Adopted Apr 23. Three days ago. Crickets on the tape.
Quick rundown of what’s actually in the 20th package:
• 120 new listings, biggest single batch in two years
• Expanded export bans on metals, minerals, chemicals and industrial tools, over €930M in trade value
• Norilsk-adjacent and Russian energy hammered: Bashneft, Slavneft, Gazprom Flot, Gazprom LNG, Rosneftflot, plus refineries at Tuapse, Komsomolsk, Angarsk, Achinsk, Ryazan, Afipsky and multiple LUKOIL sites
• 46 more shadow fleet tankers added (632 total), maritime services ban framework laid
• Anti-circumvention tool activated for the first time ever, with Kyrgyzstan formally designated as a circumvention jurisdiction
• 20 Russian banks plus 4 third-country banks (Kyrgyzstan, Laos, Azerbaijan) hit with a transaction ban
• LNG terminal services ban kicks in Jan 1, 2027
Now the piece nobody seems to be pricing.
Bloomberg reported back in February that the original package draft included direct import bans on Russian platinum, iridium, rhodium and copper. The primary target was always Norilsk Nickel, world’s #1 palladium producer, #3 platinum producer, and Russia’s largest producer of Pt, Ir and Rh. Norilsk has somehow never been directly sanctioned because the West literally cannot run its catalytic converters without them. Pd was explicitly carved out of the package for that reason. Pt, Ir and Rh were not.
Context that matters:
• Pt is in structural deficit (WPIC flagging this 3 quarters running)
• LPPM delisted Russian refiners in 2022, so Western trading hubs already de-risked
• Russian PGM flow has been quietly redirecting to Asia anyway
• Iridium and rhodium are tiny, illiquid markets where pulling any meaningful volume is a price event
So why is spot acting like none of this happened?
Three options as I see it:
1. Pt, Ir and Rh got softened or pulled in the final negotiated text and the leaks were stale
2. Market shrugs because the trade was de-facto dead already
3. Market is asleep
I have not seen the full Annex of Reg 2026/506, 509 and 511 yet. If anyone here has actually read the adopted regulation text and can confirm whether unwrought Pt, Ir and Rh made the cut, that’s the answer that matters before the next session opens.
TL;DR: EU adopted its 20th sanctions package on Apr 23. Biggest listings batch in two years, first-ever activation of the anti-circumvention tool, €930M+ in expanded metals and minerals export bans, and a Feb Bloomberg leak said the draft included direct import bans on Russian platinum, iridium and rhodium (palladium carved out). Tape is acting like none of it happened. Either the PGMs got pulled in the final text, the market doesn’t care, or the market is asleep. Looking for anyone with the actual Annex of Reg 2026/506, 509 or 511 to confirm.