EU’s 20th Russia Sanctions Package Signals a New Era of Crypto-Specific Enforcement

The EU's 20th sanctions package imposes a sectoral ban on Russia-based centralized and decentralized crypto service providers, explicitly prohibits state-backed crypto instruments (RUBx and the digital ruble), designates third-country VASPs such as Kyrgyz exchange TengriCoin/Meer.kg, activates the EU’s anti-circumvention tool (including bans on netting transactions and SPFS-linked institutions), and pairs these measures with expanded vessel, LNG, and export-control sanctions — signaling heightened compliance expectations for VASPs under the EU AMLR and a shift toward sanctioning evasion architectures rather than just named entities.