Welcome to This Month in EU Sanctions — briefings and podcast episodes at the crossroads of EU law, foreign policy, and corporate compliance. Stay ahead in a fast-evolving EU sanctions and export control landscape by subscribing to the newsletter and podcast. For June 2026, here are the main updates.
New EU Sanctions
“Mini” Russia Sanctions Package and Renewal
On 15 June 2026, delivering on prior announcements to move to a rolling sanctions approach operating in parallel to broader packages, the Council of the European Union (the “Council”) adopted a new round of sanctions against Russia spanning three legal regimes, namely, the main asset-freeze regime, the Russia destabilising-activities regime, the Russia human rights regime (Decision 2014/145/CFSP; Decision (CFSP) 2024/2643; Decision (CFSP) 2024/1484).
The Council listed 34 individuals and 47 entities overall, including 7 individuals and 21 entities supporting Russia’s military-industrial complex (including third-country suppliers in China) and 2 individuals and 24 entities involved in shadow fleet shipping of Russian crude oil and petroleum products, including Lukoil-Western Siberia and companies in Russia, Liberia, Turkey, the UAE, Azerbaijan and Hong Kong. As part of the same action, the Council extended the Crimea and Sevastopol sanctions regime for a further year, until 23 June 2027.
Separately, a nine-month derogation was introduced for dealings with Yangzhou Yangjie Electronic Technology Co., the Chinese semiconductor manufacturer listed under the 20th package. The derogation allows EU operators, principally European automakers reliant on Yangjie as a supplier, to transition to alternative sources; the company remains formally listed and full restrictions are expected to take effect 31 December 2026 for existing contracts and 15 March 2027 for critical component purchases.
In light of the joint statement of 16 February 2026 by the UK, Sweden, France, Germany and the Netherlands on the poisoning of Alexei Navalny, the Council listed one entity and 15 individuals — including Russian judges, prosecutors, law enforcement, FSB and medical personnel — for their role in his persecution, poisoning and death.
On 25 June 2026, the Council renewed its sanctions regime against Russia for 12 months, until 31 July 2027, departing from the customary six-month renewal cycle (Decision 2014/512/CFSP). The decision follows the European Council’s conclusions of 18–19 June 2026, in which EU leaders agreed to the longer renewal period.
Iran - Strait of Hormuz
On 8 June 2026, the Council made its first individual designations under the framework extended on 22 May 2026 to target those threatening freedom of navigation in the Strait of Hormuz, listing two individuals and one entity.
The Council listed the Hormozgan Provincial Command of the Islamic Revolutionary Guard Corps Navy (IRGCN), which it states implemented a toll system requiring vessels transiting the Strait to provide documentation and pay fees for safe passage. Also listed are Mohammad Akbarzadeh, IRGCN Deputy Commander for Political Affairs, accused of publicly threatening missile and drone strikes against transiting vessels, and Hamid Hosseini, an Iranian oil and gas industry representative who promoted compliance with Iran’s transit toll procedures.
Moldova
As part of the 15 June package, the Council listed six individuals under the Moldova destabilisation regime, established in April 2023 in response to actions threatening Moldova’s sovereignty, democracy and stability (Decision (CFSP) 2023/891 and Regulation (EU) 2023/888). The regime now applies to 29 individuals and five entities.
Libya
On 12 June 2026, the Council amended its restrictive measures in view of the situation in Libya to implement UN Security Council Resolution 2819 (2026) of 14 April 2026 (Council Regulation (EU) 2026/1332, amending Regulation (EU) 2016/44). The amendments introduce no new designations but make significant changes to the management of the frozen reserves of the Libyan Investment Authority (LIA), of direct relevance to financial institutions acting as global custodians or sub-custodians of those assets.
The amended Regulation authorises, subject to UN Sanctions Committee approval, the use of LIA’s frozen cash reserves for investment in low-risk time deposits or fixed-income instruments depending on the applicable UNSCR recommendation, and introduces a new Article 11b permitting the transfer of LIA’s global custodian role between institutions within the same jurisdiction, provided the assets remain frozen and their value is preserved throughout the transfer.
Sudan
On 22 June 2026, following the UN Sanctions Committee’s designation on 28 April 2026 of a fourth individual under UNSC Resolution 1591 (2005), the Council added that individual to the UN-implementing Sudan regime and, correspondingly, removed the parallel entry for that same individual from the EU’s autonomous Sudan regime, to avoid duplicate listing across the two instruments (Council Implementing Regulation (EU) 2026/1393, implementing Article 15(1) of Regulation (EU) No 747/2014; and Council Implementing Regulation (EU) 2026/1394, implementing Regulation (EU) 2023/2147).
Haiti
On 26 June 2026, the Council renewed the EU’s autonomous framework for restrictive measures against those threatening the peace, stability and security of Haiti, or undermining democracy and the rule of law in the country, for one year, until 29 July 2027. The Council reiterated the EU’s status as a long-standing political and development partner of Haiti and its continued engagement alongside regional partners in addressing the country’s humanitarian crisis.
Policy Developments
Commission Proposes 21st Sanctions Package Against Russia
On 9 June 2026, Commission President von der Leyen presented the Commission’s proposals for a 21st package of sanctions against Russia, focused on energy, financial services and crypto, and trade, including fisheries for the first time.
The proposed measures include suspension of the oil price cap adjustment mechanism until January 2027 (citing market disruption from the Strait of Hormuz crisis); listing of 170 individuals and entities, including asset freezes on approximately 90 banks; designation of 30 additional shadow fleet vessels and, for the first time, vessels supporting the shadow fleet through bunkering services; new transaction bans on ports, airports and refineries handling Russian oil; a potential full ban on crypto-asset services from third countries; expanded export controls on aerospace, defence and drone-related technologies; new import bans on goods worth approximately €60 million; and a ban on EU entry for individuals who have served in the Russian armed forces since the war began.
European Council Conclusions, 18–19 June 2026
The European Council reaffirmed its continued support for Ukraine’s independence, sovereignty and territorial integrity, and its support for a comprehensive, just and lasting peace. On sanctions specifically, it agreed to extend the Russia economic sanctions regime for twelve months rather than the customary six, reiterated the importance of further reducing Russia’s energy revenues, curbing its shadow fleet, and constraining its banking system, and called for the swift adoption of the 21st sanctions package.
G7 Leaders’ Statement on Geopolitical Issues, 17 June 2026
At the G7 Summit in Évian-les-Bains, leaders issued a statement on geopolitical issues reaffirming unwavering support for Ukraine and committing to increase deliveries of air defence capabilities and long-range systems, with leaders ready to consider extending licences to boost Ukraine’s own military production capacity. Leaders separately committed to increasing pressure on the Russian war economy, including by strengthening sanctions on the oil and gas sectors, and welcomed the US-brokered deal reopening the Strait of Hormuz and the prospect of a follow-on diplomatic agreement covering the wider region, including Lebanon and Gaza.
Compliance Guidance
On 15 June 2026, the Commission published a new FAQ on the import ban on refined petroleum products obtained from Russian crude oil, addressing the prohibition on the purchase, import or transfer of such products, including where imported via third countries (Article 3ma). The latest version of the consolidated FAQ is dated 15 June 2026.
EU Courts Developments
June 2026 was an exceptional month for EU sanctions litigation, with three CJEU judgments four General Court judgments delivered the previous day, and an Advocate General Opinion.
CJEU Confirms Broad Interpretation of “Support” to the Russian Government — Case C-801/24 P, NSD v Council
On 11 June 2026, in Case C-801/24 P, NSD v Council, the Court of Justice (Fourth Chamber) dismissed the appeal brought by NKO AO National Settlement Depository (NSD), Russia’s central securities depository, against its listing under Article 2(1)(f) of Decision 2014/145/CFSP, which targets persons “supporting, materially or financially, ... the Government of the Russian Federation.” NSD argued the criterion should be read narrowly, covering only direct financing.
The Court held that “support” must be interpreted broadly, covering any support capable, by its quantitative or qualitative importance, of providing the Russian Government with material or financial resources or facilities allowing it to pursue its actions to destabilise Ukraine — without any need to show a direct link between that support and those actions. A narrower reading would create an artificial distinction between entities that finance the government and those that merely facilitate that financing.
CJEU Rules a Third-Country Sanctions Listing Alone Cannot Justify Refusal of a Basic Payment Account — Case C-81/24, Jenec
On 11 June 2026, in Case C-81/24, Jenec, the Court of Justice (Fourth Chamber) ruled on a Slovenian reference concerning a bank’s refusal to open a basic payment account for a consumer listed by the US Office of Foreign Assets Control (OFAC), despite his never having been convicted of any offence or sanctioned by the EU, UN or Slovenia. The Court held that Directive 2014/92/EU, read with the AML Directive (EU) 2015/849, does not permit Member States to require banks to refuse a basic account for the sole reason that the applicant appears on a third-country sanctions list.
Inclusion on such a list may be a relevant risk factor within the AML Directive’s risk-based approach but cannot trigger automatic refusal; the bank must conduct an individual risk assessment and, if warranted, apply enhanced due diligence rather than blanket refusal.
CJEU Confirms Limited Review and Rebuttable Presumption Under the Syria “Family Membership” Criterion — Case C-760/24 P, Sharif v Council
On 11 June 2026, in Case C-760/24 P, Sharif v Council, the Court of Justice (Sixth Chamber) dismissed the appeal of Ammar Sharif, brother-in-law of Rami Makhlouf, against his Syria-regime listing under the “family membership” criterion, which presumes association with the Syrian regime for members of the Assad or Makhlouf families. Mr Sharif argued the presumption was, in practice, irrebuttable.
The Court confirmed the presumption is rebuttable, through evidence calling into question the Council’s evidence or demonstrating the absence of a genuine risk of circumvention — without requiring proof that the family tie itself no longer exists — and confirmed that judicial review of such general listing criteria remains limited, given the Council’s broad discretion in defining them.
General Court Upholds Ignatova’s Successive Relistings, Clarifies “Immediate Family Member” Criterion — Case T-601/24, Ignatova v Council
On 10 June 2026, in Case T-601/24, Ignatova v Council, the General Court (Tenth Chamber) dismissed in full the action of Anastasia Ignatova, stepdaughter of Rostec CEO Sergei Chemezov, against three successive listings under the “immediate family member” criterion. The case turned principally on the 85-metre yacht Valerie. The Court found sufficient evidence linking the vessel to Mr Chemezov and held that it is enough if the benefit, or its proceeds, persisted at the time of listing, regardless of whether a later sale of the holding company was genuine.
On the central legal question, the Court held that “immediate family member” covers any person whose family ties are close enough that they could be used to disperse assets to evade sanctions, irrespective of whether the tie is by blood, adoption or marriage — rejecting reliance on unrelated EU instruments (the Citizens’ Rights Directive, Dublin Regulation, ECHR family-life case law) to import a narrower test.
General Court Upholds Elena Timchenko’s Listing, Clarifies the “Associated Person” Criterion — Case T-602/24, Elena Timchenko v Council
On 10 June 2026, in Case T-602/24, Elena Timchenko v Council, the General Court (Eighth Chamber) dismissed the action of Elena Timchenko, wife of Gennady Timchenko, listed as a person “associated” with her husband. The Court reaffirmed that “association” requires a link going beyond marriage itself, but does not require proof that any benefit derived was undue.
The Court found that Mrs Timchenko’s continued status as co-founder of the Timchenko Foundation — even after resigning from its board, and despite a charter amendment removing certain founder powers — still conferred residual rights and a continued public role going beyond ordinary marital activity, reinforced by evidence that Volga Group had previously supported the Foundation’s COVID-19 relief work.
General Court Dismisses Gennady Timchenko’s Challenge and Damages Claim — Case T-603/24, Timchenko v Council
On 10 June 2026, in Case T-603/24, Timchenko v Council, the same panel dismissed Gennady Timchenko’s challenge to his September 2024 and March 2025 relistings, together with a €1,000,000 damages claim. The Court confirmed, consistent with the Court of Justice’s prior ruling in his case (C-702/23 P), that his indirect 10.323% shareholding in Bank Rossiya — making him the bank’s second-largest shareholder — establishes financial support to Russian decision-makers.
The Court also found he benefits from those decision-makers, citing a 2017 law granting him personal tax exemptions and substantial Russian government support received by companies in which he holds large stakes. The damages claim failed for want of any established unlawfulness.
General Court Upholds Iran Air’s Listing Over UAV Transfers to Russia — Case T-676/24, Iran Air v Council
On 10 June 2026, in Case T-676/24, Iran Air v Council, the General Court (Eighth Chamber) dismissed Iran Air’s challenge to its listing for allegedly transferring Iranian-made drones to Russia. The Council’s evidence — 22 items spanning press reporting, think-tank analysis and an open-source flight-tracking investigation — was found reliable due to its geographic diversity and internal corroboration, with several sources independently identifying the same Iran Air Cargo flights between Tehran and Moscow via Armenian airspace in 2022.
The Court held this constituted a sufficiently specific, precise and consistent body of evidence, rejected arguments that the Council was required to detail individual flight cargo manifests, and confirmed that pre-listing notice is not required for asset-freeze measures given their need for a surprise effect.
Advocate General Proposes Tightened Standard for “Violent Demonstrations” Criterion in Moldova Regime — Opinion in Case C-179/25 P, Tauber v Council
On 4 June 2026, in Case C-179/25 P, Tauber v Council, Advocate General Spielmann proposed that the Court of Justice set aside the General Court’s judgment upholding the listing of Marina Tauber, former deputy leader of Moldova’s ȘOR party, under the Moldova regime’s “violent demonstrations” criterion. He found the General Court had erred by treating evidence of “violent intentions” as sufficient on its own, holding the criterion instead requires proof of an objective, material element — that demonstrations planned or directed were themselves violent.
EU Export Controls Developments
Commission Publishes Second Annual Dual-Use Export Control Report
On 25 June 2026, the Commission’s Directorate-General for Trade and Economic Security published its second annual report evaluating dual-use export patterns from EU member states, covering 2024 data.
EU member states authorised dual-use exports amounting to €77.6 billion in 2024 — 3% of total extra-EU goods exports, up from €71 billion in 2023 — with 487 transactions denied on security grounds. The top five destinations by value were China (25%), the United States (21%), the United Kingdom (7%), South Korea (7%) and Ukraine (3%).
The report highlighted a 41% rise in reported infringements (from 192 in 2023 to 270 in 2024) and a corresponding rise in penalties imposed (122 to 144), alongside data of direct relevance to the Human Rights Watch report covered in the May edition: 320 applications were received for cyber-surveillance item exports, with the denial rate falling year-on-year (20 denials in 2023 to 13 in 2024) even as application volumes held broadly steady. The Commission confirmed its mandatory Article 26(4) evaluation of the Dual-Use Regulation is under way, with a public consultation due in the first half of July 2026.
Other Economic Security Developments
Council Adopts Revised Foreign Investment Screening Regulation
On 8 June 2026, the Council formally adopted a revised Regulation on the screening of foreign direct investments, replacing the framework in force since October 2020. The regulation mandates screening mechanisms with a common minimum scope across all member states, extends coverage to investments made through EU subsidiaries, and introduces new tools to facilitate information exchange and prevent circumvention.
Of particular relevance to sanctions practitioners, the underlying cooperation mechanism requires host member states to share an FDI filing with other member states and the Commission within 15 calendar days where the foreign investor, or any related party, is subject to EU sanctions — creating a direct operational link between the sanctions and FDI screening regimes. The regulation enters into force 20 days after publication, with the new rules applying 18 months thereafter.
The Podcast
Catch up with the latest three episodes of the podcast (available on all platforms).