EU sanctions reach crypto platforms in six jurisdictions
The Council of the EU adopted its 21st package of sanctions against Russia on 23 July 2026. It contains 218 listings, 48 individuals and 170 entities, the most in any package for four years. The crypto measures covered in this note were introduced through Council Regulation (EU) 2026/1848 and Decision (CFSP) 2026/1849, with parallel measures for Belarus, and entered into force on 24 July 2026.
Most of the attention has gone to the energy and banking measures. This note covers the crypto provisions, which matter for anyone with counterparties in the listed jurisdictions or with an EU crypto business.
The EU has banned transactions with 14 crypto service platforms located outside the Union, in Georgia, Panama, the UAE, the Marshall Islands, Kyrgyzstan and Belarus. According to the Council, these platforms were being used to help Russia move money around existing sanctions.
The list includes HTX, one of the largest exchanges in the world, which is operated by Huobi Global S.A., a Panamanian company. The others are Rapira, EXMO, BitPapa, Exnode, Aifory Pro, ABCeX, WhiteBird, NoOnecrypto, Tradex, Monease and PilotFinance, plus entities linked to the A7 payments network.
This is a transaction ban, not an asset freeze. The UK sanctioned several of the same platforms in May 2026 and went further, freezing assets and restricting correspondent banking. Under the EU measure, EU persons and companies simply cannot deal with the listed platforms, directly or indirectly. That covers payments, brokerage, custody arrangements and technical connections such as APIs. An exception allows EU nationals to withdraw their own funds from the newly listed platforms and banks, so that the sanctioned operators have no excuse to hold on to them.
The ban on the crypto platforms applies from 23 August 2026, and the related bans on Russian and third-country banks from 13 August 2026. The exact dates are set annex by annex, so compliance calendars should be built from the Official Journal text.
The more significant change is a new Article 5bc of Regulation 833/2014, together with a new Annex LVII. Under this provision, the EU can prohibit all transactions with crypto service providers established in a listed third country. The ban would apply to the country’s crypto sector as a whole, not to individual platforms. There is an exception for transactions by EU nationals who were resident in the listed country before its listing.
No country has been listed yet. Annex LVII is empty, and the Commission has described the measure as a deterrent: countries that host platforms helping Russia evade sanctions are expected to act against them, or risk having their whole crypto sector cut off from the EU.
The package also widens an existing restriction on EU crypto businesses. Russian and Belarusian nationals and residents are already barred from owning, controlling or holding management positions in EU providers of crypto wallet, account and custody services. From 25 August 2026, this extends to every type of crypto service provider authorised under MiCA, including exchanges, trading platforms and portfolio managers.
The timing is awkward for the industry. MiCA’s transitional period ended on 1 July 2026, so many firms have only recently been authorised and now need to check their shareholders and boards against a broader restriction. Firms with any Russian or Belarusian connection in their ownership or management should review their position before the deadline.
Finally, the package strengthens the position of EU companies in disputes connected to sanctions. EU courts and Member States may refuse to recognise or enforce judgments from Russian courts, and the scope of the right of EU operators to claim compensation for damage is clarified. This helps any EU party whose counterparty tries to litigate a sanctions-affected contract in Russia.
Disclaimer
This note is general commentary, not legal advice. Sanctions listings change frequently.
GFDL Advogados advises on crypto-assets from Lisbon. Contact us to discuss how these measures affect a particular structure.
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