Greece Secures LNG Sanctions Loophole

The EU's 21st sanctions package against Russia passed on 23 July, but only after Athens got what it wanted.

Greece held up the package until it secured an exemption for Greek-linked shipping companies. They can continue carrying Russian liquefied natural gas to buyers outside the EU, as long as the contracts were signed before Russia's full-scale invasion (Euronews, Council press release). Until that carveout was agreed, the rest of the sanctions file sat still: listings of shadow-fleet vessels, meaning old or opaque tankers used to move Russian oil around Western restrictions; banking measures; crypto controls; and a freeze on the oil price cap.

As To Brief reported when Greece first blocked the vote, the argument goes beyond one concession to Athens. It exposes a weakness in the way the EU builds sanctions when the companies needed to enforce them sit inside member states with veto power.

The firms inside the weapon

EU sanctions on Russian energy work through services rather than a full embargo. Brussels is not trying to remove Russian oil and gas from the global market. It is restricting the Western firms that make those exports possible: shipowners, insurers, port operators and brokers (European Commission). If access to those services becomes harder, Russian energy becomes more expensive and more complicated to sell.

The problem is built into the EU system. Those firms are based in member states, and every sanctions decision needs unanimous approval. A government whose national industry is being targeted can hold up the entire package.

Greece has the largest merchant fleet in the EU (Al Jazeera). Athens argued that stopping Greek operators from carrying Russian LNG to third countries would not cut Moscow's revenues, but would simply hand the business to non-EU competitors. The money involved explains the pressure. EUobserver, citing analysis by the Centre for Research on Energy and Clean Air, reported that Greek-controlled ships have carried about €248 billion 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).

For Malta, the logic is familiar. Small EU states with specialised sectors know how quickly a Brussels measure can become domestic economic policy. Shipping, financial services, gaming and compliance are not abstract categories here; they are jobs, licences and reputational risk. Athens took a real argument about unequal costs and turned it into an exemption that preserved precisely the weak point the EU had tried to close.

The contrast across capitals

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

Denmark is the sharper comparison. Copenhagen also runs one of Europe's largest merchant fleets, but did not seek an equivalent exemption. A large fleet does not automatically produce a veto threat. The Greek position was a political decision, not an unavoidable consequence of market share.

Smaller packages, same structural flaw

The package still contains real measures: 41 additional shadow-fleet vessel listings, wider 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 looking at smaller, more targeted sanctions rounds so that one government's objection cannot hold unrelated measures hostage (FT).

Majority voting is not available for this file. 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 one objection. They do not remove the veto.

Greece has shown how a member state can use unanimity to protect a national industry even when that weakens a pressure point the EU built against Russia. Athens says the business would have moved outside the bloc anyway, and the commercial argument is not empty. The test now is enforcement. If Greek firms keep carrying LNG under pre-war contracts, who checks those contracts, monitors volumes and makes sure renewals do not quietly extend the exemption? The officials drafting the 22nd package need an answer before the next veto is priced in.