Military-Industrial Complex 

  • 7 individuals and 21 entities (including third country entities) involved in supplying Russia’s armed forces.


Shadow Fleet 

  • 2 individuals and 24 entities involved in the shipment and export of Russian petroleum products, including its shadow fleet. The listings include entities based in Russia, Liberia, Türkiye, United Arab Emirates, Azerbaijan and Hong Kong.


Russian Hybrid Activities  

  • 10 individuals and one entity involved in Russian propaganda activities.


Russia’s poisoning of Alexei Navalny 

  • One entity and 15 individuals involved in the persecution, poisoning and death of Alexei Navalny.


Russia annexation of Crimea and the city of Sevastopol 

  • The Council extended the sanctions related to the annexation of Crimea and the city of Sevastopol by the Russian Federation until 23 June 2027. The EU does not recognise the annexation of Crimea and Sevastopol. 

 


21st Russian Sanctions Package-Commission Proposal  

Finance 

  • 31 more Russian banks subject to a transaction ban
  • 4 third country banks subject to a transaction ban
  • 11 third-country crypto platforms listed
  • Introduce the possibility of a full third-country ban for crypto-asset services.

 

Energy 

  • 30 more shadow fleet vessels to be listed
  • Restriction on the sale LNG tankers to Russia 
  • Targeting vessels that assist the shadow fleet - providing bunkering and other service
  • Propose targeting critical infrastructure, such as ports, airports, refineries trading or processing Russian oil
  • Freeze the oil price cap at current price ($44.10) - the price is due to increase automatically to roughly $70 based on the global market price unless an agreement is made by 15 July
  • third-country oil traders listed.

 

Trade 

  • More export restrictions for metals and alloys used in the aerospace and defence sectors
  • For drones, new export bans on ground support equipment, and jamming and launch systems
  • Import bans on certain metals, metal ores and car parts (worth €60 million)
  • Ban on import of cod and restrictions on imports of some fish products 
  • Trade restrictions aligned for Belarus.

 

UK Ban on Russian Crude Oil Imports 

The UK has tightened its Russia-related energy sanctions: from 20 May 2026, the UK banned imports of oil products (HS 2710) that were processed in any third country using Russian crude oil (HS 2709). Importers must now prove their supply chains are free from Russian crude unless the goods come from trusted jurisdictions.  

However, these Russian energy sanctions do not apply to Russian origin jet fuel (HS 2710 19 21)  and diesel (HS 2710 19 42 or HS 2710 19 44) refined in third countries, after the UK Government issued a general licence on 19 May 2026 exempting these products from sanctions.  


EU Extends Targeted Measures on Former al‑Assad Networks  

On 18 May 2026, the EU has extended its targeted sanctions on individuals and entities linked to the former al‑Assad regime in Syria until 1 June 2027. At the same time, seven entities, including the Syrian Ministries of Defence and Interior, have been removed from the sanctions list to support renewed EU engagement with Syria.  

Although the EU lifted all broad economic sanctions in May 2025 to encourage Syria’s recovery and political transition, it continues to maintain targeted measures where it believes former regime networks could still undermine reconciliation and accountability efforts.  

Those still listed remain subject to asset freezes, restrictions on EU citizens providing funds, and travel bans within the EU. 

container-ship-sailing-under-motorway-bridge-customs

BDO Global Trade Services

As Global Trade becomes more complex, and more subject to risk, we can advise on your trade implications in a Geo-Political context, assess the Risk Landscape and provide proactive duty planning, ensuring security of supply, and support in accessing new markets. In addition, we can provide Board Level briefings in order to support and advise in this new environment. If you think any of these updates could affect your business, don’t hesitate to contact us for further information or to arrange a consultation.

Contact usOpens in a new window/tab

This publication has been carefully prepared, but it has been written in general terms and should be seen as broad guidance only. The publication cannot be relied upon to cover specific situations and you should not act, or refrain from acting, upon the information contained therein without obtaining specific professional advice. Please contact BDO to discuss these matters in the context of your particular circumstances. BDO, its partners, employees and agents do not accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it. BDO is authorised by the Institute of Chartered Accountants in Ireland to carry on investment business. BDO, a partnership established under Irish Law, is a member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. BDO is the brand name for the BDO International network and for each of the BDO Member Firms. 

Copyright © 2026 BDO Ireland. All rights reserved. Published in Ireland.