EU Trends and Developments Contributed by: Valerijus Ostrovskis, Coline Cauvin, Yapa Thepkanjana and Delphine Buyle, ACQUIS
space and defence, and drone-related technologies including ground support equipment, jamming sys - tems and launch systems. The package also intro - duces sanctions on fisheries for the first time, covering substantial restrictions on certain fish products and complete bans on others including cod. In a further development, the Commission proposed aligning restrictions applicable to Belarus more closely with those on Russia, to address the risk of Belarus being used as a circumvention channel. Key trends for Russia sanctions looking ahead Anti-circumvention will intensify and expand geo - graphically. The Kyrgyzstan precedent signals to other jurisdictions that they too may face direct EU trade restrictions if they continue to serve as re-export hubs. Energy restrictions will become near-total. The LNG ban takes full effect in January 2027, and while the price cap adjustment mechanism is proposed to be paused temporarily for market stability reasons, the overall direction remains towards a comprehensive severance of Russian energy commercial ties. Digital finance will remain a central enforcement pri - ority. The proposed full ban on crypto-asset services from third-country platforms used for evasion repre - sents a further escalation of the EU’s digital finance enforcement posture. New sectors are being added. The introduction of fish - eries sanctions in the proposed 21st package illus - trates the EU’s willingness to extend the reach of the regime into sectors not previously targeted. Iran: 2026 sanctions developments The year 2026 has seen the EU maintain and develop multiple distinct Iran sanctions regimes simultane - ously, reflecting the breadth and complexity of its Iran policy. Human rights sanctions In March 2026, the Council extended the EU’s human rights sanctions regime targeting Iran until April 2027, and separately designated 16 additional persons and three entities for serious human rights violations.
Freedom of navigation and the Strait of Hormuz The most structurally novel development in EU Iran sanctions policy in 2026 has been the creation of a new legal framework targeting interference with free - dom of navigation in the Strait of Hormuz. In May 2026, the Council extended its legal framework to target those involved in Iran’s actions impeding law - ful transit passage and freedom of navigation in the Middle East, finding such actions contrary to inter - national law and an infringement upon established rights of both transit and innocent passage through international straits. Building on this framework, the Council listed two individuals and one entity in June 2026: Mohammad Akbarzadeh, Deputy Commander for Political Affairs of the IRGC Navy, for threatening to use missiles or drones against vessels transiting the strait; and Hamid Hosseini for promoting the Iranian policy of requiring vessels to pay transit fees for safe passage. This is a genuinely new dimension of EU sanctions policy. By creating a dedicated framework for maritime navigation rights and designating individuals directly administering an illegal toll system, the EU has dem - onstrated a willingness to use sanctions to enforce international law beyond the traditional domains of nuclear non-proliferation and human rights. For opera - tors in the maritime, energy and insurance sectors, this framework warrants close and continuing atten - tion. Looking ahead on Iran Any easing of restrictions remains contingent on cred - ible and verifiable behavioural change by Tehran. Cli - ents should plan on the basis that the full weight of these measures will likely remain in force throughout 2026 and into 2027. Syria: completing the transition Restoration of the EU - Syria Cooperation Agreement On 11 May 2026, the Council terminated the par - tial suspension of the 1977 Cooperation Agreement between the European Economic Community and the Syrian Arab Republic, thereby reinstating its full application. The partial suspension had been intro - duced in September 2011 in response to the Assad regime’s repression of its population. The restoration reinstates key trade-related provisions suspended
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