On 23 April 2026, the European Union adopted its 20th sanctions package against Russia. The package marks a noticeable shift in EU sanctions practice: the focus is no longer only on sanctioned individuals or entities, but increasingly also on financial actors, payment channels and infrastructure in third countries that may enable sanctions circumvention.
For banks, payment service providers and, in particular, Crypto-Asset Service Providers (“CASPs”), the package is highly relevant. The EU is sharpening its focus on alternative payment structures, financial operators in third countries and crypto-based circumvention mechanisms.
The package also contains further measures in areas such as energy, trade, maritime infrastructure and export controls. This article focuses on the measures that are particularly relevant for the financial sector.
What is new?
The package introduces several financial-sector measures:
- Financial sector: The transaction ban is extended to 20 additional Russian banks. According to the European Commission, this brings the number of Russian banks excluded from access to the EU internal market to 70. The measures particularly target banks enabling cross-border payments that support the Russian economy.
- Third-country financial intermediaries: The EU extends the transaction ban to four banks in Kyrgyzstan, Laos and Azerbaijan that assist the Russian war effort by significantly frustrating sanctions or by connecting to the Russian System for Transfer of Financial Messages (“SPFS”).
- Crypto: The package introduces a total sectorial ban on carrying out transactions with Russian crypto asset service providers as well as decentralised platforms enabling crypto trading, due to their use in sanctions circumvention.
- Digital currencies: The measures also cover the digital rouble and the rouble-backed stablecoin RUBx. The new restrictions prohibit the use of, and support for, these structures, as the EU considers them potential instruments for circumventing existing financial sanctions.
- Payment services: The package also introduces measures against so-called payment agents in Russia and other third countries. These are intermediaries that facilitate international transactions from Russia in order to bypass EU sanctions.
- Anti-circumvention tool: For the first time, the EU activates its anti-circumvention tool due to re-export structures via the Kyrgyz Republic.
- Maritime infrastructure / shadow fleet: The EU further tightens measures against Russia’s shadow fleet. A total of 632 vessels in Russia’s shadow fleet are now listed by the EU.
What does this mean in practice?
For banks and especially CASPs, it is increasingly insufficient to screen only against sanctions lists.
The new measures show that the relevant question is not only who an institution is dealing with, but also through which payment channels, intermediaries or platforms transactions are processed.
In practice, this means:
- Third-country risks require closer attention.
Payment and trade structures involving third countries may create increased circumvention risks, particularly where they facilitate the acquisition of dual-use goods, high-tech items or sanctioned goods for Russia.
- Alternative payment structures are moving into focus.
The measures against payment agents show that the EU is targeting cross-border payment structures designed to give Russian companies access to foreign suppliers.
- Crypto compliance is becoming more infrastructure-based.
CASPs should assess whether business relationships or transactions may be indirectly connected to Russian crypto service providers or Russia-related settlement structures.
- Stablecoin and CBDC risks belong in the sanctions risk assessment.
RUBx and the digital rouble show that the EU expressly treats alternative payment and settlement structures as sanctions circumvention risks.
- Sanctions circumvention is becoming a standalone compliance focus.
The regulatory focus is no longer limited to listed persons or entities. It increasingly includes payment channels, intermediaries, third-country structures and economic networks through which sanctions may be circumvented.
What should affected institutions and service providers review now?
Affected institutions and service providers should in particular assess:
- Are there any direct or indirect touchpoints with Russian crypto asset service providers?
- Are transactions processed via third countries with increased circumvention risks?
- Could Russian customers or Russia-related counterparties be connected through third-country accounts, brokers or other intermediaries?
- Are stablecoins, crypto-based settlement structures or digital currencies with a Russia or rouble nexus being used?
- Are existing sanctions controls capable of identifying indirect risks and multi-step transaction chains?
- Are escalation, documentation and governance processes aligned with current circumvention typologies?
Conclusion
The 20th EU sanctions package is more than another update. It confirms a clear trend: the EU is increasingly addressing sanctions circumvention in a systemic way.
For the financial sector, this means that sanctions compliance is moving away from a purely list-based screening exercise towards a broader analysis of payment channels, intermediaries, third-country exposure and infrastructure relationships.
Particularly in the crypto sector, blockchain analysis and a robust understanding of platform, liquidity and settlement structures are becoming increasingly important. Institutions that cannot determine whether transactions involve Russia-related platforms or settlement structures may find it increasingly difficult to demonstrate that their controls are effective, auditable and fit for purpose.
