EU Sanctions Against Russia 2026: What Companies Must Verify

Key data

If your company operates with Russian counterparties, has suppliers in Russia or manages international payments to that country, this update affects you from today. Council Implementing Regulation (EU) 2026/1362, published on 15 June 2026, expands the list of persons and entities subject to restrictive measures under Regulation (EU) 2024/1485, relating to the situation in Russia.

The effect is immediate: there is no adaptation period. From the same day of publication, it is prohibited to make funds or economic resources available to any person or entity included in the updated list.

What does this regulation establish?

Council Implementing Regulation (EU) 2026/1362 updates the annex to Regulation (EU) 2024/1485, which is the general framework of EU sanctions related to the situation in Russia. The update consists of incorporating new natural and legal persons to the list of designated persons.

The two restrictive measures that apply to all designated persons are:

• Asset freezing: all funds and economic resources belonging to designated persons or entities located in EU territory are frozen immediately.
• Prohibition of making funds available: no European person or company may make funds, assets or economic resources available to designated persons, either directly or indirectly.

This regulation is part of the EU's autonomous sanctions regime, different from the sectoral sanctions regime. It affects specific persons and entities identified by the Council, not entire economic sectors. The EU consolidated list of sanctions contains all designated persons and is updated with each new implementing regulation.

Economic and operational impact

The economic risk of breaching these sanctions is twofold: legal and reputational. The specific consequences established by the regulatory framework are:

• Administrative sanctions imposed by the competent authorities of each Member State.
• Criminal sanctions in Member States that classify non-compliance as a criminal offense (in Spain, it may involve criminal liability of legal persons).
• Freezing of ongoing operations if a counterparty is detected to be designated, with the consequent impact on treasury and contracts.

The operational cost of adapting is significantly lower than the cost of non-compliance. Companies that already have third-party screening systems must update their databases with the new list. Those that do not have them must implement them urgently.

The impact is especially relevant for financial operators, exporters and companies with supply chains that include Russian entities, as they are the most exposed to compliance risk according to the regulatory text itself.

Who does it affect?

• Financial entities and banks that manage accounts, transfers or investment products linked to Russia.
• Exporters and importers with active commercial relations with Russian counterparties.
• Companies with Russian suppliers at any level of the supply chain.
• Advisors, consultancies and law firms that provide services to persons or entities of Russian origin.
• Logistics and transport companies that operate routes or manage goods with origin or destination in Russia.
• CFOs and financial directors responsible for regulatory compliance controls in their organizations.
• Compliance officers of any company with direct or indirect exposure to Russian counterparties.

Practical example

A Spanish industrial components company has a distributor in Moscow with which it has operated since 2019. On 15 June 2026, the EU Council publishes Implementing Regulation 2026/1362 and that distributor is included in the list of designated persons.

From that same day, the Spanish company is prohibited from making any pending payment, sending merchandise or providing any service to that distributor. If it has outstanding invoices, the funds are frozen. If it executes a transfer after that date without having verified the list, it incurs non-compliance with international sanctions, with the administrative and criminal consequences that this entails in Spain.

The difference between detecting it on the same day (through an automated screening system) or detecting it weeks later can be decisive in avoiding liability.

What should companies do now?

1. Consult the EU consolidated sanctions list today: access the official EU sanctions tool (Sanctions Map) and verify whether any of your Russian counterparties appear as designated following the update of 15 June 2026.
2. Update third-party screening systems: if you have compliance software (KYC, AML, sanctions lists), force the update of databases with the new list published under Regulation 2026/1362.
3. Review contracts and ongoing operations: identify pending payments, active orders or services being executed with Russian counterparties and verify their status before proceeding.
4. Cautiously suspend doubtful operations: if in doubt about whether a counterparty is designated, halt the operation until you confirm their status. The cost of a delay is less than the cost of non-compliance.
5. Document the verification process: record when and how you performed the check. This documentation is key in case of inspection or subsequent investigation.
6. Consult specialized legal advice: if you have significant exposure to Russian counterparties, involve your legal advisor or compliance officer to assess the specific risk of your client and supplier portfolio.

Official source

Consult full regulation on 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:32026R1362