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EU’s 20th Russia Sanctions Package: Key Changes and Compliance Implications

By Erik de Bie, Dr. Lucas Wüsthof & Claudia Amthor on May 13, 2026
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Abstract_04

On 23 April 2026, the EU Council adopted its 20th package of restrictive measures against Russia, amending the core EU sanctions regulations that have been in place since 2014. The package expands existing restrictions across energy, finance, trade, and media, and introduces several new legal instruments, including the first use of the EU’s anti-circumvention mechanism against a third country and strengthened legal protections for EU operators. Companies with exposure to Russia, Belarus, or related supply chains should review the changes as summarized in this GT Alert.

Link to Continue reading the full GT Alert. Continue reading the full GT Alert.

Photo of Erik de Bie Erik de Bie

Erik de Bie is an attorney-at-law focused on international trade, customs and VAT matters. Erik counsels clients in European trade, export control, sanctions, customs and VAT related matters. He also represents clients in litigation.

He concentrates his practice on compliance with EU trade…

Erik de Bie is an attorney-at-law focused on international trade, customs and VAT matters. Erik counsels clients in European trade, export control, sanctions, customs and VAT related matters. He also represents clients in litigation.

He concentrates his practice on compliance with EU trade, sanctions and compliance rules. He assists companies to lawfully export goods, technology, and services around the globe, prioritizing practical, workable strategies for complex regulatory situations, including compliance with the growing number of sanctions. Conducting and managing internal reviews and risk mitigation are an important focus area.

Erik advises clients in customs, VAT and related matters, including support with setting up and restructuring distribution. and supply chains. Erik is regularly representing companies in (cross-border) consultations with the authorities, including disclosure matters.

Erik is experienced in representing companies before Dutch Tax and Customs Courts, the Dutch Supreme Court, the European Commission, and the European Court of Justice.

Erik is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that draws on the firm’s global platform to guide our clients through what comes next in regards to tariffs, including tariff refund matters, tax, litigation, and M&A activity spurred by these global shifts.

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Photo of Dr. Lucas Wüsthof Dr. Lucas Wüsthof

Lucas focuses his practice on competition/antitrust, foreign trade, and regulatory law. His competition law practice covers merger control, strategic cooperation agreements, joint ventures, distribution and commercial arrangements, competition law compliance, and proceedings before competition authorities. He is particularly experienced in advising clients where…

Lucas focuses his practice on competition/antitrust, foreign trade, and regulatory law. His competition law practice covers merger control, strategic cooperation agreements, joint ventures, distribution and commercial arrangements, competition law compliance, and proceedings before competition authorities. He is particularly experienced in advising clients where competition law, regulation, technology, and cross-border trade intersect.

A further focus of his practice is on EU and German foreign trade regulation, including export controls, sanctions, FDI screening, and related compliance matters. Lucas advises companies on complex cross-border requirements relating to transactions, foreign investments, the export of goods, technology, and services, and international supply chains. His experience includes transaction-related due diligence, FDI filings, regulatory filings, export classifications, license applications, sanctions guidance, internal reviews, and risk mitigation.

Building on his regulatory experience, Lucas also advises on business models in dynamic, highly regulated sectors, particularly telecommunications, digital infrastructure, and communications networks. His work also covers infrastructure and services in aerospace, defense, and security-sensitive technologies, including satellite-based communications, space-enabled connectivity, and related digital infrastructure. He advises on strategic alignment, contractual structuring, commercial design, and regulatory issues where technology, infrastructure, national security, and cross-border trade intersect.

Lucas is recognized by Best Lawyers / Handelsblatt for competition law and is listed in The Legal 500 EMEA 2025 as a “core lawyer” for telecommunications.

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Photo of Claudia Amthor Claudia Amthor

Claudia advises clients on German and European competition and regulatory law, with a particular focus on technology-driven and regulated industries as part of the firm’s TMT (Technology, Media & Telecommunications) practice. She supports companies on merger control and antitrust matters in the context…

Claudia advises clients on German and European competition and regulatory law, with a particular focus on technology-driven and regulated industries as part of the firm’s TMT (Technology, Media & Telecommunications) practice. She supports companies on merger control and antitrust matters in the context of cross-border transactions. She also contributes to the strategic and regulatory design of digital, media, and telecommunications business models and assists in developing commercial contract structures for digital platforms, telecommunications services, and other technology-enabled offerings.

Her practice further extends to foreign trade law. She advises on foreign direct investment (FDI) screening, export control regulations, and sanctions regimes, helping clients manage regulatory risks in complex transactions and structure compliant business and supply chain frameworks across different sectors.

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  • Posted in:
    Administrative and Regulatory
  • Blog:
    GT Amsterdam Law Blog
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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