The package continues the EU’s focus on third-country entities facilitating sanctions circumvention, with particular attention to Kyrgyzstan and, this time, to financial channels. It includes the first transaction ban on a Kyrgyz bank, alongside measures against three other non-Russian banks and 14 crypto-asset service providers operating from third countries. The package also adds further shadow-fleet vessels and military-industrial entities, including companies based in China, including Hong Kong, India, Kazakhstan, Kyrgyzstan, Türkiye, and the UAE.
It also expands measures against the oil sector, including Russian, Belarusian, and third-country refineries. Finally, the package introduces additional export restrictions on military-relevant goods and technologies, as well as new import restrictions on products generating revenue for Russia.
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