Sanctions against Russia: EU’s 20th Sanctions Package – No Maritime Services Ban…Yet

On 23rd April, 2026, the European Union adopted its 20th package of sanctions against Russia. As explored in this article, the measures further tighten restrictions on maritime activity connected with Russian oil exports and expands the EU’s targeting of the Russian “shadow fleet”. However, it did not, as anticipated, introduce a full maritime services ban, though it has paved the way for one in the future.

Future maritime transport ban for Russian oil

While the EU previously said that it intended to introduce a full maritime services ban in its 20th package, thereby replacing the price cap regime with a complete prohibition on the transport and related services of Russian crude oil and petroleum products, this was not agreed by all Member States.

As such, the 20th package only provides that the EU will work with the G7 and Price Cap Coalition countries to bring in a full ban on maritime services related to Russian crude oil and petroleum products. The EU has indicated that it will determine the timing of any entry into force, including any applicable wind‑down periods, but otherwise there are no further details as to when and how the ban may be implemented.

Shadow fleet targets and other designations

The EU has added a further 46 ships to the list of designated “shadow fleet”. This brings the total number of ships listed by the EU to 632.  Further designations target entities operating in third countries who are involved in the shadow fleet ecosystem, as well as a Russian insurance company, Soglasie, for its role in the insurance of Russian ships.

Exemption for recycling of shadow fleet ships

To promote recycling over the continued operation of end-of-life shadow fleet tankers, and to allow EU operators to participate in recycling activities, a new derogation has been implemented to facilitate the responsible recycling of these ships.

Port transaction bans

The latest sanctions package broadens the scope of existing port-related restrictions, by imposing a transaction ban relating to the Russian ports of Murmansk and Tuapse.

By way of reminder, as detailed in our previous article, the port transaction ban was introduced in the EU’s 16th package of sanctions, prohibiting any transaction, directly or indirectly, with certain ports or locks, subject to certain exemptions. The ports originally listed were Astrakhan, Makhachkala, Ust-Luga, Primorsk and Novorossiysk. The EU has also now listed a port located in a third country, the Karimun Oil Terminal in Indonesia, reflecting concerns regarding circumvention of the oil price cap through third‑country infrastructure. The existing reporting obligation for EU entities will also now apply in relation to calls at Murmansk, Tuapse and Karimun.

Tanker sales: new enhanced due diligence and contractual safeguards

New measures have been introduced to restrict the sale of tankers for use in the shadow fleet. Whilst it was already prohibited for EU sellers of tankers to transfer ownership, directly or indirectly, of such tankers to any Russian entity or for use in Russia, the latest measures introduce mandatory due diligence steps, including:

• EU sellers involved in the sale of tankers to any third country buyers, directly or indirectly, must now take appropriate steps (proportionate to their nature and size) to identify and assess the risks of retransfer to Russia or for use in Russia, and ensure those risk assessments are documented and kept up to date;  
• They must also implement appropriate due diligence and screening policies to mitigate and manage the risks of retransfer to Russia or for use in Russia;
• Any sale or transfer of ownership of a tanker by an EU seller to any third country must contain a written contractual prohibition on any further resale or transfer of the ship to any natural or legal person, entity or body in Russia or for use in Russia; and
• The sale contract must also include provisions requiring the purchaser’s commitment to mirror the prohibition of sale of any tankers to Russian buyers or for use in Russia, which must also be included in any further resale or transfer.

Restrictions on ice-breakers and LNG tankers

New restrictions have been introduced on ice-breakers operating in Russia, for their support in oil and gas exports, as well as Russia linked LNG tankers.

It shall be prohibited to provide, directly or indirectly, technical assistance, brokering services or financing or financial assistance, related to any ice-breaker (falling under CN code ex 8906 90) or to any LNG tanker (falling under CN code ex 8901 20), where such ship is registered under the flag of Russia, is certified by the Russian Maritime Register of Shipping, is owned or managed by any Russian natural or legal person, entity or body, is operating in Russia, or is for use in Russia. For the latter two categories the prohibition will come into force on 1st January, 2027, rather than 25th April, 2026 which applies for the other categories.

In addition, from 1st January, 2027, it shall be prohibited to provide, directly or indirectly, LNG terminal services (including offloading, storage, berthing, loading/unloading, regassification etc.) to any Russian entity, or to any entity established in the EU which is more than 50% owned or controlled by a Russian citizen or entity in Russia.

Further information can be found here.

If Members have any questions in relation to the above issues they are invited to contact the Club for further information.