The EU’s 20th Russia package becomes an anti-circumvention operating manual
DLA Piper’s update shows the EU’s 20th Russia package moving beyond listings into anti-circumvention mechanics, including targeted restrictions on high-risk goods destined for Kyrgyzstan, more than 60 Annex IV additions, managed-cybersecurity restrictions, bank and crypto controls and maritime measures.
BY GEOPOLITICS DESK · MAY 21, 2026 · 1 MIN READ
DLA Piper’s update shows the EU’s 20th Russia package moving beyond listings into anti-circumvention mechanics, including targeted restrictions on high-risk goods destined for Kyrgyzstan, more than 60 Annex IV additions, managed-cybersecurity restrictions, bank and crypto controls and maritime measures. The legal significance is that trade, payments, cyber services and shipping now need a joined-up Russia-risk map.