EU Trends and Developments Contributed by: Valerijus Ostrovskis, Coline Cauvin, Yapa Thepkanjana and Delphine Buyle, ACQUIS
cance including the IRGC-owned Khatam al-Anbiya Construction Headquarters, Bank Sepah and Bank Melli. Syria: the progressive lifting of economic sanctions The EU’s handling of Syria in 2025 illustrates the other side of sanctions diplomacy: the calibrated removal of restrictions as an instrument of positive engagement. Following the fall of the Assad regime in December 2024, the EU responded in two stages. It first sus - pended sector-specific restrictions in energy and transport, then followed with a more comprehensive removal: as of 29 May 2025, the EU lifted most sanc - tions targeting Syria, delisting 24 entities including the Central Bank of Syria, and removing wide-ranging export and import bans including the ban on crude oil and petroleum products. The approach was calibrated rather than total. Indi - vidual measures targeting persons and entities linked to the Assad regime and security-based export con - trols were maintained. This dual-track model (broad economic normalisation combined with continued targeted accountability) has become the foundation of the EU’s Syria policy going forward. 2026 Outlook and Beyond Russia: the 20th and 21st packages The 20th package and the Anti - Circumvention Tool The 20th package, adopted on 23 April 2026, is a significant development in the EU sanctions regime against Russia because it is the first-ever invoca - tion of the EU’s Anti-Circumvention Tool. For the first time, the EU imposed restrictions on certain exports of CNC machines and radios to the Kyrgyz Republic, in recognition of that country’s high risk of re-exporting sanctioned goods to Russia. This marks a qualita - tive departure from the previous approach of listing individual entities from third countries. The EU clear - ly signalled that it is prepared to impose systemic, country-level trade restrictions on jurisdictions that it considered to be persistently serving as conduits for sanctioned goods. This is a step with significant implications for every jurisdiction currently viewed as a re-export hub. The energy campaign continued apace: 46 additional shadow fleet vessel listings brought the total to 632,
and mandatory due diligence requirements were introduced for tanker sales, alongside a ban on main - tenance and services for Russian LNG tankers and ice-breakers. Port bans were extended to Murmansk and Tuapse in Russia and to Karimun Oil Terminal in Indonesia. Transaction bans on 20 additional Russian banks and a sectoral ban on Russian crypto-asset service providers completed the financial measures. The proposed 21st package On 9 June 2026, Commission President von der Leyen announced the European Commission’s proposals for a 21st package of EU sanctions against Russia. The proposed measures focus on high-impact sectors including energy, financial services (including crypto- assets) and trade restrictions (including fisheries), with a strong continued emphasis on anti-circumvention. While the package had not been formally adopted at the time of writing, its contents clearly signal the direc - tion of the EU’s Russia sanctions regime. On energy and the shadow fleet, the Commission pro - posed the listing of 30 additional vessels, and for the first time proposed targeting vessels that support the shadow fleet by providing services such as bunkering. Furthermore, the 21st package is expected to include measures directed at critical infrastructure, includ - ing ports, airports and refineries involved in handling Russian oil. In a notable calibration, the Commission also proposed pausing the automatic oil price cap adjustment mechanism until January 2027, reflecting a desire to ensure market stability in light of geopoliti - cal developments including in the Strait of Hormuz, while simultaneously maintaining and strengthening the broader shadow fleet enforcement framework. On financial services, the Commission proposed extending existing transaction bans to 31 additional Russian banks, and targeting 20 entities in third coun - tries, including banks, crypto firms or platforms, and oil traders alleged to have facilitated sanctions cir - cumvention, as well as introducing a potential full ban on crypto-asset services from third countries hosting platforms used to circumvent EU sanctions. On trade, the proposed package expands export restrictions targeting Russia’s military-industrial base, including additional metals and alloys used in aero -
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