April 2026 – EU Member States have adopted the 20th package of sanctions against Russia. The package has a pronounced anti‑circumvention focus and significantly expands measures affecting financial services and crypto‑assets. It is expressly designed to close existing and emerging circumvention pathways, including those involving third‑country financial institutions and crypto‑based payment rails. The legal acts entered into force on 24 April 2026.
For EU financial institutions and crypto‑asset service providers (CASPs), the new package raises compliance, enforcement, and governance expectations, requiring a review of exposures, internal controls, and escalation frameworks.
Expansion of banking and payment restrictions
