Key data
| Regulation | Commission Implementing Regulation (EU) 2026/1356 of June 15, 2026 |
|---|---|
| Legal basis | Regulation (EU) 2024/2642 on restrictive measures for destabilizing activities of Russia |
| Publication | June 15, 2026 |
| Entry into force | June 15, 2026 (immediate application) |
| Affected parties | Companies and financial entities with commercial or financial links to Russia or sanctioned persons |
| Category | European Regulation — directly applicable in all Member States |
| Measures | Freezing of assets and prohibition of making funds available to listed parties |
| CELEX reference | 32026R1356 |
If your company has contracts, transactions or financial relationships with Russia or Russian counterparties, this regulation requires you to act today. The Commission Implementing Regulation (EU) 2026/1356, published and in force on June 15, 2026, expands the list of natural and legal persons subject to restrictive measures under Regulation (EU) 2024/2642. It requires no national transposition: it is directly applicable in Spain from its publication.
The measures are not new in nature, but the list is updated and each update may include counterparties with which your company currently operates. Ignoring a list update does not exempt you from responsibility.
What does this regulation establish?
Regulation 2026/1356 is an implementing regulation, which means it does not create a new sanctions framework, but rather applies and updates the existing one under Regulation (EU) 2024/2642. Its specific content is as follows:
- Expansion of the list of sanctioned parties: New natural and legal persons linked to destabilizing activities attributed to Russia are added.
- Freezing of assets: All funds and economic resources belonging to listed parties must be immobilized immediately.
- Prohibition of making funds available: It is prohibited to transfer, pay, assign or make available to sanctioned parties any funds or economic resources, directly or indirectly.
- Direct application: The regulation is directly applicable in all EU Member States without the need for national transposition, including Spain.
- Verification obligation: EU companies and financial entities are obliged to verify their commercial and financial relationships against the updated list.
The sanctions framework of Regulation (EU) 2024/2642 was specifically designed to respond to destabilization activities attributed to Russia, differentiating itself from the sanctions regime for the war in Ukraine, although both coexist and are applied in a complementary manner.
Economic and operational impact
The direct impact for affected companies is twofold: operational and legal risk.
| Dimension | Concrete impact |
|---|---|
| Ongoing contracts | Must be reviewed to detect if any counterparty appears on the updated list. If so, contract execution is blocked. |
| Financial transactions | Payments, transfers or any movement of funds to sanctioned parties is prohibited as of 15/06/2026. |
| Assets under management | Financial entities must immediately immobilize any assets belonging to newly listed parties. |
| Non-compliance risk | Administrative and criminal sanctions under current Spanish law for those who fail to comply. |
| Compliance cost | Review of counterparty databases, updating screening systems and possible specialized legal advice. |
The cost of non-compliance far exceeds the cost of compliance. Sanctions for non-compliance in Spain may include significant fines and, in serious cases, criminal liability for directors. The regulation does not establish a grace period: the obligation is immediate from June 15, 2026.
Who does it affect?
- Spanish companies with contracts or commercial relationships with Russia or with Russian-owned companies.
- Financial entities (banks, savings banks, credit cooperatives, fund managers) with clients, accounts or assets linked to Russian persons or entities.
- Companies in any sector that have Russian suppliers, distributors or partners in their supply chain.
- Advisors and consultants providing services to potentially sanctioned Russian companies or individuals.
- Logistics and transport companies operating routes or services with origin or destination in Russia.
- Law firms and management companies managing assets or interests of Russian natural or legal persons.
The regulation applies to any natural or legal person established in the EU, regardless of size or sector. An SME with a single Russian supplier has the same verification obligations as a large bank.
Practical example
A Spanish industrial company has a component supply contract with a Russian company it has been working with for three years. On June 15, 2026, Regulation 2026/1356 enters into force, adding that Russian company to the list of sanctioned parties.
From that moment, the Spanish company cannot execute any pending payment or receive new deliveries if this means making funds available to the sanctioned party. It must:
- Immediately halt any pending transfer to that company.
- Notify its financial institution to block scheduled payments.
- Consult with a legal advisor specialized in international sanctions on how to manage the contract and assets already delivered.
- Document all actions taken to demonstrate due diligence in the event of an inspection.
If the Spanish company makes the payment without having verified the updated list, it incurs non-compliance with the Regulation, regardless of whether it acted in good faith. The obligation to verify is proactive, not reactive.
What should companies do now?
- Verify the updated list of sanctioned parties: Consult the consolidated EU sanctions list on the EEAS sanctions portal to check if any counterparty appears on it.
- Review active contracts and commercial relationships: Identify all contracts, orders and transactions in progress with Russian or Russian-owned counterparties.
- Halt pending payments and transfers to any entity that may be on the list until its status is confirmed.
- Update counterparty screening systems: Financial entities and companies with high transaction volumes must ensure their compliance tools incorporate the updated list.
- Document due diligence: Record all verifications performed, with date and result, to demonstrate compliance in the event of an inspection or claim.
- Consult specialized legal advice if there is any doubt about whether a counterparty is affected or how to manage ongoing contracts with sanctioned parties.
Non-compliance may result in administrative and criminal sanctions under Spanish law. The regulation is directly applicable from June 15, 2026 and there is no adaptation period.
Frequently asked questions
Where can I consult the updated list of EU-sanctioned parties linked to Russia?
The consolidated list of natural and legal persons subject to EU restrictive measures is available on the official sanctions portal of the European External Action Service (EEAS). Regulation 2026/1356 updates this list by adding new natural and legal persons linked to destabilizing activities of Russia. You must consult the most recent version before conducting any transaction with Russian counterparties.
What happens if my company makes a payment to a sanctioned entity without knowing it?
The obligation to verify is proactive: the company has a duty to check the list before executing any transaction. Lack of knowledge does not exempt you from responsibility. Non-compliance may result in administrative and criminal sanctions under Spanish law, regardless of the payer's good faith.
When is it mandatory to comply with Regulation 2026/1356?
As of June 15, 2026, the date of publication and entry into force. There is no grace period or adaptation period. As an EU implementing regulation, it is directly applicable in Spain without the need for national transposition.
Does this regulation affect only large companies or also SMEs?
It affects any natural or legal person established in the EU, regardless of size. An SME with a single Russian supplier or client has the same verification obligations as a large financial entity. The criterion is the existence of commercial or financial links with Russia or with sanctioned persons, not the size of the company.
What is the difference between this regulation and sanctions for the war in Ukraine?
Regulation 2026/1356 applies the framework of Regulation (EU) 2024/2642, specifically designed to respond to destabilization activities attributed to Russia (such as interference, sabotage, disinformation). It is a distinct, though complementary, regime to sanctions for the war in Ukraine. Both coexist and a company may be required to comply with both simultaneously.
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:32026R1356