How the EU's 21st sanctions package reaches Georgia, Kyrgyzstan and the UAE

The EU's 21st sanctions package, adopted on 23 July, lists 218 individuals and entities, 48 individuals and 170 entities, and extends the bloc's transaction bans to a Georgian refinery, a Kyrgyz bank and crypto platforms in six jurisdictions, according to the Council's press release. Two further Council actions in October, on 12 October and 15 October, kept the pressure on Russia's supply chains. This explainer sets out where the package reaches companies and banks outside Russia.

Refineries and crypto platforms

The package creates "the possibility to prohibit transactions with listed refineries in Russia and in third countries", the release says. It applies the framework first to a Georgian refinery trading and processing Russian oil in Kulevi, with a ban entering into force in six months. The release gives no calendar date for that ban.

JAMnews reports that a letter from the EU's envoy said Georgian authorities and the port operator had made "positive commitments" when the refinery was left out of the 20th package. It identifies the owner as Black Sea Petroleum and reports no official response from the Georgian government as of 24 July, according to its report. In a statement of 1 July that does not mention Kulevi, Black Sea Petroleum said it processed more than 650,000 tonnes of feedstock in the first half of 2026 and would begin processing crude of entirely non-Russian origin from August to September. JAMnews, citing national statistics, says petroleum products were Georgia's second-largest export category in January 2026, at USD 58.7 million, or 12.2 per cent of total exports.

The Council also extends its transaction ban to 14 crypto-related service platforms "based in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan, and Belarus", per the release. It adds "the possibility of a full third-country ban for crypto-asset services", which the Council describes as a deterrent for jurisdictions that host platforms used to evade sanctions. No platform is named in the release.

Banks and export controls

On banking, the Council introduces a transaction ban against "a Kyrgyz bank connected with the SPFS", Russia's financial messaging system, and against three other non-Russian banks for circumventing sanctions, the release says. It names no country for the other three. Separately, 94 banks and major financial institutions face asset freezes and a prohibition on making funds available, and the package adds four designations tied to the cross-border A7 network.

On export controls, the package adds 51 entities to the list subject to tighter restrictions on dual-use goods and technologies. The release says some are in third countries, including China (including Hong Kong), India, Kazakhstan, Kyrgyzstan, Türkiye and the United Arab Emirates, and does not give a count by country.

What followed in October

On 12 October the Council listed 826 Russian companies and 743 individuals who are chief executives of those companies, 1,569 in total, bringing the Ukraine regime to close to 4,600 listings. The release names no third countries. High Representative Kaja Kallas said in it: "Today the EU adopted the largest round of sanctions listings since 2022."

Three days later, on 15 October, the Council listed three individuals and nine entities for circumventing sanctions, including two companies in Türkiye, two in Dubai, one in Mumbai and one in the Seychelles, according to its release. The European Council, in its conclusions of 15 and 16 October, welcomed the 21st package and called for measures to reduce Russia's energy revenues, close loopholes and curb shadow fleet operations.

• The entry into force of the Kulevi ban, six months after adoption of the package, per the Council.
• Whether the Council uses its new power to ban crypto-asset services from a third country, which the release presents as a possibility.
• Any response from the Georgian government, which JAMnews did not report as of 24 July.