20th EU Sanctions Package Against Russia – Impacts on Businesses

On 23 April 2026, the European Union adopted its 20th package of sanctions against Russia, further strengthening the existing sanctions regime.

The new package introduces wide-ranging measures affecting energy, the military-industrial complex, trade, financial services, and crypto-assets. It significantly expands both the number of designated persons and the scope of restricted activities.

The package also extends restrictive measures further to Belarus.

Impact on businesses

The new measures create significant operational consequences for companies active in the above sectors. It is therefore essential to:

a) verify counterparties and ultimate beneficial owners;
b) map supply chains and commercial flows;
c) check goods, technologies, and services subject to restrictions;
d) monitor financial flows, including alternative instruments and crypto-assets;
e) review contracts and internal procedures to ensure full compliance.

Below is a summary of the main developments.

1. Strengthening of targeted restrictions

• 120 new individuals and entities added to sanctions lists;
• Designations extended to entities operating in the energy, military, and technology sectors;
• Inclusion of operators located in third countries connected to circumvention practices.

2. Energy and maritime sector

• 36 new designations introduced in the energy sector;
• 46 additional vessels added to the “shadow fleet” list, bringing the total to 632 units;
• Strengthened restrictions on services related to the transport and trading of energy products;
• Additional limitations introduced targeting specific operators and activities linked to the energy sector.

3. Military-industrial complex

• 58 entities designated for involvement in the development and production of military goods;
• Reinforced restrictions on dual-use goods and technologies;
• Measures extended to suppliers and operators located in third countries.

4. International trade and anti-circumvention measures

• New export restrictions on industrial goods and strategic technologies;
• Activation of the EU anti-circumvention instrument;
• Enhanced controls on indirect operations and international supply chains.

5. Financial services and crypto-assets

• Prohibition of transactions with 20 Russian banks;
• Inclusion of 4 financial institutions located in third countries;
• Ban on crypto-asset services provided by Russian operators or to Russian persons;
• Strengthened controls on payment systems and alternative financial instruments.

6. Measures concerning Belarus

Restrictions against Belarus have been further extended and strengthened, aligning more closely with the sanctions regime applicable to Russia.

How we can support you

The professionals at Bacciardi Partners assist clients in assessing the impact of the new sanctions on international operations, conducting both objective and subjective due diligence, and reviewing and updating contracts and internal procedures to ensure full regulatory compliance. Contact us for a tailored compliance review or to receive dedicated insights.