The European Union is facing a further tightening of its sanctions policy towards Russia. The background includes several drone incidents and suspected Russian hybrid activities in Europe. Most recently, European foreign ministers met in Wicklow, Ireland, on 2 September to discuss appropriate further measures. Particular attention was paid to the suspected Russian drone attack at Leipzig/Halle Airport: on the evening of 4 August, a drone equipped with explosives and a detonating mechanism was discovered in the security area near Ukrainian cargo aircraft.
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The German Federal Government holds Russia responsible for the failed attack and is already responding at national level with further measures against Russian nationals and institutions: the Russian Consulate General in Bonn is to be closed on 18 September, the contract for the Russian House in Berlin is to be terminated, and entry controls for Russian nationals are to be further tightened. Germany is also calling for further sanctions at EU level. The Member States are broadly in agreement that pressure on Russia should be increased. However, the precise form of the new sanctions remains open.
21st sanctions package as the starting point
The 21st sanctions package was adopted on 23 July 2026. Numerous additional individuals and companies were sanctioned and existing sectoral measures against Russia were tightened. In total, the package comprised 218 new listings, including 48 individuals and 170 organisations. Key areas included Russia’s shadow fleet, the financial sector including crypto-assets, and Russia’s military-industrial complex. The 22nd sanctions package could primarily follow the same approach and further tighten existing measures. The following four areas are likely to be particularly relevant.
22nd sanctions package: potential areas of focus
Shadow fleet: Despite existing sanctions, Russia continues to use its shadow fleet to transport oil to international markets, thereby financing its war of aggression. The 21st package already imposed a port access ban on a further 41 vessels and listed eight companies and one individual associated with the fleet. The 22nd package could include further sanctions against vessels, shipping companies, operators and beneficial owners, as well as actors that merely support oil transportation, for example by providing bunkering services. For the financial sector, this means that business relationships with shipping companies and shipowners will need to be examined even more closely for links to the shadow fleet.
Crypto platforms: Crypto services provide Russia with another means of circumventing sanctions. The 21st package already sanctioned 14 crypto platforms based in third countries and, for the first time, introduced the possibility of a complete ban on crypto services from third countries. The 22nd package could add further providers in Russia and third countries, as well as impose more stringent requirements for the scrutiny of crypto transactions. This will also be relevant for financial institutions, which will need to pay closer attention to alternative payment channels.
Third countries: In order to make sanctions effective, actors in third countries are increasingly coming into focus. The 21st package already imposed a transaction ban on four banks outside Russia and added a further 51 companies to the export restrictions. Under the 22nd package, banks, companies and crypto service providers in third countries are likely to face greater scrutiny if they can be shown to contribute to sanctions circumvention.
Individual sanctions list: As extensive sectoral measures are often politically difficult to implement, discussions are taking place in parallel regarding a particularly large number of new individual listings. According to EU High Representative Kaja Kallas, around 1,600 new listings relating to the military-industrial complex are being prepared. On 2 September, however, she stressed that no decision on these had yet been taken at the informal meeting of foreign ministers. The figure therefore refers to measures under preparation, not measures that have been adopted.
Implications for the financial sector
Further sanctions will mean increased due diligence and compliance requirements for German and European financial institutions. This applies in particular to transactions involving crypto-assets, whose international and complex structures present particular challenges for scrutiny. In addition to traditional sanctions screening, it is becoming increasingly important to understand the actual economic background and payment flows of a transaction. This includes the continuous screening of individuals and companies, the careful identification of beneficial owners across multiple levels, and the review of business relationships with crypto-asset service providers.
What should affected financial institutions review?
- Are individuals and companies continuously screened against existing sanctions?
- Are beneficial owners reliably identified across multiple levels?
- Do transactions pass through brokers, other intermediaries or accounts in a third country? How high is the risk of sanctions circumvention there?
- Are there business relationships with crypto service providers with links to Russia?
- Are potential circumvention structures involving intermediaries or third countries identified at an early stage?
Simply asking whether a business partner appears on a sanctions list will no longer be sufficient. What will matter is who actually stands behind a business relationship, where the funds are flowing and whether a transaction could form part of a sanctions circumvention scheme.
Conclusion and outlook
The meeting of foreign ministers demonstrates the broad agreement among EU Member States to further increase pressure on Russia. Although the 22nd sanctions package has not yet been officially adopted, developments to date already indicate its likely direction: the shadow fleet, crypto service providers, third-country actors and the approximately 1,600 new listings currently under preparation are likely to play a central role. For German financial institutions, this primarily means even closer scrutiny of business partners and transactions, as well as increasing AML and sanctions compliance requirements. Sanctions compliance therefore remains not a static state, but an ongoing process that must continuously be adapted to new developments.
