As the war in Ukraine approaches its fourth anniversary, the European Union has announced its 20th sanctions package, indicating a further escalation of economic, financial, and trade measures targeting Russia. The latest measures are designed to strike at Russia’s core vulnerabilities: energy revenues, financial channels, and access to critical goods and technologies, reinforcing the EU’s long-term strategy to degrade Russia’s war-fighting capacity.

The European Commission has proposed a comprehensive package spanning energy, financial services, trade, and anti-circumvention enforcement.

Energy Measures

At the heart of the package is a shift from the G7 oil price cap to a full maritime services ban on Russian crude oil, to be implemented in coordination with like-minded partners following a G7 decision. This move aims to further restrict Russia’s ability to export oil by cutting off access to essential shipping and insurance services.

Key energy measures include:

  • 43 additional vessels added to the shadow fleet blacklist, bringing the total to 640
  • Restrictions on acquiring tankers used for sanctions evasion
  • Broad bans on maintenance and support services for LNG tankers and icebreakers
  • Reinforcement of previous bans on LNG imports under the 19th sanctions package

Financial Measures

Recognising that financial infrastructure is Russia’s weak point, the EU is significantly expanding its financial sanctions. The proposal includes:

  • Listing 20 additional Russian regional banks
  • Sanctions against crypto-asset service providers and platforms enabling sanctions circumvention
  • Measures against banks in third countries found to be facilitating illegal trade in sanctioned goods

This confirms that crypto-based and alternative payment systems are now treated as central sanctions-evasion risks, rather than peripheral concerns.

Trade Measures

Another key pillar of the sanctions package focuses on tightening trade restrictions, with new export bans worth over €360 million. These include goods and services ranging from rubber and tractors to cybersecurity services.

On the import side, the EU proposes over €570 million in new bans covering:

  • Metals such as nickel, copper, iron ores, and scrap aluminium
  • Chemicals and critical minerals
  • Salt, ammonia, silicon, pebbles, and furskins

A quota on ammonia imports is also proposed to cap existing flows.

Anti-Circumvention Tool

For the first time under the EU sanctions framework, the EU plans to activate its Anti-Circumvention Instrument, prohibiting exports of computer numerical control (CNC) machines and advanced communications equipment to jurisdictions deemed high-risk for re-export to Russia.

This represents a major shift in EU enforcement strategy, explicitly targeting third-country transit hubs used to bypass sanctions.

Legal Protections for EU Companies

Beyond enforcement, the Commission is proposing stronger legal safeguards to protect EU companies from:

  • Abusive court rulings in Russia
  • IP rights violations
  • Unfair expropriation linked to sanctions compliance

This reflects growing concern about retaliatory legal risks faced by foreign firms exiting or reducing operations in Russia.

Next Steps

The package requires unanimous approval from all EU Member States before it can take effect. If adopted, it will build on the 19th sanctions package agreed in October 2025. Through the 20th package, the EU’s message is unequivocal: Ukraine’s security, prosperity, and future are inseparable from the future of the European Union itself.

MK Compliance Limited can provide daily/weekly/monthly updates on sanctions, and AML regulatory developments. These updates ensure that you are kept informed about the latest regulatory changes, therefore ensuring comprehensive compliance.

In addition, we provide sanctions-related consulting services, including legal opinions, transaction reviews, screenings and background checks on your clients and related individuals/entities/counterparties, to ensure your business operations remain fully compliant with all applicable sanctions, mitigating the risk of breaches.

The content of this article is valid as at the date of its first publication. It is intended to provide a general guide to the subject matter and does not constitute legal advice. We recommend that you seek professional advice on your specific matter before acting on any information provided.

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