Key data
| Regulation | Council Decision (CFSP) 2026/1351, of 15 June 2026 — amends Council Decision (CFSP) 2024/2643 |
|---|---|
| Publication | 15 June 2026 |
| Entry into force | 15 June 2026 (immediate effect) |
| Affected parties | Companies and individuals with commercial, financial or contractual relationships with Russia or sanctioned Russian entities |
| Category | European Regulation — Common Foreign and Security Policy (CFSP) |
| Amended regulation | Council Decision (CFSP) 2024/2643 |
| CELEX reference | 32026D1351 |
If your company exports to Russia, operates with Russian banks or partners, or works with dual-use goods, this regulatory update affects you from today. The Council Decision (CFSP) 2026/1351, published on 15 June 2026, amends Council Decision (CFSP) 2024/2643 and updates EU restrictive measures against destabilizing activities attributed to Russia. There is no adaptation period: the regulation entered into force on the same day as its publication.
What does this regulation establish?
This Council Decision amends the base regulation — Council Decision (CFSP) 2024/2643 — which governs EU restrictive measures against destabilizing activities attributed to Russia. The changes that this amendment may introduce are as follows:
- Addition of new natural or legal persons to the sanctions lists.
- Removal of natural or legal persons from the sanctions lists.
- Adjustments to the scope of prohibitions applicable to already listed entities.
The restrictive measures derived from these lists generally include: the freezing of assets of designated persons and entities, and the prohibition of making funds or economic resources available to them. European companies cannot operate, contract or conduct financial transactions with any entity or individual included in the current lists.
To find the exact and updated list of sanctioned persons and entities, the official source is the EU Sanctions Map, which is updated in real time with each amendment published in the EU Official Journal.
Economic and operational impact
The impact is not theoretical. Operating with a sanctioned entity — even unintentionally — can result in serious consequences for your company:
- Administrative sanctions imposed by the competent authorities of the Member State (in Spain, the State Secretariat for Trade and the Bank of Spain, depending on the type of operation).
- Criminal liability for company administrators and executives.
- Blocking of ongoing operations and contracts with counterparties that appear on updated lists.
- Reputational damage to clients, investors and financial entities.
Operational risk is particularly high in three areas: international payments and transfers through correspondent banks, supply or distribution contracts with Russian partners, and exports of dual-use goods (technology, industrial components, electronics) that may be subject to additional prohibitions.
Who does it affect?
- Financial sector entities: banks, insurance companies, fund managers and any intermediary that processes payments or investments with Russian counterparties.
- Exporters of dual-use goods: companies that sell technology, electronic components, machinery or other products with civil and military applications to Russian destinations.
- Companies with existing contracts with the Russian market: distributors, service providers, consultancies or any company with active commercial agreements with partners in Russia.
- Companies with indirect links: companies that operate with subsidiaries, intermediaries or subcontractors that in turn have relationships with sanctioned Russian entities.
- Advisors and consultants who provide services to companies with exposure to the Russian market.
Practical example
A Spanish industrial components company maintains a supply contract with a Russian company with which it has been operating for three years. Until now, that company did not appear on any sanctions list. With the update of 15 June 2026, that same company could have been added to the list of designated entities under Decision (CFSP) 2026/1351.
If the Spanish company does not review the updated lists and makes a shipment or collects a pending invoice after 15 June, it would be in breach of restrictive measures from the moment the entity was designated — regardless of whether the contract was legal previously. This can result in the opening of an administrative sanctions file and, depending on the amount and intent, criminal liability for its administrators.
The only way to avoid this is to verify the status of each counterparty on the EU Sanctions Map before executing any operation.
What should companies do now?
- Review the updated lists immediately: Access the EU Sanctions Map and the official text of Decision 2026/1351 to identify if any of your counterparties have been added or modified.
- Audit all commercial and financial relationships with Russia: Include customers, suppliers, partners, distributors and any intermediary with Russian links. Do not limit yourself to direct relationships.
- Preventively suspend any ongoing operations with counterparties whose status you have not yet been able to verify, until you confirm they are not on the lists.
- Implement or update the sanctions screening process: If you do not have a procedure for periodic verification of counterparties against sanctions lists, now is the time to implement it. List updates can occur at any time.
- Consult with specialized legal advisors if you have existing contracts with Russian entities or if you export dual-use goods, to assess the specific risk of your situation and possible licensing or exemption routes.
- Document all verifications performed: In case of inspection, documented due diligence is the main defense argument against administrative sanctions.
Frequently asked questions
Where can I consult the updated list of entities and persons sanctioned by the EU in relation to Russia?
The official and real-time updated list is available on the EU Sanctions Map. Each time a Decision such as 2026/1351 is published, added or removed entities are automatically reflected. You can also consult the full text of the Decision on EUR-Lex.
What happens if my company operated with a Russian entity before it was sanctioned?
Operations carried out before the date an entity is designated on the lists are not retroactively illegal. The breach occurs from the moment the entity is designated. However, any operation executed after 15 June 2026 with an entity listed in the updated list does constitute an infraction, regardless of whether the contract was prior.
When does this sanctions update come into force and is there an adaptation period?
Council Decision (CFSP) 2026/1351 entered into force on the same day as its publication: 15 June 2026. There is no adaptation period. Obligations are enforceable from that date.
What sanctions can a Spanish company receive for breaching these restrictive measures?
Breach can result in administrative and criminal sanctions in Spain, as established in national transposition regulations. The severity depends on the amount of the operation, intent and whether there is recidivism. Company administrators may incur direct criminal liability.
Does this regulation only affect exports or also services and financial payments?
It affects any type of economic relationship: exports of goods (especially dual-use goods), provision of services, financial transfers, investments and any making available of funds or economic resources in favor of persons or entities designated on the lists.
Official source
Consult complete 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:32026D1351