On July 23, 2026, the EU adopted its 21st package of sanctions against Russia. The new package freezes the oil price cap, introduces new and expanded measures targeting Russian LNG, expands transaction bans on banks and crypto-asset service providers, broadens export and import restrictions, and adds 48 individuals and 168 entities to the EU asset freeze list. This Client Alert highlights the key measures included in the latest EU sanctions package.
Sectoral sanctions1
Energy sector
Oil price cap freeze
The EU has frozen the oil price cap, suspending the automatic adjustment procedure to July 14, 2027. The current price cap for Russian crude oil remains at USD 44.10 per barrel, subject to any interim review decisions by the Council.
New and adjusted measures targeting Russian LNG sales
The EU has introduced a temporary third-country exemption to the general ban on the direct and indirect purchase, import or transfer of Russian LNG. Under this exemption, Russian LNG transfers and purchases destined for third countries (including certain related assistance/services) will not be subject to the ban until July 25, 2027, provided they are executed under a valid long-term contract concluded before February 24, 2022. There is a new requirement for EU operators affected by the exemption to report relevant Russian LNG volumes, which will assist an annual review of the ban with respect to third country activities. The EU has introduced a separate exemption until March 31, 2028, for activities relating to the transport by vessel of Russian LNG originating in the Sakhalin-2 Project to Japan and South Korea.
Separately, EU Member State nationals, residents and established entities are now required to notify all EU sales and ownership transfers of LNG tanker vessels to third countries. Based on this data, the Council will review whether to adopt a ban on any direct or indirect sale and ownership transfer of LNG tanker vessels to Russia, along with related third country diligence requirements.
From January 1, 2027, the EU will expand the pending ban on the direct or indirect provision of LNG terminal services in relation to Russia to target any person in Russia or any entity more than 50% owned or controlled by a Russian person.
Transaction ban on ports, locks and airports expanded
The EU has expanded the existing transaction ban targeting listed Russia-related ports, locks and airports to also cover listed refineries deemed to be used for processing of Russian crude oil or petroleum and mineral products, or for engaging in EU sanctions circumvention. The Kulevi Refinery in Georgia has been designated under this expanded transaction ban, with application expected from January 25, 2027. The EU has also added the Russian ports of Olya and Vysotsk, and four Russian airports (including Sheremetyevo airport), to the list.
Expanded measures targeting Russia's "shadow fleet"
The EU has expanded the criteria for designating vessels linked to Russia's "shadow fleet" to cover vessels providing bunkering, tug or ship-to-ship transfer services to already-designated vessels. The EU has also added 41 vessels to the prohibited "shadow fleet" list, against which a ban on port access and various related services applies.
Banking and financial sector
The EU has expanded its banking transaction ban against Russia-related credit and financial institutions to target 33 additional Russian banks (plus one bank in Kyrgyzstan linked to Russian SPFS-related services), some of which have also been added to the EU asset freeze list. The EU has also expanded its transaction ban against crypto-asset and related service providers deemed to frustrate EU sanctions against Russia to target a further 17 crypto-asset service platforms and banks (including entities in India, Nigeria, the UAE, Georgia and Belarus) and five third-country oil trading entities.
The EU has introduced a new transaction ban targeting designated third countries whose crypto-asset service providers are found to have systematically and persistently facilitated the circumvention of EU sanctions against Russia. Any crypto-asset services provider established in such a designated country would automatically become subject to the transaction ban. No countries have yet been designated under this new provision.
Trade restrictions
The EU has expanded the product scope in relation to the export ban on advanced technology items by adding specialty metals and powders, advanced self-adhesive films and strips, and specific UAV-related items. In addition, the EU has added 51 entities deemed as linked to the Russian military-industrial complex—some of which are based in China (including Hong Kong), Türkiye, Kyrgyzstan, India, Kazakhstan and the UAE— to the list of entities to which dual-use or restricted advanced technology goods (and related assistance/services) may not be provided.
The EU has also expanded the existing import ban on goods to include copper, nickel, lead and precious-metal ores, unwrought zinc and zinc oxides, chromium oxides, specialty glass products and car parts.
Other measures
The EU has expanded the so-called non-recognition obligation and anti-suit injunction framework in relation to transactions impacted by EU sanctions, including to cover any Russian court or authority decision against an EU person and so that EU nationals or companies may now obtain Member State court orders directing a party pursuing certain Russian court proceedings either to discontinue the proceedings or not seek enforcement or recognition of any resulting decision in any jurisdiction.
Finally, the deadline for various types of Member State authorizations under derogations to permit divestment from Russia or the wind-down of business activities in Russia has been extended until December 31, 2027. This includes the derogations covering otherwise prohibited sale, supply or transfer of restricted goods (including related intellectual property rights and trade secrets); provision of professional services; satisfaction of certain claims by Russian persons linked to contracts or transactions impacted by EU sanctions; and transactions to allow certain entities targeted by a transaction ban to withdraw from the EU (as well as a related exemption for joint venture wind-down transactions).
Asset freeze
The EU has designated 48 additional individuals and 168 additional entities on the EU asset freeze list. Key new designations target Russia's financial and crypto sectors, oil and gas companies operating refineries, mining and metals enterprises, and companies involved in manufacturing and supply of key items used by the defence industry (including in relation to UAV production).2 The EU has also introduced certain new derogations and exemptions, including in relation to Russian Railways and the Paks II civil nuclear project.3
Belarus
The EU has amended the sectoral sanctions against Belarus to largely mirror the new and expanded trade and services restrictions imposed on Russia, including in relation to the trade restrictions and certain crypto-asset services restrictions. The EU has also added new entities to the list of parties subject to tighter trade controls on dual-use items and goods contributing to Belarus's defence and security sector.4
Matthaios Koumoundouros (Trainee, Brussels) and Riikka Kuoppamäki (Professional Support Lawyer, London) contributed to the development of this publication.
1 See Council Regulation 833/2014 as amended by Council Regulation 2026/1848.
2 See Council Regulation 269/2014 as amended by Council Implementing Regulation 2026/1843.
3 See Council Regulation 269/2014 as amended by Council Regulation 2026/1844.
4 Council Regulation 765/2006 as amended by Council Regulation 2026/1846.
White & Case means the international legal practice comprising White & Case LLP, a New York State registered limited liability partnership, White & Case LLP, a limited liability partnership incorporated under English law and all other affiliated partnerships, companies and entities.
This article is prepared for the general information of interested persons. It is not, and does not attempt to be, comprehensive in nature. Due to the general nature of its content, it should not be regarded as legal advice.
© 2026 White & Case LLP
