EU Sanctions: 20th Sanctions Package Against Russia

On 23 April 2026, the Council of the European Union adopted its 20th package of
restrictive measures against Russia, amending Regulation (EU) 833/2014 and
Regulation (EU) 269/2014. These measures were implemented in Council Regulation
(EU) 2026/506, Council Implementing Regulation (EU) 2026/509, and Council
Regulation (EU) 2026/511 and published in the Official Journal of the EU. Further
details can be found here. The EU also issued FAQs in relation to the 20th package
which can be found here.
The package comprises 120 individual and entity listings, the largest number in a
single package in two years, together with a range of sectoral, trade, financial and anti
circumvention measures.
This update summarises the key measures of particular relevance to shipping, marine
insurance, and related maritime services.
Key takeaways for Members
• Significant expansion of the shadow fleet regime, including 46 newly listed
vessels and new tanker sale due-diligence obligations.
• Ban on financial services including insurance to LNG tankers: Russian
owned or flagged from 25 April 2026; all others operating in Russia or for use
in Russia from 1 January 2027
• Establishment of the legal basis for a future full maritime services ban for
Russian crude oil and petroleum products, pending coordinated G7
implementation.
• New transaction bans on 2 Russian ports – Murmansk and Tuapse, and
the Karimun Oil Terminal in Indonesia
• First use of the EU’s country-level anti-circumvention tool, targeting
exports to the Kyrgyz Republic.
Shadow Fleet and Vessel Designations
Forty six additional vessels have been designated under Regulation (EU) 269/2014,
bringing the total number of designated shadow fleet vessels to 632. Eleven vessels
have been delisted following demonstrated return to compliance by their owners.
Designated vessels are subject to an EU port access ban and a prohibition on the
provision of a broad range of services related to maritime transport, including
insurance, as well as a prohibition on ship-to-ship transfers and any other cargo
transfer involving such vessels.

A derogation has been introduced to facilitate the recycling of listed shadow fleet
vessels that have reached end-of-life, including activities necessary for such vessels
to proceed to the recycling facility, and for any relevant activities or for payments
related to the recycling.
Entity Designations
A total of 120 individuals and entities have been designated. The 36 energy-related
designations cover both the upstream and downstream segments of the Russian
energy sector, including exploration, extraction, refining, and transportation of oil. They
include entities operating in third countries as part of the shadow fleet ecosystem, and
the Russian insurance company, Soglasie (also designated by the UK since 9th May
2025).
The following entities in the energy sector entities are now subject to an asset freeze:
Bashneft, Slavneft, Gazprom Flot, Gazprom LNG Technologies, Gazpromneft Marine
Bunker, Rosneftflot, and Lukoil Nizhnevolzhskneft.
A number of UAE-based ship management entities have been designated: Centauri
Services LLC, Lumen Ship Management FZCO, Alghaf Marine DMCC, and Lark Ship
Management LLC. Novus Middle East, which controls the previously designated
2Rivers Group, is also listed. Moran Security Group has been designated for supplying
personnel to provide security to shadow fleet tankers.
Furthermore, 58 designations specifically target actors associated with Russia’s
military-industrial complex, including 16 entities established in third countries, notably
China, UAE, Belarus, and states in Central Asia.
Port Transaction Bans
Transaction bans have been introduced on the Russian ports of Murmansk and
Tuapse and on the oil terminal at the port of Karimun in Indonesia (under Article 5ae
of Regulation (EU) no. 833/2014).
Maritime Services Ban: Legal Basis Established
The package establishes the legal basis for a future full prohibition on the provision of
maritime services, including insurance, to vessels transporting Russian crude oil and
petroleum products. In practical terms, such a prohibition would ban the transport of
Russian oil and related services including financing and insurance to vessels carrying
Russian oil. The Council will decide when this prohibition is to enter into force, taking
into account an appropriate wind-down period, following coordination with the G7 and
the Price Cap Coalition. No decision on phase-in has been taken at this stage.

Services for Russian LNG Tankers and Icebreakers
With effect from 25 April 2026, it is prohibited to provide technical, financial, or
brokering services, including insurance, for Russia-flagged, certified or Russian
managed LNG tankers and icebreakers.
With effect from 1 January 2027, it is prohibited to provide technical, financial, or
brokering services, including insurance to LNG tankers – not Russian-flagged or
owned, but operating in Russia or for use in Russia.
With effect from 1 January 2027, it will also be prohibited to provide LNG terminal
services to Russian entities or to entities owned or controlled by Russian nationals or
operators.
Tanker Sales
The package introduces mandatory due diligence requirements for EU operators
engaged in the sale of tankers. All tanker sale contracts are required to include a
mandatory clause prohibiting resale to Russian entities or use in Russia. Sellers must
carry out and document a risk assessment addressing the possibility of re-transfer to
Russia, adopt appropriate controls to mitigate identified risks, and promptly notify the
competent authority of the relevant Member State of any sale, including full details of
the parties and the vessel (IMO number and call sign).
The “no-Russia” resale prohibition must be mirrored through the contractual chain,
requiring third-country purchasers to impose equivalent restrictions on any onward
transfer to ensure that such obligations bind all subsequent acquirers.
Financial Measures
A transaction ban has been extended to an additional 20 Russian banks. Four financial
institutions in Kyrgyzstan, Laos, and Azerbaijan have been subjected to a transaction
ban for assisting Russian entities in circumventing EU sanctions or for connection to
Russia’s financial messaging network. Five financial institutions have been removed
from the transaction ban list following successful engagement with third-country
jurisdictions.
Anti-Circumvention
The EU has applied its anti-circumvention tool at country level for the first time,
restricting the export to Kyrgyzstan of certain machine tools and telecommunications
equipment used for drones and missiles, assessed as being systematically re
exported to Russia.
Legal protections for EU operators
The package strengthens protections for EU operators against retaliatory and abusive
litigation. EU courts may now issue orders requiring parties to cease or refrain from                                                                                                                                                initiating proceedings before Russian courts that assert jurisdiction over disputes
affected by EU sanctions.
In addition, EU persons may bring claims for damages before the courts of Member
States against parties seeking to enforce Russian court or administrative decisions in
third countries, including in cases involving illegitimate expropriations.
The prohibition on satisfying claims has been further expanded to cover claims brought
by third-country persons (other than those established in listed partner countries) in
connection with contracts or transactions affected by EU sanctions.
Other Measures
The package introduces new import bans on metals, chemicals, and minerals worth
over €530 million, an import quota on Russian ammonia, a ban on the provision of
cybersecurity services to Russia, new export restrictions on chemicals, rubber, steel
components, and certain industrial equipment, and measures protecting EU operators
against retaliatory legal proceedings in Russian courts and the enforcement of abusive
Russian judgments in third countries.
Members are reminded that cover is not available for any trade that breaches
applicable sanctions. Members are advised that they should conduct thorough due
diligence on the parties, cargoes, vessels, and other service providers that are or may
be involved before they engage in any trade with a high sanctions risk. Finally,
Members are reminded to keep records of their due diligence investigations and
findings.
All Clubs in the International Group have issued a similarly worded circular.
If you have any questions, please contact Ingvild Høgenes Nilsen, Executive Vice
President, Corporate Legal, Chief Legal Officer in Gard

Yours faithfully,
GARD AS

Rolf Thore Roppestad
Chief Executive Officer

Source: assets.eu.ctfassets.net