February 24, 2022, marked the fourth anniversary of the start of Russia’s war of aggression against Ukraine. The EU’s economic and financial countermeasures to date are increasingly taking effect: In 2025, Russian tax revenues from oil and gas transactions fell by nearly a quarter compared to 2024, reaching their lowest level since 2020. Nevertheless, there are still gaps to be closed. For this reason, the European Commission recently presented another proposal for what is now the 20th sanctions package. For European companies, this means that the already dense web of regulations continues to grow.

Review: The Key Points of the 19th Sanctions Package

To properly contextualize the new measures, it is worth taking a brief look at the comprehensive 19th sanctions package from October 2025. The focus was on combating circumvention schemes. The following points were particularly relevant for business practice:

i. Expanded export controls: Export restrictions on so-called “dual-use” goods (goods with dual purposes that can be used for both civilian and military purposes), such as microelectronics, machine tools, and drones, were significantly tightened. In addition, 45 new organizations involved in circumventing these bans were added to the list. These included numerous companies in third countries such as China, India, and Thailand.

ii. Service bans: A critical turning point for the IT and tech industry was the ban on providing AI services, IT services in the field of high-performance computing, and commercial space-based services to the Russian government or other organizations based in Russia.

iii. Shadow fleet & logistics: The ban on reinsuring ships in the so-called “shadow fleet” and access restrictions to European ports for over 100 additional ships severely curtailed transport in violation of sanctions.

iv. Financial and crypto sanctions: The EU responded to Russia’s use of crypto assets, such as the state-backed stablecoin A7A5, with strict transaction bans and extended these to all crypto financial service providers. European economic actors were also prohibited from cooperating with the Russian national payment card system “Mir.”

Outlook: Key Points of the 20th Sanctions Package

The planned 20th package focuses on the following key points:

i. New import and export bans: This includes further direct trade restrictions; in addition to import bans on critical minerals and military goods, the Commission is specifically planning to introduce a complete ban on maritime transport services for Russian crude oil. Companies must therefore prepare for additional categories of goods to be excluded from cross-border trade.

ii. Focus on the financial and crypto sectors: Major banks have already been targeted in the past. Now, regional Russian banks and other players in the crypto sector are to be specifically sanctioned in order to further cut off financing channels.

iii. Restrictions on logistics services: The measures taken so far are to be expanded. In the future, port services, insurance, and certifications will also be affected by new restrictions.

National level: The 6th and 7th Sanctions Implementation Ordinances

In addition to EU requirements, companies must also keep an eye on the national implementation of international sanctions.

At the end of March 2026, the Federal Minister of Finance promulgated the 6th and 7th Sanctions Implementation Regulations (Sankt-DV) pursuant to Section 2 of the Sanctions Act 2024 (SanktG). These national regulations serve to directly implement UN Security Council sanctions resolutions against specific individuals and entities.

These regulations serve as a kind of “bridge.” The regulations take effect upon their promulgation and remain in force until the day a directly applicable European Union sanction measure enters into force that implements exactly the same provisions of international law as the UN. For specific EU sanctions against Russia, however, the relevant EU regulations remain primarily authoritative.

Conclusion

The 20th EU sanctions package is another consistent step toward isolating Russia under international law. The steady expansion of the measures—particularly to the services sector, third countries, and cryptocurrencies—significantly increases the legal complexity for the business community. To avoid substantial fines and reputational damage, a functioning, comprehensive compliance management system is essential for every internationally active company today.