Twenty packages, and counting.
Click any package below to read what it changed. The 20th, adopted 23 April 2026, sharpens the regime's anti-circumvention edge.
Council Regulation 833/2014 contains the sectoral economic restrictions; Council Regulation 269/2014 contains the asset-freezing and "no funds available" obligations. Both are binding regulations addressed to individuals, organisations and bodies under EU jurisdiction — not soft law, not guidance, not aspirational.
Anti-circumvention activated
Targets energy, financial services including crypto, trade, Russian military-industrial procurement, shadow-fleet infrastructure, media-propaganda mirror outlets, and third-country actors supporting Russia. Adds 46 shadow-fleet vessels (total 632), tanker-sale safeguards, port-infrastructure ban, prohibitions on RUBx and the digital rouble, and activates the EU anti-circumvention tool against Kyrgyzstan.
If you touch the Union, the rules touch you.
Regulation 833/2014 reaches EU territory, EU-flag aircraft and vessels, EU nationals worldwide, EU-incorporated legal persons worldwide, and any legal person in respect of business done in whole or in part within the Union.
Non-EU subsidiaries are more nuanced. The Commission accepts that EU sanctions do not apply extra-territorially in the same way to a Russian subsidiary incorporated under Russian law — but EU parents may not use those subsidiaries to circumvent obligations that apply to the parent. Since the 14th package, EU operators carry an additional "best efforts" duty to prevent owned or controlled non-EU entities from undermining EU restrictive measures, calibrated to size, control and circumstance.
The practical conclusion for German and Baltic operators is bracingly simple. If the company is established in the EU, has EU managers, uses EU banks, uses EU logistics, exports from the EU, invoices through the EU, or performs any part of the business in the EU — sanctions compliance is mandatory.
Four duties, ordered by severity.
Tap a duty to read its scope and the operational triggers that should make it bite.
Freeze, immediately.
Funds and economic resources belonging to, held by, owned by, or controlled by a listed person must be frozen. "Economic resources" is broader than money — it includes goods, real estate, shares, equipment, vessels, intellectual property, receivables and contractual rights.
Estonia's MFA describes the freeze as preventing sanctioned persons from accessing or realising financial resources in the EU, including cash, deposits, shares, and tangible or intangible property.
Triggers — freeze applies
- Counterparty match in 269/2014 listings
- UBO match — direct or indirect
- Vessel owner / manager listed
- Bank or payment intermediary listed
- Entity owned/controlled by a listed person
Indirect benefit is still benefit.
Even where no money flows directly to a listed party, providing goods, services, software, technology, labour, credit, transport, insurance or guarantees may be prohibited if it makes funds or economic resources available, directly or indirectly.
The Commission warns that entities owned or controlled by listed persons may also need to be treated as frozen — and that no funds or economic resources can be made available to them.
Triggers — availability test
- Service to entity controlled by listed person
- Goods routed through listed-party logistics
- Insurance or guarantee benefiting listed person
- Labour, training, or know-how transfer
- Credit terms benefiting frozen UBO
The operative test.
Operators must not knowingly and intentionally participate in arrangements whose object or effect is to circumvent sanctions. A "clean" immediate customer is not enough if facts suggest the real end user, financing source, destination or beneficiary is restricted.
Commission guidance instructs EU operators to assess how circumvention risk can materialise — including transfers to Russia via third countries — and to use trained staff, contractual monitoring and end-use verification as mitigation.
Triggers — enhanced due diligence
- New intermediary post 24 February 2022
- Third-country entity ordering Russia-relevant goods
- Pre-war Russia trade replaced by CIS / TR / UAE flows
- Refusal to accept Article 12g clause
- Ownership or address overlap with frozen entities
Document, report, retain.
Frozen funds, frozen economic resources, breaches and attempted circumventions must be reported to the competent authority. In Germany: funds → Bundesbank, economic resources → BAFA. EU exporters must inform their authority on becoming aware of any breach of a mandatory no-re-export-to-Russia clause.
The decision trail must survive audit — authorities will assess whether breaches were intentional, reckless, or negligent.
Triggers — report obligation
- Funds frozen at onboarding or in-flight
- Economic resources identified as frozen
- Breach or attempted breach of Art. 12g clause
- Suspected circumvention by counterparty
- Licence question or exemption request
Eight surfaces, one regime.
Click each row to expand. The Russia sanctions regime touches every commercial function — treat them as one perimeter with eight faces.
Putin, Lavrov, ministers, governors, Duma members, oligarchs, propagandists, military officials, persons involved in Bucha and Mariupol, missile strikes, deportation of Ukrainian children, drone manufacture, sanctions circumvention, and shadow-fleet operations.
Restrictions on Russian access to EU capital and financial markets; Central Bank, banks, SPFS, Mir, SBP; large deposits by Russian nationals; the Russian Direct Investment Fund; euro banknotes; crypto-asset service providers; trust services. The 20th package targets RUBx and the digital rouble.
Oil price-cap measures; bans on crude, petroleum products, coal, refined products from Russian oil in third countries, LNG and LPG; Nord Stream; gas storage capacity; investments in Russian LNG. The 20th package adds 46 vessels, port-access bans, tanker-sale safeguards.
Closure of EU airspace and ports to Russian aircraft and vessels; bans on aviation, maritime and space-sector goods; Russian road operators and trailers transporting goods into the EU; transactions with the Russian maritime shipping register; transport-related repair, maintenance and financial services.
Drone engines and components; arms; ammunition; military vehicles; IT, electronic and optical components; chemicals; navigational instruments; integrated circuits; CNC machine tools; wireless-communications electronics; manufacturing or testing equipment for electric components and circuit boards.
Bans on luxury goods exports; import bans on steel, iron, aluminium, copper and aluminium wire, cement, bitumen, asphalt, wood, paper, rubber, plastics, helium, chemicals, seafood, spirits, cigarettes, cosmetics, diamonds, gold, jewellery. The 20th package extends from rubber to tractors.
Mandatory prior authorisation for services to the Russian government; bans on accounting, audit, bookkeeping, tax, construction, architectural, engineering, cybersecurity, IT consultancy, legal advisory, advertising, market research, brokering, and IP / trade-secret services tied to restricted goods. Software support, remote maintenance and know-how transfer fall in scope.
Suspension of Kremlin-backed broadcasting; prohibition on EU political parties, NGOs, think-tanks and media accepting Russian state funding. The 20th package adds measures against mirror outlets and prohibits EU research institutes, universities and individuals from accepting Russian government funding.
Four flags, four enforcement architectures.
Hover or tap each country to focus its authority map.
Germany
- BundesbankFunds
- BAFAGoods · Resources
- ZollCustoms
- ZfSAsset enforcement
- AWG / AWVReformed 2024
Estonia
- FIUFinancial
- MFACoordination
- Int'l Sanctions ActImplementation
- Strategic Goods ActExport controls
- Penal CodeCriminal liability
Latvia
- FIU LatviaDefault authority
- MFACoordination
- Bank of LatviaFinancial sector
- SRSCustoms · Revenue
- OFAC overlayProcurement
Lithuania
- FCISFinancial
- MoEIDual-use · Military
- CustomsClassification
- MoEnergyEnergy
- MoTCTransport
Latvia's procurement overlay deserves attention. Public entities must comply not only with international and Latvian sanctions, but also with national sanctions of EU and NATO member states where significant financial-market interests are affected — meaning OFAC sanctions can travel into Latvian public-private partnership and procurement contexts. Latvian sanctions violations carry a maximum custodial sentence of eight years; control-system failures attract administrative fines up to EUR 5 million.
The "no re-export" clause is not optional.
Article 12g of Regulation 833/2014 requires EU exporters to insert a no-re-export-to-Russia clause in contracts for certain sensitive goods — and to walk away from non-EU operators who refuse it.
Scope: aviation goods, jet fuel, firearms, and Common High Priority items. The clause must contain adequate remedies — suspension, interruption, termination, financial penalties — strong enough to deter breach. Exporters must inform the competent authority once they become aware of a breach.
Mandatory no-re-export-to-Russia clause. Walk away if the counterparty refuses. Adequate remedies required: suspension, termination, financial penalties.
Sanctions clause, audit rights, end-use/end-user certificate, no onward transfer without consent.
Flow-down due diligence obligations and reseller screening. Distributor must apply equivalent controls to its own customer base.
No sanctioned vessels, no Russia/Belarus routing, no concealed transshipment, right to stop shipment in transit.
No sanctioned banks, no Russian payment systems, no crypto unless cleared, no third-party payer without approval.
Termination, suspension, indemnity, penalties; buyer certificates, UBO data, customs declarations and screening logs retained for the audit window.
Seven indicators, one perimeter.
Russian procurement networks layer intermediaries, geography, documentation, logistics and payment. Click each indicator to read it; the radar visualises their relative weight in current EU enforcement.
Indicators in current EU practice
A transaction, scored.
Compose a hypothetical transaction below. The simulator returns a risk tier and the prescribed control response — the same logic a working compliance team should apply.
Score a hypothetical cross-border deal.
Counterparty
Goods or service
Route & logistics
Payment
Prescribed response
Standard screening & documentation
A direct intra-EU transaction with established counterparties, non-sensitive goods, and a familiar payment route falls in the LOW tier. Apply baseline screening and periodic review; document the decision in the per-transaction sanctions file.
- Standard counterparty screening (name + address)
- Goods classification & HS code
- Standard payment screening
- Retain in per-transaction sanctions file
A programme, not a project.
Sanctions compliance must be owned at management level, with clear authority to block transactions. Ten functions carry day-to-day responsibility — sales, procurement, logistics, treasury, customs, export control, IT, legal, HR, audit.
The minimum-viable per-transaction file: counterparty legal name, registration, address; UBOs, directors; sanctions-screening result for names & addresses; goods/service classification; HS code; dual-use or military-list flag; destination, transit, end user, end use; bank, currency, payer, beneficiary; freight forwarder, carrier, vessel, port, route; Article 12g clause where required; red-flag checklist; approval decision and named approver; post-shipment monitoring where diversion risk is material.
Thirty, ninety, one hundred and eighty.
Click each item to mark it complete. The bar tracks programme maturity end-to-end.
- Appoint sanctions owner with authority to block transactions
- Update sanctions policy for the 20th package
- Implement screening — names, UBOs, addresses, vessels, banks
- Identify CHPL, dual-use, military-list, aviation exposure
- Update contract templates with Art. 12g and broader clauses
- Create red-flag escalation workflow
- Train Sales, Procurement, Logistics, Treasury, Customer Service
- Build product sanctions matrix in ERP / master data
- Automated screening at onboarding, order, shipment, payment
- Review distributors and resellers in high-risk jurisdictions
- Audit logistics lanes, forwarders, ports, vessel screening
- Audit Russia, Belarus, CIS, TR, UAE, China, Central Asia exposure
- Map non-EU subsidiaries; implement "best efforts" controls
- Authority-reporting templates for frozen assets & circumvention
- Internal audit testing of the programme end-to-end
- Review rejected and held transactions for control weakness
- Continuous monitoring for ownership changes & new listings
- Stress-test against realistic diversion scenarios
- Review management liability and D&O implications
- Align with AML, export control, customs, supplier DD, ESG
- Independent attestation of operating effectiveness
One question. Asked of every transaction.
For a company in Germany or the Baltic States, Russia sanctions compliance must now be built around counter-circumvention.
Could this transaction, payment, service, shipment, technology, contract, or business relationship — directly or indirectly — make goods, funds, services, technology, or economic resources available to Russia, a sanctioned person, an owned or controlled entity, Russia's military-industrial base, or a circumvention network?
If the answer cannot be confidently documented, the transaction should be stopped, escalated, and — where legally required — reported. That is the entire programme, in a sentence.