the scope of EU sanctions.
Why do you want to ban the export of these two types of goods?
We are proposing to prohibit the sale, supply, transfer or export to Russia of specific high-risk goods. This includes certain telecommunication equipment used for drones and missiles, as well as machining tools for working metal which are widely used in defence manufacturing. These goods stand out as being increasingly imported from the EU to the Kyrgyz Republic and re-exported to Russia. These goods directly allow Russia to pursue its illegal military aggression against Ukraine and to sustain its ability to wage war.
TRADE MEASURES
EXPORTS
Which are the new export restrictions and bans included with the 20th package of sanctions?
The package adds new export restrictions and bans to further curtail Russia's war economy and industrial capabilities.
The new export bans (corresponding to over EUR 365 million of EU exports in 2024), include:
- Chemicals used in the production of lubricant additives and solvents (EUR 228 million);
- Rubber and articles of vulcanised rubber (EUR 35 million);
- Screws, bolts, and buts of steel (EUR 48 million);
- Tools/components used for metal production, such as coated electrodes of base metal for electric arc-welding (EUR 27 million);
- Tractors with engine power greater than 130 kW (EUR 27 million) that are used in various industrial sectors (construction operations, mining industry), road maintenance; highway maintenance; and material handling.
The package also adds new export restrictions and strengthens existing controls on dual-use and advanced technology items (Annex VII) to prevent that their export contributes to the Russia military capabilities.
- New export restrictions, amounting to over EUR 33 million in 2024, and covering:
- laboratory glassware;
- certain lubricating materials of high performance; and
- three additives for lubricating materials
- Strengthening the existing controls on
- lubricating materials of high performance (oils and greases with high technical specifications);
- 11 additives for lubricating materials; and
- three energetic materials that can be used to create explosives - amatol, nitroglycol and picryl chloride.
Restrictions on services: additional restrictions on the provision of cybersecurity services to Russia.
IMPORTS
Which are the new import bans included with the 20th package of sanctions?
- The new import bans on certain metals, chemicals, and minerals apply to imports with a value (2024 values) of around EUR 532 million, and include:
- minerals such as silicon, salts, quicklime (EUR 40 million in 2024);
- iron ore (EUR 2 million in 2024);
- copper (EUR 279 million in 2024);
- the remaining processed aluminium goods not yet banned (EUR 7 million in 2024);
- scrap of steel, aluminium, copper, nickel, iron ore slag (EUR 104 million in 2024);
- most the of the remaining but not yet banned chemicals (EUR 77 million in 2024), except fertiliser precursors (more below on ammonia) and except products used in the pharmaceutical industry;
- articles of vulcanised rubber (EUR 8 million in 2024); and
- tanned fur skins (EUR 12 million in 2024).
Quota on ammonia imports
Finally, this package introduces a yearly quota on ammonia imports that will be automatically renewed every year, set at the volume of 2025 imports. The quota is established to cap existing import levels that have been increasing and to avoid the export of ammonia being used to circumvent the REPowerEU ban on gas imports when this prohibition takes effect, while ensuring that there is sufficient supply for the Union's market.
LEGAL PROTECTION OF EU OPERATORS
Which are the new provisions adopted that further protect EU operators?
Russia has committed the most severe violations of international law. Our sanctions are a justified response. The protection of our Member States, operators, and citizens from Russian retaliation linked to EU sanctions is crucial. That is why this package adds further legal protection for EU operators against abusive lawsuits from Russians, as well as legal protection from enforcement of abusive Russian judgments and other retaliation measures. In particular:
- The package enables the Council to impose a transaction ban against third country firms and individuals that assist Russians seeking enforcement of their abusive legal claims in their countries.
- The new measures allow Union firms to claim damages from those third country firms and individuals for such acts of enforcement.
- Moreover, the scope of application of the ‘no claims clause' is extended to certain third-country persons – excluding partner countries – to avoid EU operators being sued for contracts whose performance has become impossible as a consequence of EU sanctions.
- Additionally, the measures introduce a transaction ban against those who use intellectual property rights of EU operators in Russia without their consent.
- The package inserts the possibility for the Council to impose a transaction ban on Russian competitors taking advantage of the fact that EU operators have been subject to de facto expropriations in Russia, including the direct and indirect beneficiaries of such measures.
- The EU also empowers Member State courts to order the discontinuation of abusive proceedings in Russia and to impose penalties on Russian actors who seek orders from Russian courts unlawfully forcing Union operators to resolve disputes in Russia.
DE-LISTINGS
Why are some financial institutions de-listed?
The aim of sanctions is to trigger behavioural change and ensure that third country institutions do not take actions that frustrate our sanctions. Today's decision follows successful outreach and engagement with third-country jurisdictions. Thanks to this constructive dialogue, a number of proposed listings were avoided, demonstrating the effectiveness of the EU's diplomatic and cooperative approach in ensuring compliance with its sanction's framework. Where change has occurred, the Commission believes it is right to recognise it and respond accordingly. The Council decides unanimously whether to place an entity under a transaction ban, and the same procedure applies to removals. In the 20th package, five financial institutions are removed from the transaction ban list. The Commission remains in regular contact with third countries on listed entities under their jurisdiction to find solutions consistent with the aims of the listing. When our analysis shows the conditions for de-listing are met, it indicates that sanctions are delivering their intended effect.
Why are 11 vessels de-listed?
Where the EU's sanctions regime has achieved change by vessels turning away from the transport of sanctioned Russian oil, the EU is prepared to consider their removal from our sanction's regime. In this case, the owners of the vessels were able to demonstrate their return to compliance. These 11 de-listings show that delisting is a credible prospect for vessels that return to compliance.
OTHER MEASURES
FIGHTING DISINFORMATION
The 20th package introduces an expansion of the broadcasting ban, through a ‘catch all' clause, to tackle online mirror outlets that distribute the same content as sanctioned propaganda media outlets (such as Russia Today, Sputnik, etc.). Mirror sites, accounts or domains that act as proxies of official media channels to circumvent the broadcasting ban must be blocked from spreading this content.
RESEARCH
The new measures prohibit the acceptance of Russian research donations or grants. The prohibition covers the acceptance of benefits, support and financing for research and innovation from the Russian Government, and publicly owned or controlled bodies more broadly and it is in line with the ban on political parties accepting Russian financing.
BELARUS ALIGNMENT
Which new measures concern Belarus?
The package mirrors, where relevant, certain trade, financial and services related provisions as well as provisions related to the protection of EU operators in the Belarus sanctions regime, per previous practice.
BACKGROUND
Impact of EU Sanctions
EU sanctions remain at the core of the EU's response to Russia's unjustified military aggression against Ukraine. They have a clear objective - to undermine Russia's ability to finance and sustain its illegal war against Ukraine. Economic data clearly indicate that EU sanctions are effective. However, developments in energy markets following the war in Iran are generating higher revenues for Russia. Therefore, it is more important than ever that the EU and its Member States maintain pressure by strengthening sanctions and ensuring strict implementation to prevent circumvention.
The Russian economy has entered a period of stagnation as the growth created by increased military spending begins to fade. After growth of 4.9% in 2024, Russian GDP grew by only 1% in 2025 and declined year on year in January and February 2026 (by 2.1% and 1.5%, respectively). Key sanctioned industries such as energy, mineral extraction, and steel and metals are all experiencing severe pressure. Corporate sectors, especially in regions dependent on/intertwined with specific industries (i.e., coal-extractive industrial cities) are becoming dependent on fiscal support.
Russia's primary source of income has always been energy. However, in 2025 oil and gas revenues were 24% lower than in 2024. In the first two months of 2026, oil and gas revenues nearly halved (-48%) with respect to the same period in 2025, highlighting the effectiveness of sanctions in contributing to the curtailing of Russia's revenues from fossil fuels. Data on March's oil and gas revenues show that, despite an increase with respect to the previous month, they remained substantially below (-43%) the level of March 2025.
Russia's federal budget deficit in 2025 increased significantly to 2.6% (from 1.7% in 2024) and the consolidated budget deficit increased to 3.9%. Preliminary data from the first quarter of 2026 point to a further sharp increase of the budget deficit. Russian regional finances are under severe strain: the majority of Russian regions have recorded deficits. As a result, the volume of investments in regions has been lagging, curtailing growth and eroding future productivity.
The beginning of the war in Iran at the end of February 2026, with the sharp increase in fossil fuels prices, is leading to a temporary inversion of this trend. The IMF expects Russia's economy to benefit from higher fossil fuels prices. Thus, it reviewed upwards Russia's GDP growth forecasts in 2026 to 1.1%, from 0.8%. This does not fundamentally change the picture, but it could bring some relief to Russia's finances. Higher international oil prices and the waiver of US sanctions on Russian oil at sea allowed Russia to export its oil at a higher price and increase its related fiscal revenues. EU sanctions help keep pressure on Russian oil prices and consequently on Russia's fiscal space to finance its war effort.
The National Wealth Fund (NWF) liquid assets (ready to invest/spend) further declined, covering only 1.7% of GDP at the end of March 2026. Due to sanctions in 2025, the NWF was compelled to continue supporting several large sanctioned state-owned banks and state-owned enterprises, spending more than 1 trillion roubles in 2025 on Gazprombank, VTB, Sberbank, Rostex, and in other investments, as well as providing financing in the markets for listed corporations and sectors.
The high level of interest rates, macroeconomic imbalances, sanctions, and previous rapid increases in debt levels, resulted in banking sector vulnerability, including increases of the level of non-performing assets and credit risks for banks, which is especially the case for banks focused on services to specific industries or large enterprises.
For more information
20th package of sanctions in the official journal