Greece wins LNG carveout in EU sanctions

The EU's 21st sanctions package against Russia passed on 23 July. But it passed Greece's way.

Athens blocked the entire package until it won an exemption: Greek-linked shipping companies can keep transporting Russian liquefied natural gas to non-EU buyers, provided the contracts predate Russia's full-scale invasion (Euronews, Council press release). Everything else in the package waited: listings of shadow-fleet vessels (ageing or opaque tankers used to move Russian oil around Western sanctions), banking restrictions, crypto measures, an oil-price-cap freeze. None of it moved until Athens got its carveout.

As To Brief reported when Greece first blocked the vote, this dispute reaches into whether the way the EU builds sanctions can survive contact with the industries it needs for enforcement.

The firms inside the weapon

EU sanctions on Russian energy work through services, not embargoes. Brussels doesn't try to pull Russian oil and gas off the global market. It restricts the Western firms that make those exports possible: shippers, insurers, port operators and brokers (European Commission). Control access to those services, and Russian energy becomes harder and costlier to sell.

The structural problem: those firms sit inside member states whose governments must unanimously approve every sanctions decision. A country whose companies provide the targeted service can hold up the whole package.

Greece operates the largest merchant fleet in the EU (Al Jazeera). Athens argued that banning Greek operators from carrying Russian LNG to third countries would hand the business to non-EU competitors while leaving Moscow's revenues intact. The financial stakes back the argument. EUobserver, citing analysis by the Centre for Research on Energy and Clean Air, reported that Greek-controlled ships carried roughly €248bn worth of Russian fossil fuels since the full-scale invasion began (EUobserver). According to UPI, citing the research group Urgewald, Dynagas, the shipping group linked to Greek billionaire George Prokopiou, handled about 35% of Novatek-linked Russian LNG activity in early 2026 (UPI).

Athens converted a genuine complaint about unequal cost into a carveout that preserved exactly the pressure point the EU had identified and tried to close.

The contrast across capitals

Lithuanian Foreign Minister Kęstutis Budrys said sanctions decisions are increasingly shaped by member states' economic interests, weakening collective pressure on Moscow (LRT). Dutch officials framed the result as progress, emphasising shadow-fleet listings and anti-circumvention tools despite the Greek exemption (Rijksoverheid, NRC).

Denmark is the useful comparison. Copenhagen runs one of Europe's largest merchant fleets but sought no equivalent exemption. A large fleet does not automatically produce a veto threat. The Greek position was a political choice, not a mechanical consequence of market share.

Smaller packages, same structural flaw

The package still delivered substance: 41 additional shadow-fleet vessel listings, expanded criteria covering ships that service sanctioned vessels, and new banking and crypto restrictions (Finnish government, Global Sanctions). The FT reported that EU officials are now exploring smaller, more targeted rounds so that one government's objection cannot hold unrelated measures hostage (FT).

Switching to majority voting is not available. Sanctions fall under EU foreign policy, where unanimity is the rule, and changing that rule would itself require unanimity (IAI). Smaller packages limit how much one objection can delay. They do not eliminate the veto.

Greece showed that a member state can use the unanimity requirement to protect a national industry, even when that weakens a pressure point the EU built against Russia. Athens argues the business would have shifted outside the bloc anyway, and the commercial logic is not baseless. But the unanswered question is enforcement: if Greek firms keep transporting LNG under pre-war contracts, who reviews those contracts, monitors volumes and checks whether renewals quietly stretch the exemption? The officials designing the 22nd package owe that answer.