EU agrees 21st Russia sanctions package, granting Greece a carve-out to continue shipping Russian LNG to non-EU clients under pre-invasion contracts
EU member state ambassadors reached agreement on a 21st package of sanctions against Russia, with the deal unlocked only after Greece secured a targeted exemption allowing it to continue shipping Russian LNG (liquefied natural gas) to non-EU clients. The carve-out covers contracts concluded before the start of Russia's invasion of Ukraine in February 2022. Greece, which operates the world's largest merchant fleet, had blocked agreement on the sanctions package by demanding a revision of a Russian LNG ban unanimously agreed as part of a previous sanctions round. The country held its veto firmly in place until the majority of member states agreed to introduce the derogation. Without the exemption, Greek-flagged or Greek-operated vessels would have faced restrictions on transshipping Russian LNG cargoes to third-country buyers, threatening a commercially significant trade route for the Greek shipping sector. The exemption is framed as limited to pre-invasion contracts with non-EU buyers, meaning the political cost of the concession is contained. However, the precedent of one member state securing a sector-specific carve-out to a unanimously agreed prior restriction will be closely watched by other member states seeking flexibility in future sanctions rounds. The agreement adds to an already complex landscape for energy traders, commodity finance lenders, and shipping companies who must continuously track the boundary between permitted and prohibited transactions under evolving EU sanctions frameworks.
Why this matters
The Greek LNG carve-out has direct implications for energy traders, commodity finance banks, and shipping companies who structure transactions around permitted categories in EU sanctions regulations. Every new sanctions package and every new exemption requires legal teams to update compliance matrices, re-screen existing contracts, and advise clients on whether their specific arrangements fall within or outside the derogation. The use of a veto by a single member state to extract a sector-specific exemption also illustrates the political fragility of EU sanctions consensus, which matters for project finance lawyers advising on long-term energy infrastructure with any Russian supply chain exposure. London-based commodity trading desks and shipping finance practices will need to review the precise drafting of the exemption to advise on which contracts and trade routes remain permissible.
On the Ground
A trainee on a sanctions compliance matter would assist with drafting regulatory filing coordination memos summarising the new exemption's scope, preparing licence condition summaries for clients in the shipping or commodity trading sectors, and updating compliance gap analysis memos to reflect the revised permitted categories under the 21st sanctions package.
Interview prep
Question you might get
“How would you advise a London-based commodity trading client on whether its existing contracts for shipping Russian LNG fall within the Greek exemption secured under the EU's 21st sanctions package?”
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