EU adopts a limited set of new sanctions against Russia ahead of the expected 21st package
On 15 June 2026, the Council of the European Union adopted a new set of restrictive measures targeting Russia's full-scale invasion against Ukraine, its hybrid activities, and systematic human rights violations. The package, adopted ahead of the broader 21st sanctions package currently under discussion at COREPER II, comprises additional listings of 34 individuals and 47 entities across multiple restrictive measures regimes, namely Regulation (EU) No 269/2014, Regulation (EU) 2024/2642 and Regulation (EU) 2024/1485.
Focus on third-country designations and secondary sanctions exposure
One of the most notable aspects of the latest package is the continued expansion of EU restrictive measures beyond Russia itself. The new designations adopted under Regulation (EU) No 269/2014 target not only Russian individuals and entities, but also a growing number of companies established in third countries that are alleged to support Russia’s military, energy or logistics sectors. The listings include entities located in China, Hong Kong, the United Arab Emirates, Türkiye, Azerbaijan and Liberia.
These measures illustrate the increasingly international dimension of the EU restrictive measures regime. While EU sanctions do not formally operate through secondary sanctions in the manner of certain non-EU jurisdictions (e.g., the US), the practical consequences for third-country operators can nevertheless be significant. Once designated under Regulation (EU) No 269/2014, an entity becomes subject to the EU asset-freeze regime, meaning that EU operators must freeze any funds or economic resources belonging to it and refrain from making funds or economic resources available to it, directly or indirectly.
As a result, risk exposure to EU restrictive measures may arise even where transactions have no immediate connection to Russia. Businesses dealing with companies located in third countries should remain attentive to the possibility that such counterparties may become subject to EU restrictive measures.
Overview of the main measures
Under Regulation (EU) No 269/2014, the Council targeted Russia's military-industrial complex, imposing restrictive measures:
a. On 7 individuals and 21 entities supporting the Russian defence sector, including manufacturers and suppliers of drones and other military equipment to the Russian armed forces; and
b. On Russia's shadow fleet ecosystem, listing 2 individuals and 24 entities involved in the shipment and export of crude oil or petroleum products from Russia, which poses a threat to maritime safety and the environment.
Regulation (EU) No 269/2014 now also includes a temporary derogation for Yangzhou Yangjie Electronic Technology Co., Ltd., a Chinese company. Subject to authorization by the competent national authority, frozen funds may be released or made available where necessary to wind down pre-existing contracts by 31 December 2026 or to purchase critical components while transitioning to alternative suppliers by 16 March 2027.
2. Under Regulation (EU) 2024/2642, the Council designated 10 individuals and one entity linked to Russia’s destabilising and information manipulation activities. The listed persons include several Russian propagandists, while the designated entity is the Presidential Foundation for Cultural Initiatives.
3. Under Regulation (EU) 2024/1485, the Council designated 15 individuals and one entity in connection with the poisoning of Alexei Navalny. The listings target Russian judges, prosecutors, security and medical personnel, as well as IPJSC NTK, a company involved in facial recognition systems used against journalists and opposition activists.
Separately, the Council renewed the restrictive measures relating to the illegal annexation of Crimea and the city of Sevastopol, extending their application until 23 June 2027.
Sources : Implementing regulation - EU - 2026/1361, Regulation - EU - 2026/1336 , Implementing regulation - EU - 2026/1356, Implementing regulation - EU - 2026/1362, Council of the EU - Press release - 15 June 2026 and Coreper II - Consilium.
For more information, please contact Bruno Lebrun – Partner – b.lebrun@janson.be