The European Commission's 20th sanctions package proposes a comprehensive ban on all cryptocurrency transactions involving Russia, an escalation from targeting specific bad actors to attempting to sanitize the rails themselves. The question is whether the EU can raise the cost of evasion sufficiently by controlling chokepoints: regulated exchanges, stablecoin issuers, and third-country financial intermediaries. The proposal arrives at a moment when enforcement data already tells a clear story about displacement. Between 2024 and 2025, flows to and from sanctioned entities via centralized exchanges fell roughly 30%, according to TRM Labs. Over the same period, flows through high-risk, no-KYC, and decentralized services increased by more than 200%. Russia hasn't stopped using crypto for cross-border trade and sanctions evasion. It has simply moved the activity to venues beyond the reach of Western compliance infrastructure. What's actually new and what's already bannedThe EU's Russia sanctions framework already prohibits providing crypto-asset wallet, account, or custody services to Russian nationals, residents, and Russia-established entities. The 19th sanctions package went further, banning transactions involving A7A5, a Russia-linked stablecoin that Chainalysis estimates has processed $93.3 billion in less than a year.