
The package focuses on energy, banking, crypto assets, military production, and sanctions evasion networks, while also introducing the largest number of individual sanctions listings in four years.
Key measures include:
- Major expansion of designated persons and entities: The package adds 218 new sanctions listings (48 individuals and 170 entities), making it the largest round of listings in four years.
- Increased focus on financial institutions: The EU imposed asset freezes and funding prohibitions on 94 banks and major financial institutions and extended transaction restrictions to 33 additional Russian financial institutions.
- Crypto-asset risks have become a major enforcement priority: The EU extended restrictions to 14 crypto-service providers and created a mechanism for broader bans on crypto providers that facilitate sanctions evasion.
- Focus on sanctions circumvention through third countries: The package specifically targets entities and institutions in jurisdictions where authorities believe there is circumvention of sanctions.
- Targeted networks: The sanctions package continues targeting networks supporting Russia's military-industrial sector, energy sector and shadow fleet. Many sanctioned entities operate through complex ownership structures and intermediaries.
- Property and corporate transaction risks: The package significantly expands sanctions on oil traders, refineries, shipping companies, military-industrial firms, logistics service providers.
- Asset freeze obligations: The substantial increase in designations raises the risk of inadvertent breaches.
For more information see the 21st Package of Sanctions in the Official Journal or the EU Council Press Release on 21st Package of Sanctions.