# ANALYSIS: The EU finally draws its anti-circumvention weapon on Putin

> On April 23, 2026, the European Commission confirmed the adoption of its 20th sanctions package against Russia. Within that package, one measure stands out for being unprecedented: the activation, for the first time, of…

- Author: Maxime Marquette
- Publisher: MadMax (https://mad-max.co)
- Section: Analysis
- Published: 2026-07-20
- Canonical URL: https://mad-max.co/en/article/analysis-the-eu-finally-draws-its-anti-circumvention-weapon-on-putin

## Introduction: The tool Brussels kept in a drawer for years

### A historic first in the sanctions arsenal

On **April 23, 2026**, the **European Commission** confirmed the adoption of its **20th sanctions package** against Russia. Within that package, one measure stands out for being unprecedented: the activation, for the **first time**, of the European Union's **anti-circumvention tool**. This legal mechanism, created years ago but never truly deployed until now, allows Brussels to target third countries and entities that help Russia dodge Western sanctions, according to official **European Commission** documents.

This is not a **technical detail** among others. It is a **shift in posture**. For years, the European Union built an increasingly sophisticated sanctions arsenal — lists of individuals, frozen assets, trade restrictions, an oil price cap — without ever using the most aggressive tool in its legal toolbox: the one that lets it directly sanction those who help Russia dodge those very sanctions. This 20th package changes that.

### Why this tool sat unused for so long

It's worth understanding why **Brussels** long hesitated to draw this instrument. The **anti-circumvention tool** allows targeting **third countries** — not just Russian companies or individuals — which immediately raises delicate diplomatic questions. Sanctioning a third country for facilitating Russian trade amounts to publicly accusing a trading partner, sometimes an ally on other matters, which explains Europe's caution in previous years.

But after more than **four years of war**, and facing increasingly sophisticated circumvention networks — shell companies, trade routes redrawn through Central Asia or the Gulf, technology exports rerouted via third countries — the European Union has evidently decided that diplomatic caution can no longer take priority over sanctions effectiveness. **It is an implicit admission that previous measures, on their own, were no longer enough.**

*It took twenty sanctions packages and four years of war for Brussels to finally pull the weapon it had kept in its arsenal from the start. One could see this as bureaucratic slowness. I prefer to see it as proof that the European Union, for all its legendary heaviness, keeps learning and adapting against an opponent who has never lacked inventiveness in dodging its own international commitments.*

## What the anti-circumvention tool actually targets

### From financial services to cryptocurrencies: the net tightens

The **20th package** doesn't stop at the symbolic activation of the anti-circumvention tool. It backs it up with concrete measures targeting **financial services**, including, for the first time this explicitly, **cryptocurrencies**, according to details provided by the European Commission. This expansion into digital assets responds to a documented reality: sanctioned Russian actors, along with certain complicit intermediaries, have increasingly turned to cryptocurrencies to move funds while bypassing the traditional banking system, which is more easily monitored by Western regulators.

By explicitly targeting **cryptocurrencies** in its anti-circumvention framework, the **European Union** is acknowledging that the sanctions war has partly shifted onto digital terrain, where traditional surveillance tools — bank controls, SWIFT lists, classic asset freezes — are losing effectiveness. **It is a necessary adaptation to a reality regulators long underestimated.**

### Trade and Russian media propaganda also in the crosshairs

Beyond finance, the **package** also targets **trade** — likely through additional restrictions on dual-use goods capable of strengthening Russian military capabilities — as well as **Russian media propaganda**, a front the European Union has been building since the start of the conflict by banning several Kremlin-linked channels and outlets from European territory.

This **four-pronged approach** — financial, technological through cryptocurrencies, commercial, and informational — sketches an increasingly comprehensive sanctions doctrine, one that no longer settles for targeting individual symbols of Russian power but instead attacks the entire **set of circuits that keep the regime running despite international isolation**.

*What strikes me about this package is its systemic coherence. This is no longer just about targeting oligarchs or banks — it's about targeting the entire plumbing of circumvention: crypto, propaganda, trade circuits. This is the kind of sanction that never makes headlines but, accumulated over several years, genuinely complicates life for anyone trying to run a war economy under embargo.*

## Russian propaganda, target of an information war that dares not speak its name

### Why Europe is also targeting narratives, not just capital

The **propaganda component** devoted to **Russian media propaganda** deserves attention, because it reveals an often-underestimated dimension of this war: the battle of narratives. Since 2022, the Kremlin has invested heavily in international news channels, online disinformation networks, and influence campaigns aimed at weakening Western support for Ukraine, particularly among European public opinion most skeptical of continued military aid.

By building an **anti-propaganda component** into its anti-circumvention framework, the European Union is acknowledging that the information war is an integral part of Russia's war strategy, on par with missile strikes or diplomatic maneuvers. Cutting off the financing and distribution channels for this propaganda reduces the Kremlin's ability to maintain **narrative influence** inside Europe itself, where Western unity remains Ukraine's chief asset against Russian aggression.

### The limits of an information war fought through legal texts

Still, it's worth being honest about the **limits** of this exercise. Banning official channels is not enough to eradicate disinformation, which today thrives on decentralized platforms, anonymous accounts, and social networks that are difficult to regulate at a continental scale. Russian propaganda has already largely adapted to previous bans by redeploying under other formats, other channels, often harder to trace directly to Russian state sources.

**But every channel closed, every funding stream cut, every account identified and sanctioned represents one more piece of friction.** In an information war fought over the long haul, these accumulated frictions eventually add up, even if none of them, on its own, represents a decisive victory.

*In the West, we too often underestimate the scale of Russia's effort to shape European public opinion. This part of the sanctions package is not a minor measure — it is the belated recognition that the battle to keep convincing European citizens to keep supporting Ukraine is also fought in our own news feeds, not just on the battlefields of the Donbas.*

## Cryptocurrencies, the new front in the economic war

### A terrain Western regulators long neglected

During the war's early years, the question of **cryptocurrencies** as a sanctions-evasion tool remained relatively marginal in Western public debate, which was more focused on gas, oil, and the maritime shadow fleet. Yet several journalistic investigations and financial oversight reports have documented, over the years, the growing use of cryptocurrency exchange platforms by sanctioned Russian actors to move capital outside the traditional banking system.

The explicit inclusion of **cryptocurrencies** in this **20th package** confirms that Brussels now considers this terrain significant enough to warrant dedicated regulatory action. This fits a broader trend also seen in the **United States** and the **United Kingdom**, where financial regulators have likewise stepped up monitoring of cryptocurrency flows linked to sanctioned Russian entities.

### A technological race between regulators and violators

The **challenge** facing the European Union remains immense: the **decentralized**, cross-border nature of cryptocurrencies makes their regulation inherently more complex than that of classic banking flows, where major Western financial institutions exert far more **direct control**. Every **restrictive measure** taken by Brussels has to contend with exchange platforms based in less cooperative jurisdictions, where European investigations quickly run into political and legal limits.

It is an ongoing technological and regulatory race, in which **every European advance is quickly followed by an adaptation from sanctioned actors**. But inaction was no longer a viable option for Brussels, given how far the documented scale of the phenomenon had exceeded the threshold of political tolerance within European institutions.

*There is something almost ironic about the fact that technology meant to embody decentralized financial freedom has become, for some, a tool of circumvention serving an authoritarian regime at war. This doesn't discredit cryptocurrencies themselves — but it's a reminder that any technological innovation can be hijacked by those seeking to escape the consequences of their actions.*

## Trade in dual-use goods, a blind spot finally addressed

### How civilian components end up in Russian military drones

The **trade component** of this 20th package likely aims, as previous packages did, to close persistent gaps in the control of **dual-use goods** — civilian technologies that can also serve military purposes, such as certain semiconductors, electronic components, or navigation equipment. Since the start of the war, several investigations have shown that Western components, legally manufactured and sold to distributors in third countries, ended up equipping drones or guidance systems used by Russia on the Ukrainian battlefield.

This **trade diversion** phenomenon is one of the most persistent flaws in the Western sanctions regime. Despite tighter export controls since 2022, the complexity of international supply chains makes it extremely difficult to guarantee that a component legally sold in Europe won't end up, after several intermediaries, in a drone manufacturing workshop in Izhevsk or elsewhere in Russia.

### The anti-circumvention tool as a structural response

It is precisely this reality that justifies, according to **European authorities**, the activation of the anti-circumvention tool: rather than settling for sanctioning Russian entities directly, this mechanism allows Brussels to **trace the chain upward** and target **intermediaries** in third countries who facilitate this circumvention trade, whether knowingly or through **negligence**. It is a logical evolution after years in which European journalistic and parliamentary investigations have documented the scale of these parallel networks.

It remains to be seen whether this **new legal capacity** will translate into actual sanctions against specific entities in the months ahead, or whether it will remain, like other tools before it, more a rhetorical deterrent than a lever genuinely put to use in the field.

*I stay cautious on this specific point: having a legal tool never guarantees it will be used with the necessary rigor. The history of Western sanctions against Russia is also a history of good intentions that sometimes dissolved in the details of enforcement. This will be the real test of the coming months: will Brussels actually name and sanction recalcitrant third countries, or will it settle for simply having built the tool without ever fully using it?*

## The shadow fleet and the ports, another piece of the same package

### Murmansk, Tuapse, and the logic of geographic lockdown

This **20th sanctions package** is not limited to the anti-circumvention tool: it also includes the listing of the Russian ports of **Murmansk** and **Tuapse** among the banned port infrastructure for vessels linked to Russia's shadow fleet, along with, for the first time, a port located in a third country — the **Karimun oil terminal in Indonesia**. The European Union now lists **632 vessels** belonging to this shadow fleet, all barred from accessing European ports.

This coherence across the different parts of the package — anti-circumvention tool, cryptocurrencies, ports, shadow fleet — reveals an increasingly integrated approach from Brussels, where each measure reinforces the others rather than acting in isolation. **It is this systemic coherence, more than any single measure, that marks the real novelty of this 20th package.**

### A sanctions architecture reaching maturity

After more than **four years of war** and **twenty successive packages**, the European Union appears to have reached a level of legal and technical sophistication that would have been unthinkable in the conflict's early months, when sanctions were largely limited to individual asset freezes and travel bans for a few dozen Kremlin-linked oligarchs.

This **maturity** does not guarantee total effectiveness — Russia has repeatedly demonstrated its ability to adapt to Western sanctions. But it reflects genuine institutional learning, where every flaw identified in previous packages is progressively closed by increasingly targeted and technically elaborate measures.

*What impresses me, watching the evolution of these twenty packages since 2022, is not the perfection of the system — it is far from perfect — but its capacity to learn. Brussels started with largely symbolic gestures. Today it produces legal texts of a technical sophistication that would almost command respect, if the goal weren't so grave: depriving a war machine of the means to keep killing.*

## Reactions in Kyiv, Moscow, and Western capitals

### Ukraine welcomes progress, while demanding more

In **Kyiv**, this **20th package** was well received by Ukrainian authorities, who have long pushed for tougher anti-circumvention mechanisms, seen as one of the main flaws in the Western sanctions regime. Several Ukrainian officials nonetheless noted, in statements reported by the Ukrainian press, that the effectiveness of these measures will depend entirely on their actual enforcement in the months following their formal adoption.

This **Ukrainian caution** is not diplomatic bad faith. It reflects experience accumulated since 2022: several previous sanctions packages were greeted with enthusiasm at the time of their announcement, before revealing, over time, enforcement gaps or exemptions that partially neutralized their practical reach.

### Moscow downplays, as it does with every new package

On the **Russian** side, the official reaction follows a now-familiar pattern: publicly minimizing the impact of sanctions while quietly seeking, behind the scenes, new circumvention routes. The Kremlin has systematically presented each successive sanctions package as a sign of Western **weakness** rather than resolve, a communications exercise that becomes harder to sustain as the cumulative effects of these twenty packages are increasingly felt in the real Russian economy.

**The repetition of this denial narrative, package after package, says more about its defensive nature than about its economic accuracy.**

*There is a kind of theater in these systematic Russian reactions of minimization. But theater has a cost: by constantly repeating that nothing affects them, Russian authorities deprive themselves of the ability to honestly acknowledge, even internally, the scale of the real economic difficulties these cumulative sanctions are starting to cause.*

## The American and British precedents, an instructive comparison

### Washington and London already tested similar tools

The **European Union** is not the first Western power to experiment with targeted **anti-circumvention mechanisms**. The **United States**, through the Treasury Department's **OFAC** (Office of Foreign Assets Control), has for years developed secondary sanctions that directly threaten companies and financial institutions in third countries doing business with sanctioned Russian entities. The **United Kingdom**, for its part, has also strengthened its own post-Brexit sanctions regime, sometimes in close coordination with Washington and Brussels, sometimes independently.

This **transatlantic comparison** reveals an important structural difference: American secondary sanctions benefit from the **dollar's** dominant position in the global financial system, giving Washington a leverage point that Brussels does not possess to the same degree with the **euro**. The European anti-circumvention tool will therefore have to work within structural limits that equivalent American sanctions do not necessarily face.

### Transatlantic coordination, still imperfect

Despite largely shared goals, **coordination** between the American, British, and European sanctions regimes remains imperfect, with differing adoption timelines, sanctioned-entity lists that don't always fully overlap, and diplomatic priorities that sometimes diverge depending on the administration in power in **Washington**. The **Trump** administration, in particular, has broadly maintained a **firm** line on energy and military sanctions against Russia, while occasionally granting temporary exemptions on certain Russian oil purchases that have drawn criticism in Kyiv and Brussels.

**This lack of perfect synchronization creates blind spots that Russian circumvention networks know how to exploit**, redirecting their activities toward whichever jurisdiction is least coordinated at any given moment. It is precisely this reality that makes the activation of the European anti-circumvention tool all the more necessary, even though it arrives late in the conflict's timeline.

*I firmly believe that the real effectiveness of these sanctions will depend less on the sophistication of any single text than on the ability of Washington, London, and Brussels to coordinate without gaps. Every mismatch, every exemption granted unilaterally by one of the three Western blocs, hands Moscow an exit door that the other two will then have to painstakingly close.*

## Conclusion: One more tool in a war of attrition that isn't slowing down

### What this 20th package really changes

The activation of the European **anti-circumvention tool** will not end the **war in Ukraine**. It will not topple **Vladimir Putin's** regime overnight. But it represents a significant step in the growing sophistication of the Western sanctions arsenal, an evolution that, combined with the twenty previous packages, makes it harder every month for Russia to finance its war machine without friction.

This **package** also illustrates a broader truth about this war: it is not fought only on the front lines of the Donbas or in the skies over Kharkiv. It is also fought in European Commission meeting rooms, in the legal texts drafted by Brussels officials, and in the West's ability to sustain, over several years, coordinated pressure despite political fatigue and diverging economic interests.

### The question that remains open: consistency in enforcement

The **real test** of this 20th package won't play out in the weeks following its adoption, but in the months and years ahead, when the European Union will have to prove its genuine willingness to name and sanction recalcitrant third countries, rather than settling for having merely created the legal tool without ever fully using it.

**History will judge this package not by its intentions, but by its enforcement.** And it is precisely that enforcement, over time, that will determine whether the West lives up to its commitment to Ukraine.

*I close this piece without triumphalism. A legal tool, however well designed, is only worth as much as the political will that activates it. But I also close it without cynicism: after twenty packages, the European Union has proven it knows how to learn from its failures. That is not much, given Ukraine's urgency. But in a war of attrition, it is also the only thing that truly matters: holding the line, and getting better.*

**By Maxime Marquette, columnist**

## Columnist's transparency note

### Editorial stance

I am not a journalist but a **columnist and analyst**. My expertise lies in observing and analysing the geopolitical, economic and strategic dynamics that shape our world. My work is to take political strategies apart, to understand global economic movements, to put the decisions of international actors in context and to offer analytical perspectives on the changes that are redefining our societies.

I do not claim the cold objectivity of traditional journalism, which stops at reporting facts. **I claim analytical clarity**, rigorous interpretation and a deep understanding of the complex issues that concern us all. My role is to give meaning to the facts, to place them in their historical and strategic context, and to offer a critical reading of events.

### Method and sources

This text keeps the basic distinction between **verified facts and interpretive analysis**. The rule never changes: a factual claim is published only when a verifiable source supports it, and the sources this article actually used are listed under **Sources**, never here.

**Primary source families** used by the publication, when the story has them: official statements from governments and international institutions, public statements by political leaders, reports from intergovernmental organisations, dispatches from recognised international news agencies.

**Secondary source families**: specialised publications, internationally recognised news media, analyses from established research institutions, reports from industry organisations.

When an article cites statistical, economic or geopolitical data, it comes from the institutions that produce it (intergovernmental organisations, central banks, national statistics offices), and the exact institution is named under **Sources**.

### Nature of the analysis

The analyses, interpretations and perspectives in the analytical sections of this article are a **critical, contextual synthesis** based on the information available, the trends observed and the expert comments cited in the sources consulted.

My role is to interpret these facts, to set them in the context of today's geopolitical and economic dynamics, and to give them a coherent meaning within the larger story of the changes shaping our time. These analyses reflect expertise built through continuous observation of international affairs and an understanding of the strategic mechanisms that drive global actors.

This article describes a documented state of affairs on its publication date, not a prediction: later developments may shift its outlook. No update is promised in advance; when an article is corrected or completed, the change is dated in the text.

## Sources

### Primary sources

- [European Commission: EU adopts 20th sanctions package against Russia — April 23, 2026](https://finance.ec.europa.eu/news/eu-adopts-20th-package-sanctions-against-russia-2026-04-23_en)

- [What's in the EU's 20th sanctions package against Russia — Reuters, April 22, 2026](https://www.reuters.com/business/energy/whats-eus-20th-package-sanctions-against-russia-2026-04-22/)

### Secondary sources

- [Ongoing coverage of the war and Western sanctions — The Kyiv Independent](https://kyivindependent.com/)

- [News and analysis on the Russo-Ukrainian war — Ukrinform](https://www.ukrinform.net/)

- [Drone strikes force Russian refineries to halt, deepening economic pressure — The Moscow Times, May 20, 2026](https://www.themoscowtimes.com/2026/05/20/drone-strikes-force-central-russian-refineries-to-halt-or-cut-output-reuters-a92805)

- [Drone offensive hits Russian oil tankers and refineries at "industrial scale" — Fox News, July 8, 2026](https://www.foxnews.com/world/drone-offensive-hits-russian-oil-tankers-refineries-industrial-scale-moscow-bans-diesel-exports)

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Source: Maxime Marquette, MadMax. When citing, name the author and link https://mad-max.co/en/article/analysis-the-eu-finally-draws-its-anti-circumvention-weapon-on-putin