On 15 June 2026, the European Union adopted a new listing package extending its sanctions against Russia. This is not the 21st sanctions package but rather an expansion of the existing sanctions lists to include additional designated persons and organisations. The newly listed entities are primarily associated with Russia’s military-industrial complex as well as propaganda and influence structures.
Table of Contents
The 21st sanctions package is already under preparation and was proposed by Commission President Ursula von der Leyen on 9 June 2026. It is intended to tighten restrictive measures in the energy, financial services, crypto-assets and trade sectors. In addition, a new area of sanctions is envisaged covering fishery and aquaculture products. This article outlines the key elements of both packages and focuses on their implications for the financial sector.
Listing package of 15 June 2026
The new listings affect a total of 47 organisations and 34 individuals. Newly designated entities primarily include companies involved in the production and supply of military-use goods, as well as persons and organisations participating in the export of crude oil and petroleum products. Once again, particular attention is paid to Russia’s so-called “shadow fleet”.
Furthermore, ten individuals and one organisation have been listed for spreading propaganda related to Russia’s war of aggression against Ukraine. Another ten individuals and one organisation have been sanctioned due to serious human rights violations within Russia.
The EU continues its strategy of increasingly targeting non-Russian actors as part of its sanctions regime. Accordingly, the listing package also includes several Chinese supplier companies.
21st sanctions package (proposed)
Financial and crypto sector
As with the previous package, the proposed 21st sanctions package is expected to strengthen and broaden restrictive measures affecting the financial and crypto sectors as well as financial intermediaries established in third countries.
According to the current proposal, transaction bans are expected to be extended to an additional 31 Russian banks as well as 20 banks, crypto firms, crypto platforms and oil traders located in third countries. These entities are alleged to have cooperated with Russian actors in sanctioned sectors or to have facilitated sanctions circumvention.
Russian shadow fleet and energy sector
Measures targeting Russia’s shadow fleet are also expected to be expanded. The total number of listed vessels could increase to 662.
For the first time, vessels providing supporting services to the shadow fleet are also expected to be covered. Furthermore, restrictions would no longer apply only to the sale of oil tankers but also to LNG tankers supplied to Russia. In addition, far-reaching sanctions against critical Russian infrastructure, including ports, airports and refineries, are under consideration.
Trade in goods (imports/exports) and travel bans
The proposal also introduces further export restrictions covering military-use goods, strategic resources and technologies. These measures range from certain metals and alloys to radar jamming systems.
Additional import restrictions are likewise envisaged, including, for the first time, phased import restrictions and import bans on certain fishery products.
Finally, travel bans are being discussed for current and former Russian combatants who have participated in military operations since the beginning of Russia’s war of aggression against Ukraine.
Implications for the financial sector
Both sanctions packages clearly demonstrate that the EU is increasingly extending its sanctions regime to actors located in third countries, including Belarus, China, Kyrgyzstan, Laos and Azerbaijan. Within the financial services sector in particular, these measures are intended to address emerging methods of sanctions circumvention.
Sanctioned entities are increasingly relying on alternative payment systems to facilitate international transactions involving Russia, while companies established in third countries often act as financial intermediaries.
From a sanctions compliance perspective, merely screening customers against sanctions lists will no longer be sufficient. Financial institutions should increasingly focus on:
- analysing payment and trade structures;
- assessing the commercial purpose of transactions, particularly whether they involve military-use goods, high-tech products or other sanctioned goods;
- within the crypto sector, verifying whether transactions or business relationships are connected to Russian crypto-asset service providers or other Russia-related settlement structures.
Questions financial institutions should consider
- Do current sanctions screening controls identify indirect risks and multi-layered transaction chains?
- Are governance, documentation and escalation procedures designed to address intermediary structures and complex payment routes?
- Are transactions processed through brokers, financial intermediaries or accounts located in third countries?
- What is the sanctions exposure associated with the relevant third country?
- Are there direct or indirect links to Russian crypto-asset service providers?
- Are digital currencies, such as stablecoins, or crypto-based settlement structures connected with Russia or the Russian rouble being used?
Conclusion and outlook
The Council of the European Union is expected to decide on the proposed 21st sanctions package by 15 July 2026.
It is already apparent that the EU intends to further diversify its sanctions regime by adopting a more comprehensive approach. Beyond traditional list-based sanctions, greater attention is being paid to alternative payment and trading structures as well as the involvement of entities established in third countries.
For financial market participants, this means continuously monitoring new sanctions circumvention mechanisms and adapting sanctions compliance frameworks accordingly.
