European Commission President Ursula von der Leyen said on November 12, 2026, that the Commission plans to present a new Russia sanctions package before the European Council's special summit on November 26–27. The proposed measures would represent the EU's 22nd sanctions package since Russia's full-scale invasion of Ukraine.
According to Reuters, the package under discussion may focus on banks, cryptocurrencies, and crypto platforms while seeking to close channels used to circumvent existing restrictions through third countries. The measures are still being developed, and proposed provisions should not be treated as sanctions already in force.
Why Are Crypto Platforms Part of the EU Sanctions Discussion?
Sanctions enforcement involves more than preventing listed entities from accessing financial services directly. Authorities also need to assess whether sanctioned parties continue moving funds through third-country institutions, affiliated companies, or digital asset service providers. Because crypto assets can move across borders and through multiple wallets and service providers, they represent a potential channel that regulators monitor.
The EU has already adopted multiple rounds of restrictions targeting Russian financial institutions and economic activity. One focus of the latest discussions is identifying how sanctioned parties may use foreign banks, payment channels, and crypto platforms to maintain access to financial services.
How Can Third-Country Sanctions Evasion Risks Be Identified?
A connection to a third country does not automatically mean that a business or transaction violates sanctions. Compliance teams need to assess specific counterparties, beneficial owners, fund origins, and transaction flows rather than making decisions based solely on geography.
For crypto platforms, relevant risk scenarios include sanctioned parties using third-party wallets, affiliated companies arranging transfers, and funds moving through several exchanges before re-entering regulated financial channels.
Businesses should combine sanctions-list screening, customer due diligence, and KYT analysis to identify wallet relationships with known high-risk entities. Complex transaction paths should be escalated for further review.
How Should Crypto Providers Prepare for Potential Sanctions Changes?
The EU's next sanctions package has not yet been formally published. Businesses should therefore avoid treating measures under discussion as current legal obligations. They can, however, use the preparation period to review whether existing controls cover third-country transactions, affiliated entities, wallet addresses, and indirect fund flows.
An effective sanctions compliance framework should include list updates, customer and counterparty screening, on-chain risk monitoring, escalation procedures, and audit records. Firms should also define how to handle potential matches, including restrictions, transaction rejection, and reporting where legally required.
As the EU continues to examine the potential use of digital assets for sanctions evasion, crypto platforms need to incorporate indirect transactions and cross-border fund paths into ongoing risk assessments rather than screening only the names of direct customers.