AUTHOR: Anna Cesar – Senior Manager Regulatory Compliance, EMEA

Since the adoption of the EU's 18th sanctions package in July 2025, the EU has introduced three additional sanctions packages (19th, 20th and 21st) with a continued focus on anti-circumvention, financial controls, and transportation networks used to support Russia's war effort.

Impacts on the Clinical Supply Chain

Designated Airports and Transport Infrastructure

Recent sanctions packages expanded restrictions on certain Russian transport infrastructure, including airports and ports identified as supporting the Russian military and sanctions-circumvention activities.

Impact:

• Additional due diligence may be required when shipments pass through sanctioned ports, terminals, ships, or airports.
• Clients should assess whether applicable exemptions, derogations or authorisations are available before arranging shipments.

Medicinal Product Exemptions

EU sanctions continue to provide exemptions and authorisation mechanisms for certain healthcare-related goods, including medicinal products and clinical trial materials. Applicable exemptions must be assessed by the shipper on a case-by-case basis.

Other Key Developments

• Increased focus on anti-circumvention controls, particularly involving third-country routing and intermediary parties.
• Expanded sanctions affecting banks, financial institutions and crypto-asset providers, increasing the importance of payment screening.
• Continued growth in the number of sanctioned vessels and logistics providers supporting Russian trade networks.

Marken is committed to supporting clients as regulatory requirements continue to evolve. For further information or assistance, please contact TradeCompliance@marken.com.

Sources

• European Commission – 19th Package of Sanctions (23 October 2025) 
• European Commission – 20th Package of Sanctions (23 April 2026) 
• European Commission – 21st Package of Sanctions (23 July 2026) 
• Council of the European Union Press Releases on the 19th, 20th and 21st Packages