On Thursday 23 April, the EU Member States adopted the twentieth package of sanctions against Russia. This package, presented on 5 February (see EUROPE 13803/1), had until now been blocked by Hungary and Slovakia, in connection with the shutdown of the Druzhba pipeline.
The adoption of the package, which focuses on energy, trade and financial services, was welcomed by the Presidents of the European Council, António Costa, the European Commission, Ursula von der Leyen, and Ukraine, Volodymyr Zelensky, in a statement issued after a meeting in Cyprus. They also stressed “the necessity of applying further pressure on Russia to cease its aggression and engage in meaningful negotiations towards peace”.
Energy. In its twentieth package, the EU is taking measures against the Russian energy sector, imposing sanctions on an additional 36 companies, particularly those involved in oil exploration, extraction, refining and transport, as well as against the ‘shadow fleet’, with measures against a major maritime insurer and 46 additional vessels. Conversely, 11 ships had their sanctions lifted after complying with the regulations. The EU is now imposing sanctions on 632 vessels belonging to Russia’s ‘shadow fleet’.
Guarantees are being put in place on sales of EU tankers to prevent their end use by Russia, with increased due diligence on the part of EU sellers and a mandatory ‘no Russia’ clause to be included in sales contracts, aimed at preventing their deployment as part of the ‘shadow fleet’. A new ‘shadow fleet scrapping’ clause will facilitate the decommissioning or ‘recycling’ of vessels and their exit from the shadow fleet.
In addition, two Russian ports (Murmansk and Tuapse) and the Indonesian oil terminal of Karimun are subject to measures because of their links with the shadow fleet and the circumvention of oil price caps.
The EU is introducing a ban on maintenance services for Russian LNG carriers and icebreakers and, from 1 January 2027, on LNG terminal services.
Although the Commission had proposed a ban on maritime services for Russian crude oil and petroleum products, this will not come into force immediately. The package provides for a future ban on the transport of Russian oil and oil products, in full coordination and consultation with the G7 and the Price Cap Coalition. The EU Council will decide on the date of entry into force of this ban at a later date, allowing for an appropriate transition period. According to a European source, it is not out of the question for the EU to introduce the measure without a G7 agreement.
Finances. The EU is extending the ban on doing business with twenty more Russian banks, with a few exceptions, notably for humanitarian transactions. Seventy Russian banks are now excluded from the EU internal market and the SWIFT system.
The ban on transactions has also been extended to four banks in Kyrgyzstan, Laos and Azerbaijan that contribute to the Russian war effort by significantly circumventing sanctions or by connecting to Russia’s System for Transfer of Financial Messages (SPFS). Five third-country financial entities have also been removed from the list of EU financial institutions.
It is now forbidden to trade with any Russian cryptocurrency service provider and any decentralised platform enabling cryptocurrency trading, as well as to use and support the cryptocurrency RUBx, a stablecoin backed by the rouble, and digital rouble.
The EU bans transactions with agents in Russia and third countries who offer to facilitate international transactions from Russia in order to circumvent EU sanctions.
Trade. The twentieth package “further constrains the Russian military-industrial complex” by introducing new export and import restrictions and bans. These include a ban on exports to Russia of goods ranging from rubber to tractors, worth more than €365 million, as well as metals, chemicals and minerals not yet subject to sanctions, worth more than €530 million.
New export restrictions have also been introduced for items and technologies used in the Russian war effort, such as explosives, laboratory glassware and high-performance lubricants and their additives or as well for the supply of cyber security services to Russia. A quota has been imposed on ammonia in order to cap existing imports.
All these measures will be supplemented by a tightening of the ban on transit through Russian territory.
Military industry. 58 companies and individuals involved in the development and manufacture of military goods, such as drones, have been sanctioned. These include 16 entities based in China, the United Arab Emirates, Uzbekistan, Kazakhstan and Belarus that have supplied dual-use goods or weapons systems to the Russian military-industrial complex.
Anti-circumvention measures. For the first time, the EU is activating its anti-circumvention tool. This concerns Kyrgyzstan, which, according to the Commission, is “systematically and persistently” failing to prevent the sale, supply, transfer or export to Russia of certain machine and radio equipment from the EU and used to manufacture drones and missiles in Russia. The EU is therefore banning the export of computer numerical control machines and radios to Kyrgyzstan.
Sixty entities providing direct or indirect support to the Russian military-industrial complex or engaging in activities to circumvent sanctions are also sanctioned: Thirty-two are based in Russia and 28 in China, including Hong Kong, Türkiye, the United Arab Emirates and Thailand.
Other measures. The EU is imposing sanctions on 33 individuals and 83 entities, mainly linked to the Russian energy and military sectors. Among those sanctioned, five individuals and one entity were involved in the abduction of Ukrainian children, four in the looting of cultural heritage, including Sergei Obryvalin, Russia’s First Deputy Minister of Culture, and four were propagandists. This is the highest number of people and entities sanctioned in a single package, bringing the total number of sanctioned to more than 2,700.
Dissemination in the EU of the content of ‘mirror’ sites and domains that circumvent the ban on dissemination by rebroadcasting online the same content as the sanctioned ‘propaganda media’ (such as Russia Today or Sputnik) is prohibited.
Similarly, it is now forbidden for EU research institutes, higher education establishments and other bodies, as well as natural persons associated with them, to accept funding, including donations and grants from the Russian government in the field of research and innovation.
Legal protection. The twentieth package strengthens the legal protection of EU companies against retaliatory measures by the Russian government, by authorising Member State courts to impose fines on Russians who bring abusive legal actions before Russian courts. It enables EU companies as well to claim damages in the event of unfair judgements being enforced in third countries. The EU Council is also authorised to impose a transaction ban on companies and individuals from third countries who cooperate in the implementation of such measures.
A ban on transactions against Russian competitors who take advantage of de facto illegitimate expropriations of EU operators by the Russian government is being introduced, as well as against Russians who steal and use the intellectual property rights of EU operators in Russia without their consent.
Belarus. Finally, the package incorporates certain provisions of the Russian regime relating to trade, finance, services and the legal protection of EU operators under the Belarus sanctions regime, which has been extended until 28 February 2027. Three new entities linked to the Belarusian military-industrial complex and the Lukashenko regime, including the Chinese state-owned entity China Space Sanjiang Group, have also been sanctioned.
To see the legislative acts: https://aeur.eu/f/lo0
To see the joint statement by the Presidents of the European Council, the European Commission and Ukraine: https://aeur.eu/f/lnz (Original version in French by Camille-Cerise Gessant)