Key data
| Regulation | Council Decision (CFSP) 2026/1357, of 15 June 2026 |
|---|---|
| Modified regulation | Council Decision (CFSP) 2023/891 on restrictive measures concerning Moldova |
| Publication | 15 June 2026 |
| Entry into force | 15 June 2026 (immediate effect) |
| Affected parties | Companies and individuals with commercial or financial relationships linked to Moldova |
| Category | European Regulation — Common Foreign and Security Policy (CFSP) |
| Year | 2026 |
| CELEX reference | 32026D1357 |
From 15 June 2026, Spanish companies with links in Moldova or the region must operate with an updated sanctions list. Decision (CFSP) 2026/1357 modifies Decision (CFSP) 2023/891 —the sanctioning framework in force since 2023— and introduces changes that may affect the lists of sanctioned persons and entities, travel bans, and applicable asset freezes.
This decision is part of the EU's common foreign and security policy (CFSP) in response to external interference in Moldova. Non-compliance is not a minor matter: the consequences include both administrative sanctions and criminal liability for executives and the company.
What does this regulation establish?
Decision (CFSP) 2026/1357 modifies the sanctioning regime established in 2023 against those destabilizing the Republic of Moldova. The changes may include the following elements of the restrictive framework:
| Element of the sanctioning regime | Description |
|---|---|
| Lists of sanctioned persons and entities | Update of designated subjects: new natural or legal persons may be added, or previously included ones removed |
| Asset freezes | Prohibition on making funds or economic resources available to designated subjects |
| Travel bans | Restrictions on entry and transit in EU territory for designated persons |
| Adjustments to commercial or financial prohibitions | Possible modifications to restrictions applicable to operations with listed subjects |
The original reference regulation, Decision (CFSP) 2023/891, established the initial framework of restrictive measures. This 2026 update adapts it to the current situation, which requires all affected companies to review their third-party databases and screening procedures against the updated list.
Economic and operational impact
The impact is not only legal: operating with a sanctioned counterparty can result in immediate suspension of operations, freezing of funds in transit, and opening of sanctioning proceedings. The specific risks for companies are:
- Serious administrative sanctions for maintaining commercial or financial relationships with subjects included in the updated lists.
- Criminal liability for administrators and executives if knowledge or gross negligence in compliance is established.
- Blocking of payments and transfers if the intermediary financial entity detects a sanctioned counterparty.
- Reputational damage to clients, investors, and financing entities.
- Operational adaptation costs: updating screening systems, reviewing existing contracts, and training compliance teams.
The cost of not acting far exceeds the cost of reviewing controls. The competent authorities in Spain —mainly the Ministry of Foreign Affairs and the State Secretariat for Trade— can initiate inspections upon evidence of non-compliance.
Who does it affect?
This regulation directly affects any Spanish operator with links in Moldova or with counterparties operating in the region:
- Exporters and importers with commercial operations to or from Moldova.
- Financial entities and payment operators that process transfers with Moldovan counterparties or with subjects linked to the region.
- Investment companies and funds with positions in assets or companies with presence in Moldova.
- Advisors, consultancies, and law firms that provide services to clients with links in the region.
- Logistics and transport companies that operate routes with origin or destination in Moldova.
- Any company that has suppliers, distributors, or business partners in Moldova or in neighboring countries with exposure to sanctioned subjects.
Practical example
A Spanish agricultural machinery company exports equipment to a distributor in Moldova with which it has worked since 2021. Following the publication of Decision (CFSP) 2026/1357 on 15 June 2026, the compliance officer must verify whether that distributor —or its partners and administrators— appears on the updated list of sanctioned persons and entities.
If the distributor has been added to the list in this update and the Spanish company continues to execute pending orders or transfer funds, it would be in breach of EU restrictive measures. This could result in the opening of an administrative sanctioning proceeding and, depending on severity, criminal liability for its administrators. The solution: execute screening before processing any pending operation and cautiously suspend transactions until confirming that the counterparty is not designated.
What should companies do now?
- Immediately review the updated list of sanctioned subjects published in the Official Journal of the EU to identify whether any counterparty, partner, or supplier has been designated.
- Execute screening of the entire portfolio of counterparties linked to Moldova or the region, including natural persons (administrators, partners, representatives) and legal persons.
- Cautiously suspend any pending operations with Moldovan counterparties until confirming that they are not included in the updated lists.
- Update internal compliance systems with the new list of designated subjects and establish automatic alerts for future updates.
- Review existing contracts with counterparties in Moldova to include international sanctions compliance clauses if they do not already have them.
- Inform the management team and legal department of the regulatory change and associated risks of non-compliance, including possible criminal liability of administrators.
- Consult with a specialist advisor in foreign trade and international sanctions if there is any doubt about the company's specific exposure.
Frequently asked questions
When do the new sanctions against Moldova come into force?
Decision (CFSP) 2026/1357 came into force on the same day as its publication: 15 June 2026. There is no transitional period: obligations are enforceable from that date.
What happens if my company operates with a counterparty that appears on the updated list?
If a company maintains commercial or financial relationships with subjects included in the updated lists, it may face serious administrative sanctions and criminal liability for its administrators. It is essential to suspend operations and consult with a specialist advisor immediately.
Where can I consult the updated list of sanctioned persons and entities?
The official list is published in the Official Journal of the European Union (EUR-Lex), under CELEX reference 32026D1357. It can also be consulted in the EU sanctions repository maintained by the European External Action Service.
Does this regulation only affect companies that export to Moldova?
No. It affects any company with commercial or financial relationships linked to Moldova: importers, exporters, financial entities, investors, advisors, logistics companies, and any operator that has counterparties in the region, regardless of the direction of the commercial flow.
What is the difference between this decision and Decision (CFSP) 2023/891 that it modifies?
Decision (CFSP) 2023/891 established the original framework of restrictive measures against those destabilizing Moldova. The new Decision (CFSP) 2026/1357 updates it: it may involve changes to the lists of designated persons and entities, adjustments to travel bans, and modifications to asset freezes. Companies must always operate with the most recent version of the lists.
Official source
Consult complete regulation in official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026D1357