EU 20th Russia Sanctions Package: cryptoasset ban, shadow-fleet expansion, anti-circumvention upgrade

The EU adopted its 20th Russia sanctions package on 23 April 2026, entering into force in phased tranches through 24 May 2026, with certain LNG provisions deferred to January 2027. The package introduces a blanket prohibition on transactions with all Russia-based cryptoasset service providers (not entity-by-entity listings), bans the digital ruble and RUBx cryptoasset, adds 46 vessels to the EU port ban (bringing the total to 632 sanctioned vessels), lists Murmansk and Tuapse as sanctioned ports, and — for the first time — lists a third-country port, the Karimun Oil Terminal in Indonesia, for facilitating oil-price-cap circumvention. Sixty new entities were added to Annex IV dual-use listings, including entities based in China/Hong Kong, Thailand, Turkey and the UAE. Law firms and in-house teams should review digital-asset and trade-finance transaction flows against Russia immediately; LNG service contracts with Russian or Russian-controlled parties need legal-consequence analysis before the January 2027 window; and tanker-vessel sales require new contractual prohibitions on resale/retransfer to Russia with immediate notification obligations to competent authorities.