EU Sanctions Package May Target Intermediaries in Third Countries
The European Union is preparing a proposed 22nd sanctions package focused primarily on preventing the circumvention of existing restrictions.
According to Izvestia, the package is not expected to introduce major new sector-wide bans. Instead, it may expand blacklists and target companies, banks and individuals viewed as intermediaries in third-country trading structures.
The European Commission is preparing the proposal, with approval procedures expected to be completed around the meeting of the EU Foreign Affairs Council scheduled for 12 October.
Compliance pressure may extend beyond Russia
The proposed approach is based on targeted restrictions rather than broad new prohibitions.
The measures may affect:
- trading intermediaries
- banks
- logistics companies
- corporate service providers
- counterparties in third countries
- entities involved in re-export structures
Earlier reporting cited a possible expansion of sanctions lists by up to 1,600 companies. Existing EU restrictions already cover more than 3,100 individuals and legal entities.
The article also notes that the previous package included companies from China and other non-EU jurisdictions.
A transaction may face compliance risk even when the product itself is not subject to a new sectoral ban.
Implications for fertilizer and chemical trade
Fertilizer and chemical buyers should verify the full transaction chain, including:
- legal seller and buyer
- beneficial ownership
- origin and destination
- banks and payment route
- vessel and logistics providers
- export and import documentation
- role of any intermediary
Several EU countries have previously raised objections to measures affecting raw-material trade and maritime transport, showing that the final package may differ from the initial proposal.
EUROCHEM TRADING proceeds only with verified counterparties and a documented transaction structure. Product allocation follows verification, SPA execution and funding of the first contractual stage through the Trading Portal.
Source: Izvestia, 5 August 2026.