Greece Secures LNG Sanctions Loophole

The EU's 21st sanctions package against Russia was agreed on 23 July, but only after Athens got what it came for.

Greece held up the package until it secured an exemption for Greek-linked shipping companies. They will still be allowed to carry Russian liquefied natural gas to buyers outside the EU, as long as the contracts were signed before Russia's full-scale invasion of Ukraine (Euronews, Council press release). Until that was settled, the rest of the sanctions package sat still: new listings of shadow-fleet vessels, tighter banking restrictions, crypto measures and a freeze on the oil price cap. The shadow fleet refers to ageing or opaque tankers used to move Russian oil around Western sanctions. None of the measures moved until Greece got its carveout.

As To Brief reported when Greece first blocked the vote, this row goes to the centre of how EU sanctions are built: they depend on industries that sit inside member states, and those same member states have a veto.

The firms inside the weapon

EU sanctions on Russian energy are built around services rather than a simple embargo. Brussels is not trying to remove Russian oil and gas from the world market altogether. It is trying to restrict the Western firms that make those exports work: shippers, insurers, port operators and brokers (European Commission). If Moscow loses access to those services, selling energy becomes harder and more expensive.

The problem is that these firms are not abstract European infrastructure. They are based in real member states, with real governments, and every sanctions decision still needs unanimous approval. If a country's companies provide the service being targeted, that government can slow the whole process down.

Greece operates the largest merchant fleet in the EU (Al Jazeera). Athens argued that stopping Greek operators from carrying Russian LNG to third countries would simply hand the trade to non-EU rivals while doing little to reduce Moscow's income. There is commercial weight behind that claim. 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). UPI, citing the research group Urgewald, reported that Dynagas, the shipping group linked to Greek billionaire George Prokopiou, handled about 35% of Novatek-linked Russian LNG activity in early 2026 (UPI).

Athens took a fair complaint about uneven costs and turned it into a carveout that protects the very pressure point the EU had identified.

The contrast across capitals

Lithuanian Foreign Minister Kęstutis Budrys said sanctions decisions are increasingly being shaped by member states' economic interests, which weakens the collective pressure on Moscow (LRT). Dutch officials chose a more pragmatic line, presenting the package as progress because it still included shadow-fleet listings and new anti-circumvention tools despite the Greek exemption (Rijksoverheid, NRC).

Denmark is the revealing comparison. Copenhagen also has one of Europe's largest merchant fleets, but it did not seek an equivalent exemption. A large shipping sector does not automatically lead to a veto threat. Greece made a political choice, not an unavoidable response to market share.

Smaller packages, same structural flaw

The package still does real work. It adds 41 shadow-fleet vessels to the sanctions list, expands the criteria to include ships servicing sanctioned vessels, and introduces new banking and crypto restrictions (Finnish government, Global Sanctions). The FT reported that EU officials are now looking at smaller, more targeted sanctions rounds so that one government's objection cannot hold up unrelated measures (FT).

Majority voting is not on the table. Sanctions fall under EU foreign policy, where unanimity remains the rule, and changing that rule would itself require unanimity (IAI). Smaller packages can reduce the damage caused by a single objection. They cannot remove the veto.

Greece has shown how a member state can use unanimity to protect a national industry, even when doing so weakens a pressure point the EU designed against Russia. Athens says the business would have moved outside the bloc anyway, and that argument is not without logic. The harder question is enforcement. If Greek firms can keep carrying LNG under pre-war contracts, who checks those contracts, tracks the volumes and ensures renewals do not quietly stretch the exemption? The officials drafting the 22nd package need an answer.