Sanctions and export control update

The 20th sanctions package was adopted by the Council on 23 April 2026, introducing further amendments to the existing framework of restrictive measures in response to Russia's ongoing war against Ukraine. The package comprises a range of measures concerning Russia's energy revenues, military-industrial complex, and trade and financial services, 120 new individual listings, and several structural innovations, including the first-ever use of the EU's anti-circumvention tool. Norway implemented the 20th package into Norwegian law with amendments that entered into force on 14 July 2026, largely corresponding to the EU measures. 

Energy measures

• Maritime transport of oil: The package lays the legal groundwork for a future ban on maritime transport services for Russian crude oil and petroleum products.
   
• LNG terminal services: From 1 January 2027, it will be illegal to provide LNG terminal services to Russian entities or entities owned or controlled by Russian nationals or operators. Existing contracts must be terminated by that date.
   
• Ancillary services ban: New restrictions bar ancillary services to Russian-linked LNG tankers and icebreakers.
   
• New listings: 36 entities across the Russian energy sector's upstream and downstream operations (exploration, extraction, refining, transportation) were added. The list of vessels that are subject to restrictions grew by 46 vessels (11 delisted), covering measures such as port access and flag registration bans. This also shows that delisting is a possibility for vessels returning to compliance.
   
• Tanker sales and shadow fleet: EU sellers of tankers must now conduct mandatory due diligence and include a contractual "no Russia" clause, alongside a new scrapping clause designed to help vessels exit the shadow fleet.
   
• Extraterritorial reach: For the first time, the port infrastructure ban extends beyond Russian territory, a terminal in Indonesia, due to its stated role in shadow fleet operations and circumvention of the oil price cap. 
   

Financial measures and crypto

• Transaction ban: An additional 20 Russian banks were made subject to the transaction ban, with narrow exceptions such as for humanitarian transactions.
   
• Third-country financial institutions supporting Russia: Four financial institutions in third countries were also brought within the transaction ban, including for their connection to Russia's domestic banking messaging network (SPFS).
   
• Crypto services and exchange: Sweeping ban on dealings with Russian crypto asset service providers and with decentralised trading platforms, due to their use in circumventing sanctions.
   
• Payment services: The package prohibits transactions with agents in Russia and other third countries facilitating international transactions from Russia in order to bypass EU sanctions.
   

Trade measures and military-industrial complex

• Export bans: New export prohibitions cover a range of goods, including rubber products and agricultural and industrial machinery. Further restrictions target items and technologies used in Russia's military effort, such as explosives, laboratory glassware, and high-performance lubricants and additives.
   
• Import bans and quotas: New import bans cover metals, chemicals and minerals not previously sanctioned, alongside a new quota on ammonia imports.
   
• Military-industrial complex: Export prohibitions were extended to 60 additional entities – 32 Russian and 28 based in third countries – for indirectly supporting Russia's military-industrial complex.
   
• Listings of producers and global suppliers: 58 companies and associated individuals involved in developing and manufacturing military goods, such as drones, were designated. Further listings target third-country suppliers of critical high-tech items, including entities in China, the UAE, Uzbekistan, Kazakhstan and Belarus.
   

Other measures

• EU's anti-circumvention tool: The package marked the first-ever use of the EU's anti-circumvention tool, introduced under the 11th sanctions package in 2023. The tool allows the EU to restrict the sale, supply, transfer, or export of certain goods to specific third countries when those jurisdictions persistently fail to prevent the re-export of those items to Russia The tool was activated against Kyrgyzstan to prevent the onward export to Russia of machine tools and telecommunications equipment used in manufacturing Russian drones and missiles.
   
• Legal protection of EU operators: The package strengthens legal protections for EU companies facing proceedings before Russian courts.

The EU's 21st sanctions package was adopted by the Council on 23 July 2026. It is the largest package of individual listings adopted in the past four years, adding 218 listings in total (48 individuals and 170 entities). The package has not yet been implemented in Norwegian law. However, as Norway has consistently aligned with previous EU sanctions against Russia, it is expected to be implemented through amendments to the sanctions regulations. We are monitoring the political and legal developments closely.

Energy measures

• Oil price cap freeze: The Russian crude oil price cap is frozen at USD 44.10 per barrel until 15 July 2027, with the automatic adjustment mechanism suspended.
   
• Expanded "shadow fleet" measures: The criteria for designating vessels linked to Russia's "shadow fleet" now also cover vessels providing bunkering, tug or ship-to-ship transfer services to already-designated vessels. The EU has also added 41 vessels to the shadow-fleet list.
   
• Refineries and infrastructure: The package designates 18 entities and one individual in the oil  sector. It creates the possibility to prohibit transactions with listed refineries in Russia and in third countries processing or refining Russian crude oil and petroleum products. Two Russian ports and four Russian airports have also been listed.
   
• LNG: New rules introduce notification requirements for LNG tanker sales, a mandatory contractual prohibition on resale or transfer of the vessel to Russia, and a temporary conditional exemption for certain transfers of Russian LNG to third countries.
   

Financial measures and crypto

• 94 Russian financial institutions have been listed, bringing nearly all Russian banks within EU asset-freeze measures.
   
• Transaction ban: 33 additional Russian credit and financial institutions join the transaction ban, Furthermore, it is introducing a transaction ban against a Kyrgyz bank connected with the SPFS and three other non-Russian banks for circumventing sanctions.
   
• Crypto: Four designations were added relating to the cross-border A7 network, including its new links to Africa. The transaction ban was extended to 14 crypto-related platforms in several third countries, and the EU introduced the possibility of a full third-country ban for crypto-asset services used by Russia. 
   
• Wind-down: New wind-down provisions allow EU, EEA and Swiss nationals, subject to authorisation, to withdraw funds and close accounts with newly designated banks and crypto/payment providers.
   

Trade measures and military-industrial complex

• Military-industrial complex: 56 individuals and entities linked to Russia’s military-industrial complex have been designated, including actors involved in long-range drone production. A further 51 entities have been made subject to enhanced export controls on dual-use goods and technologies, including entities in third countries involved in sanctions circumvention.
   
• Exports: Export restrictions have been expanded to additional goods and technologies used by Russia’s military industry, including certain nickel and beryllium products, aerospace materials and UAV-related aviation items.
   
• Imports: New import restrictions cover a range of Russian goods, including metal ores, precious-metal ores, zinc and chromium products, glassware, imitation pearls and car parts.

On 3 August 2026, the EU received €1.4 billion in interest income generated by immobilised assets belonging to Russia's central bank – the fifth transfer of its kind, covering revenue from the first half of 2026. In total, the immobilised assets have generated €8 billion since they were frozen. The funds are being split, with 95% going to the Ukraine Loan Cooperation Mechanism (helping Ukraine repay the EU's macro-financial assistance loan and G7 loans), and 5% to cover military and defence-related needs. The underlying assets themselves remain frozen, but the Council has ruled that the interest they generate does not belong to Russia and can therefore be used to support Ukraine.

Chinese countermeasures to Western trade restrictions continues to be a hot topic, as China recently issued its first judicial confirmation that compliance with foreign sanctions cannot excuse a breach of contract. In a Shanghai Maritime Court judgment, published by the Supreme People's Court on 24 June 2026 as a 2025 national typical maritime case, a Singaporean carrier was found liable for refusing cargo delivery based on the shipper's foreign sanctions listing, and ordered to pay the Hong Kong shipper approximately RMB 4.99 million plus interest. This marks the first judicial application of China's Anti-Foreign Sanctions Law (AFSL), with the court holding that Article 12 overrides the parties' choice of law or contractual arrangements.

While a typical case is not binding precedent, it carries significant weight and is generally followed by Chinese courts. For clients with Chinese counterparties, the key takeaway is that a sanctions clause can no longer be treated as a safe default for pausing or terminating the performance of contractual obligations, as Chinese courts may reject it as a valid defence. Combined with an earlier Nanjing Maritime Court case and new regulatory tools, this suggests Chinese authorities are encouraging more proactive use of the AFSL, and we expect more AFSL-based claims and defences going forward.

For our clients with Chinese counterparties, the decision is a reminder that where Chinese law or Chinese courts are relevant, reliance on foreign-sanctions clauses may not shield a party from liability for non-performance under Chinese law. 

Sanctions also continue to be a topic in the context of the Israel and Palestine conflict. On 19 June 2026, the Norwegian Government submitted for public consultation a proposal for a new law prohibiting trade with Israeli settlements in Palestine. The proposal would introduce four prohibitions: (i) import/export of goods originating in or destined for the settlements; (ii) purchase or acquisition of real estate; (iii) provision of certain property-related services; and (iv) acquisition of stakes in businesses in the settlements. Only two exceptions are proposed – a sufficient Palestinian nexus, and a humanitarian carve-out. 

Violations would constitute criminal offences, with the ordinary double criminality requirement disapplied so conduct abroad can still be prosecuted in Norway. Businesses trading with Israel, engaging in settlement-related real estate or share acquisitions, or providing related services – including banks, insurers and freight forwarders exposed via complicity liability – should review their supply chains and due diligence frameworks. This should include indirect trade exposure. Companies with a U.S. nexus should also watch for potential tension with U.S. anti-boycott laws, which the Ministry's proposal unfortunately is yet to address in the bill proposal. 

The consultation period runs until 19 September 2026, with adoption not likely before the end of 2026 or early 2027. At the EU level, an EU-wide ban on imports from Israeli settlements is also under consideration, with the issue recently having been discussed among EU foreign ministers on 13 July 2026. We will be monitoring the political and legal developments on this field closely.

Schjødt's corporate compliance team is experienced in all aspects of sanctions and export control-related matters, including risk assessments and associated review of projects, business partners and M&A-activities that may entail an increased sanctions risk. We have an extensive global network consisting of leading compliance and white-collar crime specialists and can efficiently include relevant local knowledge in our assistance.

Please note that these updates do not constitute legal advice, nor do they provide an exhaustive description of all sanctions in place and the exemptions. Any person or entity involved, directly or indirectly, in business activities in any way directly or indirectly related to countries, entities or persons targeted by sanctions should carefully assess how they are affected by the sanctions. Schjødt's team is ready to assist in this regard.