EU Sanctions: a "mini" package of restrictive measures adopted in connection with Russia ...

On 15 June 2026, the European Union adopted, pending the XXI sanctions package (which is being discussed by COREPER), a number of new provisions amending several existing sanctions regimes. In particular, the following legislative acts were adopted:

An overview of the main developments introduced is set out below.

In view of the continuation and escalation of the Russian Federation's aggression against Ukraine, the Council deemed it necessary to adopt further restrictive measures, adding 9 natural persons and 45 entities to the list set out in Annex I to Reg. 269/2014.

The new designations cover a diverse range of subjects: executives and owners of companies active in the Russian military-industrial complex, maritime insurance brokers involved in the so-called Russian "shadow fleet" as well as operators and technical managers of vessels used for the transport of crude oil and petroleum products of Russian origin, and Chinese companies supplying components and materials to Russian defence sector entities.

As is well known, the designation of a person or entity under Reg. 269/2014 entails the freezing of all funds and economic resources belonging to, owned, held or controlled by the designated persons or entities, as well as a prohibition on making funds or economic resources available, directly or indirectly, to or for the benefit of such persons or entities (Art. 2, Reg. 269/2014).

Key development: new derogation for transactions with Yangzhou Yangjie Electronic Technology Co., Ltd. (entry 692 of Annex I).

This is the most operationally significant provision of the present package, as it introduces a temporary derogation specifically designed to allow EU operators in the semiconductor sector to manage an orderly transition away from supplies provided by the Chinese company (or its subsidiaries), whose designation through the sanctions package adopted on 23 April 2026 ( link ) had significant adverse impacts on multiple EU production supply chains.

Specifically, a new paragraph 5 terdecies is added to Article 6b of Reg. 269/2014, pursuant to which the competent authorities of a Member State may authorise the release of certain frozen funds or economic resources belonging to the entity referred to under the heading "Entities", entry 692 of Annex I (i.e. Yangzhou Yangjie Electronic Technology Co., Ltd.) or the making available of certain funds or economic resources to that entity, under such conditions as they deem appropriate, after having determined that such funds or economic resources are strictly necessary for one of the following purposes:

Key operational considerations: EU operators that have ongoing contractual relationships with Yangzhou Yangjie Electronic Technology Co., Ltd. may benefit from the derogation only upon prior authorisation granted by the competent authority of the relevant Member State. The authorisation is discretionary and subject to verification that the funds or economic resources are strictly necessary.

Through the adoption of Regulation (EU) 2026/1362, which amends Regulation (EU) 2024/1485, 15 individuals and one new entity have been added to Annex IV, against whom, pursuant to Article 6 of Regulation (EU) 2024/1485, asset freeze measures and a prohibition on making funds and economic resources available now apply.

Of particular note is the designation of IPJSC NTK (alias International Public Joint-Stock Company NTK), the holding company of NtechLab, a Russian technology company specialising in facial recognition that is already subject to EU restrictive measures.

As regards Council Implementing Regulation (EU) 2026/1356 of 15 June 2026, it adds 10 natural persons and one entity to the list set out in Annex I to Regulation (EU) 2024/2642. The designated persons — subject to asset freeze measures — are all linked to propaganda activities and information manipulation in support of Russia's war of aggression: they are primarily journalists, commentators and influencers operating for pro-Kremlin outlets (including RT, Tsargrad TV and Solovyov LIVE), as well as a religious figure spreading disinformation from occupied Crimea. The sole designated entity is the Presidential Fund for Cultural Initiatives (PFKI) , established by presidential decree, which provides grants to projects supporting Russia's war of aggression, including information manipulation campaigns targeting Western audiences.

The Union continues to unreservedly support the Republic of Moldova and its resilience in the face of destabilising activities conducted by external actors. In view of the situation in the country, the Council deemed it appropriate to add six natural persons to the list of persons subject to asset freeze measures under Annex I to Regulation (EU) 2023/888.

The six designated persons fall into two main typological profiles: on the one hand, individuals involved in covert disinformation and electoral manipulation operations financed by Russia (linked to the Ilan Shor network) ahead of the Moldovan parliamentary elections of September 2025; on the other hand, political figures who maintained contacts with senior Russian officials and participated in coordinated initiatives aimed at destabilising the democratic process.

Regulation (EU) 2026/1332 of 12 June 2026 amends Regulation (EU) 2016/44 concerning restrictive measures in view of the situation in Libya. The amendments to the Libyan regime do not entail new personal designations but have a significant impact on the practical management of the frozen reserves of the Libyan Investment Authority, with relevant implications for financial institutions acting as global custodians or sub-custodians of such assets. The amendments implement United Nations Security Council Resolution 2819 (2026), adopted on 14 April 2026, which introduces an amendment to a listing criterion and modifies the scope of the measures imposed on the Libyan Investment Authority .

In particular, the Regulation provides for:

In light of the developments introduced by this package, companies are advised to:

To mitigate non-compliance risks, operators should conduct targeted risk assessments to verify the level of compliance with restrictive measures and the effectiveness of the safeguards adopted to date. Such activities should then feed into an update of the Organisation, Management and Control Models.

For further information or an assessment of the impact of this situation on your business, please Nicolò Cusimano , Lorenzo Di Rubbo or another member of the Bird & Bird Trade & Customs team .

Our professionals specialising in Trade & Customs are available to provide the necessary support in addressing the new measures.