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ARTICLE · 13 MAY 2025

EU's 20th Russia Sanctions Package: Key Changes And Compliance Implications

Greenberg Traurig
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The EU Council has adopted its 20th package of restrictive measures against Russia, introducing sweeping changes that include the first-ever use of the EU's anti-circumvention mechanism against a third country...

GlobalInternational Law
Erik de Bie
Erik de Bie
Lucas Wüsthof
Lucas Wüsthof
Claudia Amthor
Claudia Amthor

On 23 April 2026, the EU Council adopted its 20th package of restrictive measures against Russia, amending the core EU sanctions regulations that have been in place since 2014. The package expands existing restrictions across energy, finance, trade, and media, and introduces several new legal instruments, including the first use of the EU’s anti-circumvention mechanism against a third country and strengthened legal protections for EU operators. Companies with exposure to Russia, Belarus, or related supply chains should review the changes as summarized in this GT Alert.

Key Changes

1. Anti-Circumvention Mechanism: First Use Against a Third Country

The Kyrgyz Republic has been formally designated as a jurisdiction where circumvention of EU export controls is systematic and persistent. Imports of controlled EU goods into Kyrgyzstan rose by approximately 800% compared to pre-war levels; re-exports to Russia rose by approximately 1,200%. The goods concerned, primarily machining centres

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