29 July 2026 EU Sanctions: 21 st Sanctions Package Against Russia On 23 July 2026, the Council of the European Union adopted its 21st package of restrictive measures against Russia, amending Regulation (EU) 833/2014 and Regulation (EU) 269/2014. These measures were implemented in Council Regulation (EU) 2026/1848, Council Implementing Regulation (EU) 2026/1843, Council Regulation (EU) 2026/1844 and Council Decision (CFSP) 2026/1845, and published in the Official Journal of the EU. The Council's press release can be found here and FAQs issued by the European Commission can be found here. The priority development for Members to note is that the EU has for the first time expanded the listing criteria to include vessels that service shadow fleet ships, whether or not designated. More broadly, the package comprises 218 individual and entity listings (170 entities and 48 individuals) including 94 Russian banks and financial institutions, which is the largest number of designations in a single package in four years, together with a range of sectoral, trade, financial and anti-circumvention measures. Key takeaways for Members • Shadow fleet expansion: 41 further vessels designated (under Council Regulation (EU) 2026/1848 amending Regulation (EU) 833/2014), bringing the total number of sanctioned vessels to over 670, including, for the first time under widened criteria, five bunkering tankers alleged to have regularly refuelled designated vessels. • New power for EU Member States to confiscate and sell cargoes carried aboard detained shadow fleet vessels. • LNG carrier sales: owners must now notify their EU member state of residence of any sale of an LNG tanker to a third country. The European Commission will review, by 25 October 2026, whether to introduce a full ban on the sale of LNG tankers to Russia, which would also require sellers to take reasonable steps to ensure vessels sold to third countries are not resold or transferred to Russian interests, including via proxy ownership. • LNG trade: a one-year, renewable exemption permitting continued transport of Russian LNG to third countries under long-term contracts concluded before 24 February 2022, capped at 2025 volumes; all other previously agreed restrictions on Russian LNG, including the import ban from 1 January 2027, remain unchanged. • Oil price cap: the automatic adjustment mechanism has been paused for 12 months (until 15 July 2027), maintaining the price cap for Russian-origin crude oil at USD44.10 per barrel. • Further transaction bans: two Russian ports, four Russian airports, a Georgian refinery, and five oil traders, together with new designations of refineries in Russia and Belarus. • Designation of an individual identified as a central figure behind a network of fraudulent ship registries used to document ageing tankers engaged in Russian trades. Shadow Fleet and Vessel Designations Forty-one additional vessels have been designated under Regulation (EU) 2026/1848, taking the total number of such vessels to over 670. The new listings include non-EU tankers alleged to be circumventing the oil price cap, and vessels supporting Russia’s energy sector, transporting military equipment, or carrying grain removed from occupied Ukrainian territory. Designated vessels remain subject to an EU port access ban and a prohibition on the provision of a broad range of maritime services, including insurance, together with a ban on ship-to-ship transfers and other cargo transfers involving such