Regulatory watch · Sanctions
EU 21st sanctions package: what changes in practice for exporters
Adopted on 23 July 2026, the package adds the largest number of designations since the start of the conflict and continues shifting compliance towards third-country distribution chains. Here is what to update in your procedures.
Disclaimer
This note is an operational reading for compliance and supply chain teams. It replaces neither the text of the regulations published in the Official Journal of the European Union nor legal advice on a specific situation. Swiss companies must separately check the transposition of these measures by Federal Council ordinances, whose timing and scope may differ.
What the package contains
Adopted on 23 July 2026, the twenty-first package of restrictive measures against Russia is accompanied by an extension of the measures targeting Belarus. It is characterised by an unprecedented volume of designations — more than two hundred new listings across individuals and entities — and by marked attention to circumvention through third countries.
- Financial sector: transaction bans extended to a substantial number of additional banks, new restrictions on crypto-asset service providers established in third countries, and measures relating to financial messaging services.
- Energy and maritime transport: an enlarged list of designated vessels, designation of ports, airports and refineries, and new notification duties on sales of LNG tankers to third-country buyers.
- Exports: new prohibitions covering metal powders, aerospace alloys and drone-production related items.
- Imports: new restrictions on several ores and metals, and on certain categories of car parts and specialty glass.
- Circumvention: around fifty entities established outside Russia — notably in China, Türkiye, Kyrgyzstan, India, Kazakhstan and the UAE — added to the lists restricting access to controlled goods.
Why this package matters more than its technical content
For most European industrial exporters, the direct impact of the newly prohibited tariff lines will be limited: few companies sell metal powders or aerospace alloys to Russia. The real impact lies elsewhere.
It lies in the continuing extension of designations to entities established in third countries. A company selling to a distributor in Türkiye, the UAE or Central Asia can no longer assume compliance stops at the EU border. These designations mean counterparties that were perfectly eligible six months ago no longer are, and that annual portfolio screening has no value.
It also lies in the logic now established: the duty to insert a contractual prohibition on re-export to Russia and Belarus for the most sensitive goods, the duty to use best efforts so that non-EU entities under your control do not undermine the measures, and the attention paid to volumes delivered to markets with no economic reason to absorb them.
Six actions to take
- Re-screen the entire portfolio. Customers, suppliers, forwarders, banks, known shareholders. A timestamped re-screen after each list update is what constitutes evidence of diligence; an annual re-screen does not.
- Redo the ownership analysis on counterparties in the third countries concerned. New designations mechanically create new entities owned beyond the 50% threshold that appear on no list themselves.
- Check the newly targeted tariff headings in your product master, both outbound and inbound, and block the corresponding product/destination combinations in your systems.
- Verify that no-re-export clauses are actually present in current contracts, not just in the template. The gap between the two is common.
- Analyse volume anomalies by market over the last twelve months. Unexplained growth towards a country neighbouring an embargoed zone is the most reliable signal available to you.
- Document what you did. Sanctions compliance is demonstrated by dated records, not by procedures. A timestamped re-screening log is worth more than a hundred-page manual.
The blind spot for groups
The best-efforts requirement concerning non-EU entities under your control changes the nature of the subject for any group with subsidiaries outside the Union. A Turkish, Emirati or Kazakh subsidiary continuing flows that have become prohibited no longer exposes only itself: it places the parent in a position that is hard to defend without written evidence of instructions given, checks performed and consequences drawn.
In practice this requires three elements few groups have formalised: a written instruction to subsidiaries, a control framework applicable to their flows, and a record of the verifications carried out. It is the workstream we most frequently see opened since this obligation was introduced.
Frequently asked questions
Does Switzerland apply this package?
Switzerland has its own framework, based on the Embargo Act, and transposes European measures through Federal Council ordinances applied by SECO. It has adopted the substance of the successive packages, but on its own timetable and with occasional differences of scope. A Swiss company must therefore check the version of the applicable ordinance in force rather than relying directly on the EU regulation — while bearing in mind that its European subsidiaries, its banks and its customers may impose the EU standard contractually.
Should we re-screen after every package?
Yes, and the question is evidential as much as legal. Designations take effect on publication in the Official Journal with no grace period: a counterparty eligible one day may not be the next, while an order is being prepared. A re-screen triggered by the list update, timestamped and archived, is the record an authority or your bank will examine. It is also the easiest control to automate.
What do we do with a live order if the customer has just been designated?
Suspend performance and payment immediately, preserve all records, and have the situation analysed without delay — asset freeze and prohibition on making economic resources available apply from entry into force of the designation, regardless of when the contract was signed. Depending on the case, an authorisation request or a declaration to the competent authority may be required, and some regimes provide for framed wind-down periods. This is a situation where the analysis must be run with legal counsel, and where partial performance "just to finish the contract" is the worst possible choice.