New restrictions as part of the EU's 21st sanctions package

On July 23, 2026 the Council of the European Union adopted the 21st package of sanctions against Russia in response to its war of aggression against Ukraine. This is one of the largest batch of sanctions over the last four years, significantly expanding restrictions in the sectors of energy, finance (including crypto), trade and military-industrial complex. These sanctions aim to further cripple Russia’s ability to finance the war and bypass the previously introduced restrictions.

Crucial points of the 21st package of sanctions:

1. Individual (targeted) sanctions

•  48 private individuals and 170 legal entities have been included on the sanctions list (totalling 218 subjects, which is the largest number over the last four years).
•  Funds and economic assets are frozen for these persons and companies; moreover, it is prohibited to provide funds or resources to them.
•  The list has been also supplemented with subjects related to the Russian energy sector, banking sector, military industry and bypassing of sanctions. Within the context of Latvia, targeted sanctions apply to the chain of retail stores MERE (SIA LATPRODUKTI, UAB Valiente, etc.).

2. Energy sector

•  The automatic adjustment of the oil price cap mechanism is suspended until July 15 2027. The current price cap remains at USD 44.10 per barrel.
•  More than 40 new ‘shadow fleet’ vessels have been identified and sanctioned (the total number exceeds 670). Criteria for including vessels on the list have been expanded (including support services, bunkering).
•  Ban on transactions with certain oil refineries in Russia, Belarus and third countries, ports, airports and other objects of infrastructure.
•  New obligations and possible restrictions with regard to the selling of LNG tankers.

3. Financial sector and crypto

•  The ban on transactions expanded with additional 33 Russian credit institutions (the total number exceeds 100).
•  Sanctions against several third-country banks and financial institutions involved in the bypassing of sanctions (including in Kyrgyzstan and other countries).
•  Stricter restrictions in relation to the providers of crypto services. A new mechanism introduced allowing to set a complete ban on transactions with third-country crypto platforms, if they are used for bypassing sanctions.

4. Trading and military-industrial complex

•  The export and transit ban expanded with regard to goods and technologies that might boost Russia’s military and technological power (including aviation components for unmanned aircraft, certain metals, alloys, etc.).
•  Import restrictions expanded with regard to ores, metals and other goods generating income.
•  Sanctions against 51 Russian and third-country legal entities that support Russia’s defence sector or are involved in bypassing of sanctions.

5. Measures against Belarus

•  Export and import restrictions as well as sanctions expanded against additional Belarusian companies, taking into account their involvement in aggression against Ukraine.

We encourage to consider whether the new sanctions might affect the operations of your company, paying special attention to the following:

•  current and planned transactions with partners that might be related to new subjects of sanctions;
•  supply chains, especially in the field of energy, finance, logistics and technology;
•  cooperation with third-country banks, providers of financial services or the so-called ‘shadow fleet’ vessels.

More information on the European Union sanctions and their application is available on the website of the Financial Intelligence Unit www.sankcijas.fid.gov.lv.

If you have any questions as to how the new sanctions might affect your transactions, partners and the operation of your company in general, please contact us. We will gladly provide explanations and help to ensure compliance with the applicable regulations.