EU Crypto and LNG Restrictions in the 21st Package — New Risk Categories for Transactional Practices

Beyond the bank transaction bans, the EU's 21st Russia sanctions package introduced two new risk categories that require specific assessment by transactional practices. On crypto: from August 25, Russian and Belarusian citizens and residents will be prohibited from owning, controlling, or holding posts in EU crypto-asset service providers — a prohibition now covering all CASPs under MiCA, not only those offering wallet, account, or custody services. A new framework also enables transaction bans against crypto platforms in third countries that help Russia evade sanctions, creating a mechanism that has no current targets but signals the EU's intent to extend crypto enforcement extraterritorially. On LNG: EU nationals, residents, and entities must now notify competent Member State authorities when arranging transfers of ownership of LNG tanker vessels to any third country, and the EU will assess after October 2026 whether to extend oil-tanker-style restrictions to LNG tankers. The Kulevi Oil Refinery in Georgia — a known processing point for Russian crude — faces a transaction ban from January 25, 2027 unless it diversifies its crude oil sources. For in-house counsel in financial services, energy, and shipping, each of these new measures requires a targeted compliance review: CASP employment and governance structures, LNG tanker ownership and vessel management arrangements, and supply chain crude oil sourcing documentation all need to be assessed against the August 25 and January 2027 effective dates.