NewsCryptoEU’s 21st Russia Sanctions Package Adds Mechanism to Block Crypto Services of Third Countries

EU’s 21st Russia Sanctions Package Adds Mechanism to Block Crypto Services of Third Countries

Author: Crypto Valley Journal·

Key Takeaways

  • The 21st sanctions package adds 170 entities and 48 individuals, bringing the EU’s Russia sanctions list to nearly 3,000 entries.
  • The EU can now impose transaction bans on crypto services from entire third countries linked to sanctions evasion by Russian actors.
  • More than 100 Russian banks are now under EU sanctions, covering over half of Russia’s internationally connected lenders.
  • The package directly bans transactions with 14 listed crypto platforms based in Georgia, Panama, the United Arab Emirates, the Marshall Islands, Kyrgyzstan, and Belarus.
  • The EU froze the Russian oil price cap at $44.10 per barrel for 12 months while maintaining broader energy and shipping restrictions.
EU’s 21st Russia Sanctions Package Adds Mechanism to Block Crypto Services of Third Countries

The Council of the European Union has adopted its 21st sanctions package against Russia, marking the largest expansion of the EU sanctions list in four years. For the first time, the package includes a mechanism that can block crypto services provided from entire third countries.

An EU sanctions package is a set of legally binding measures adopted by the Council of the EU. Such measures can include asset freezes, transaction bans, and the listing of individuals and entities. They apply to EU persons and companies, as well as activity within EU jurisdiction, making them directly relevant for banks, payment firms, exchanges, custodians, and other service providers that must screen counterparties and transactions. Brussels has adopted successive sanctions rounds against Russia since the war began in 2022, and crypto-related restrictions have become a growing focus across the past three packages.

In October 2025, the 19th package banned a token by name for the first time. The 20th package later expanded the restrictions to all Russian and Belarusian crypto service providers. European Commission President Ursula von der Leyen presented the latest proposal on 9 July. After objections from Greece, France, Italy, Germany, Austria, Portugal, and Bulgaria, the Council ultimately adopted the package.

The 21st package contains 218 new listings, including 170 entities and 48 individuals. More than 100 Russian banks are now under sanctions, representing more than half of the country’s 213 internationally connected lenders. The full EU sanctions list against Russia now contains nearly 3,000 entries.

New mechanism can block crypto services of entire third countries

The central crypto element of the package is a tool the EU previously did not have. Until now, Brussels could sanction individual tokens or specific platforms. Under the new mechanism, the Council can impose a full transaction ban on crypto services from an entire third country when that country hosts crypto providers that help Russian actors evade sanctions.

The change shifts the sanctions approach from targeting only individual actors to potentially targeting entire jurisdictions. As an initial measure, the package imposes direct transaction bans on 14 listed crypto platforms based in Georgia, Panama, the United Arab Emirates, the Marshall Islands, Kyrgyzstan, and Belarus.

The Council also prohibits Russian nationals from owning, controlling, or holding board seats in companies that offer crypto-asset services covered by the restrictions. The measures therefore address both the platforms themselves and the people behind them.

Banks outside Russia are also covered by the package’s focus on sanctions evasion. The Council placed a transaction ban on a Kyrgyz bank connected to Russia’s SPFS payment system. The same measure applies to three additional credit institutions outside Russia for sanctions evasion.

For compliance teams, the package introduces a broader systemic risk consideration. Direct business relationships are no longer the only relevant factor; the home jurisdiction of a crypto partner is increasingly material under the EU’s sanctions framework. That matters because crypto services can operate across borders even when their legal entity, management, banking access, or infrastructure sits outside the EU.

More than 100 Russian banks are now covered by EU sanctions

Banking restrictions remain a core part of the financial measures. The Council imposed asset freezes and a provision ban on 94 Russian banks and major financial institutions. In total, more than 100 institutions in Russia’s banking sector are now sanctioned, accounting for more than half of its internationally connected lenders.

A separate transaction ban targets 33 additional credit and financial institutions and cuts them off from the SWIFT payment system. The latest measures mainly affect smaller and regional banks. Russia’s largest institutions had already lost SWIFT access in 2022, and Brussels is now targeting the second tier of the banking system, through which part of the disrupted payment flows had recently moved.

EU foreign policy chief Kaja Kallas described the scope of the package in a statement.

"Our 21st package includes the highest number of listings in four years. We are hitting more than a hundred banks and crypto operators, over 40 shadow fleet vessels, and several oil refineries in Russia and Belarus." - Kaja Kallas, High Representative of the EU for Foreign Affairs and Security Policy

From A7A5 to Grinex: the sanctions evasion pattern

The new third-country mechanism responds to a pattern that appeared across recent sanctions packages. In October 2025, the 19th package banned a crypto token by name for the first time: the ruble-backed stablecoin A7A5. The same sanctions round also prohibited transactions through the Russian payment systems Mir and SBP.

A7A5 is issued by the Kyrgyz company Old Vector LLC, a subsidiary of A7 LLC. Its majority owner is the Moldovan oligarch Ilan Shor, who was convicted in absentia by a court of bank fraud running into the billions. The stablecoin is backed by ruble deposits at the sanctioned Russian state bank Promsvyazbank. It operates on Ethereum and Tron and has no freeze function.

The token served as a financial bridge between two exchanges. Law enforcement seized one of them, Garantex, in spring 2025. The successor platform Grinex later assumed its function. According to analytics firm CertiK, A7A5 processed more than 110 billion USD in on-chain transactions over 16 months. Elliptic and TRM Labs classified around 34% of that volume as wash trading.

The 20th sanctions package had already addressed this type of evasion by extending the transaction ban to all crypto service providers based in Russia and Belarus. It also covered the digital ruble, RUBx, and the Belarusian digital ruble. However, when the EU sanctions a platform or token, activity can shift elsewhere, with successor services operating in more loosely regulated third countries. The new blocking mechanism is intended to pre-empt that pattern by giving the Council a jurisdiction-level option rather than requiring it to list each successor service one by one.

Oil price cap frozen at 44.10 USD for twelve months

Alongside the financial and crypto measures, the package further tightens restrictions affecting Russia’s energy revenue. The Council is freezing the oil price cap at 44.10 USD per barrel for twelve months. Brussels says the pause is intended to prevent Russia’s war chest from benefiting from market shocks.

Without the suspension, the regular review process would have required the cap to rise to around 58.50 USD because of the Iran-driven price jump. Russian Urals crude has been trading above the cap since February 2026. Most recently, it stood at around 67.50 USD per barrel, excluding freight and insurance costs.

Individual EU member states also negotiated exemptions. Greece received a one-year, automatically renewable exemption for transporting Russian liquefied natural gas (LNG) from the Arctic to third countries. As a result, the ban on those transfer services, originally planned for 1 January, does not apply for now. EU imports of Russian LNG remain prohibited from that date.

The package also covers more than 40 vessels in Russia’s shadow fleet and targets several oil refineries in Russia and Belarus. More than 50 military-industrial entities involved in producing long-range drones are included as well. In addition, EU courts may no longer recognize or enforce Russian court rulings arising from sanctions proceedings.