On July 23, 2026, the EU member states adopted what is now the 21st sanctions package against Russia. Once again, the focus is on revenue from energy transactions, access to the financial system, and supplies to the Russian defense industry. At the same time, the EU is increasingly targeting intermediaries and companies in third countries.

A Look Back: Key Points of the 20th Sanctions Package

To properly contextualize the new measures, it is worth taking a brief look at the comprehensive 20th sanctions package. From a business perspective, three issues were at the forefront:

1. Import and Export Bans: The proposal called for additional trade restrictions as well as a complete ban on maritime transport services for Russian crude oil. This was intended to curtail further sources of revenue for Russia.
2. Financial and Crypto Sectors: In addition to major banks, the proposal aimed to increasingly target regional Russian banks and other players in the crypto sector in order to shut down alternative financing channels.
3.  Logistics and Energy: The proposal also targeted port services, insurance, and certification. The latest Commission communication further confirms that the 20th package introduced a ban on LNG terminal services.

Current Status: Key Points of the 21st Sanctions Package

According to the Commission communication, the new package focuses in particular on the following areas:

1. Energy and the Shadow Fleet: The regular adjustment of the oil price cap is suspended until July 2027; exceptional market developments may justify an earlier adjustment. The transaction ban is extended to additional Russian ports and airports, as well as to refineries that process Russian oil. An additional 41 vessels are subject to port and service bans. For the first time, vessels providing services to already-listed vessels are also covered; this includes five bunker vessels. A reporting requirement has been added for the sale of LNG tankers to third countries. The existing ban on LNG terminal services also applies to non-Russian economic operators from third countries that are controlled by Russian companies.
2. Banks and Crypto Assets: Transaction bans are being extended to additional Russian banks and third-country banks. The ban also covers the use of messaging services for payment transactions. In total, more than 100 Russian banks are now affected. Additional crypto platforms and crypto-related companies in third countries are also covered. Furthermore, a specific ban on crypto-asset services from third countries is introduced if the platforms in question facilitate the circumvention of sanctions.
3. Trade and Circumvention: New export restrictions apply, among other things, to certain metal powders and alloys used in the aerospace industry and for drone production; import bans have also been imposed on items such as metal ores. The list of organizations that support Russia’s military-industrial complex or help circumvent sanctions has grown by 51 entries, 27 of which are in third countries.
4. Legal Protection and New Designations: EU companies are granted additional means to defend themselves against abusive lawsuits filed in response to EU sanctions. This includes the ability to sue non-Russian contracting parties in the EU for damages. EU courts may also issue orders to prevent third countries from enforcing unlawful Russian judgments. To protect EU economic operators in disputes arising from EU sanctions, EU courts and Member States may refuse to recognize or enforce decisions from proceedings before Russian courts. In addition, the sanctions lists are being expanded by 218 entries—48 individuals and 170 organizations. Their assets will be frozen; no funds or economic resources may be made available to them.

National Level: The 8th, 9th, and 10th Sanctions Implementation Regulation

Independently of the 21st EU sanctions package, the Federal Minister of Finance promulgated the 8th, 9th, and 10th Sanctions Implementation Regulations (Sankt-DV) on April 29 and July 17 and 24, 2026, pursuant to Section 2(1) of the Sanctions Act 2024 (SanktG 2024). The ordinances serve to implement resolutions of the UN Security Council and pertain to various sanctions regimes:

1. The 8th Sankt-DV designates four individuals in connection with support for the Rapid Support Forces in Sudan.
2. The 9th Sankt-DV designates six individuals and two organizations in connection with armed groups in the Democratic Republic of the Congo.
3. The 10th Sanctions Ordinance covers the oil tanker “Avax,” which, according to the ordinance, has been located near the old port of Benghazi in Libya since April 4, 2026.

Assets belonging to the listed individuals and entities are frozen; furthermore, the direct or indirect provision of such assets is prohibited. Exceptions apply, in particular, to certain forms of humanitarian aid and activities aimed at meeting basic human needs. In addition, there is no obligation to fulfill civil law claims arising from contracts or other legal transactions whose fulfillment has been impeded by these measures.

The regulations enter into force upon their publication and expire on the date on which a directly applicable European Union sanctions measure implementing the respective UN sanctions measures enters into force. The three regulations are not part of the 21st EU sanctions package against Russia.

Conclusion

The 21st EU sanctions package expands existing measures, particularly in the areas of energy, financial services, cryptocurrencies, trade, and the military-industrial complex. It includes further restrictions on ships, banks, cryptocurrency platforms, and organizations, as well as additional measures against sanctions evasion and to provide legal protection for EU economic operators. Separately, the 8th, 9th, and 10th Sanctions Decisions serve to implement resolutions of the UN Security Council.