BELGIUM Law and Practice Contributed by: Valerijus Ostrovskis, Coline Cauvin, Delphine Buyle and Yapa Thepkanjana, ACQUIS
ACQUIS Rue du Trône 98 1050 Brussels Belgium
Tel: +32 0 2 887 94 10 Email: info@acquislp.eu Web: www.acquislp.eu
1. Trends and Overview 1.1 Sanctions Market Key Developments
ers and ice-breakers, and provides that LNG-terminal services to Russian entities will be prohibited from January 2027. The 20th package also includes increased restrictions on technology and dual-use goods exports to hin - der military and technological advancements, includ - ing the first activation of the Anti-Circumvention Tool targeting re-export risks via third countries such as the Kyrgyz Republic. The package further introduces expanded financial restrictions, including a sectoral ban on Russian crypto-asset platforms and a new transaction ban on 20 additional Russian financial institutions. The EU’s 21st package of sanctions against Russia, adopted on 23 July 2026, focuses largely on finan - cial services, crypto-assets and the oil sector. On the financial side, transaction bans were extended to cov - er 33 further Russian credit and financial institutions, four non-Russian banks and 14 crypto-related service platforms. Over 90 additional banks were subjected to asset freezes, forming part of a broader set of 218 new individual designations. The package also adds 41 vessels to the list of ships associated with Russia’s shadow fleet, tightens meas - ures targeting the oil sector, and widens existing trade restrictions on goods and technologies feeding Rus -
The market in Belgium has been affected by EU sanc - tions developments in relation to the ongoing war in Ukraine. At the time of writing, the EU has adopted four additional sanctions packages targeting Russia alone since June 2025. The 20th sanctions package targeting Russia was published in April 2026, and more recently the EU adopted the 21st package of sanctions against Russia in July 2026. There are also EU sanctions developments in rela - tion to the conflict in the Middle East. Among others, the EU has extended the scope of measures target - ing individuals and entities involved in Iran’s actions threatening freedom of navigation in the Middle East. The EU’s 20th package of sanctions against Russia includes further asset-freeze listings of individuals and entities linked to Russia’s military-industrial complex, the shadow-fleet ecosystem and sanctions circum - vention. The new listings also target third-country entities, including in China, the United Arab Emir - ates (UAE), Kazakhstan and Uzbekistan, that have supported Russia’s war effort or supplied restricted goods. The package further strengthens energy-related measures. It establishes the legal basis for a future ban on maritime services connected with Russian crude oil and petroleum products, expands shadow- fleet restrictions, prohibits maintenance and related services for Russian liquefied natural gas (LNG) tank -
sia’s military-industrial complex. Impact on European Companies
European companies are facing higher compliance costs, operational challenges, disrupted supply
49 CHAMBERS.COM
Powered by FlippingBook