EU Sanctions Against Ukraine 2026: What Companies and Financial Entities Must Do

Key data

If your company operates with international counterparties or your entity manages client assets with links to Russia or the conflict in Ukraine, this update affects you today. The Decision (CFSP) 2026/1364, published on 15 June 2026, amends Decision 2014/145/CFSP and expands the list of persons and entities subject to the most severe restrictive measures that the European Union can apply: asset freezing and prohibition of entry into the EU.

This is not a regulation with deferred compliance. The text is clear: immediate effect from its publication in the EU Official Journal. Any business or financial relationship maintained with the newly designated parties from that date onwards constitutes an infraction.

What does this regulation establish?

Decision 2014/145/CFSP is the European sanctions framework applicable to those who threaten or undermine the territorial integrity, sovereignty and independence of Ukraine. It has been in force since 2014 and is updated periodically through amending decisions of the Council.

The Decision (CFSP) 2026/1364 introduces the following specific amendment:

• Update of the designations list: new natural and legal persons are added to the list of subjects subject to restrictive measures.
• Measures applicable to newly designated parties:
  • Freezing of all assets and economic resources that they own, control or hold in the EU.
  • Prohibition of entry or transit through the territory of the EU Member States.
• Obligation for economic operators: no European company or financial entity may make available to the designated parties funds, assets or economic resources, directly or indirectly.

The complete and updated list of designated parties is available in the official source on EUR-Lex and in the EU consolidated sanctions system.

Economic and operational impact

The direct impact for companies is not a fee or fixed cost: it is the risk of criminal and administrative sanctions for operating with counterparties included in the list. In Spain, non-compliance with international sanctions can result in:

• Criminal liability for natural persons (administrators, executives, compliance officers).
• Administrative sanctions for the company, the amount of which depends on the legislation of each Member State.
• Blocking of operations and possible regulatory intervention for supervised financial entities.
• Reputational damage and loss of access to European markets.

The immediate operational cost is the update of screening systems and control lists. Companies that use compliance tools (KYC, AML, sanctions lists) must ensure that their providers have already incorporated the new designations from this decision.

Who does it affect?

• Financial entities: banks, insurance companies, fund managers, payment entities — obliged to block assets and cease relationships with designated parties.
• Export and import companies with activity in markets related to Russia, Belarus or the conflict in Ukraine.
• Companies with partners, shareholders or suppliers that may be linked to sanctioned persons or entities.
• Law firms, consultancies and advisors that provide services to clients with possible links to designated parties.
• Compliance officers and compliance managers in any organization with international exposure.
• Executives and administrators of companies with operations in countries in the conflict area.

Practical example

A Spanish industrial machinery company has a distributor in a third country that, following the update of 15 June 2026, appears on the new list of designated parties under Decision (CFSP) 2026/1364. The company has a pending transfer of €80,000 for an order already placed.

From 15 June, executing that transfer constitutes a breach of EU sanctions, regardless of whether the order was placed earlier. The company must: (1) block the payment immediately, (2) notify its financial entity, (3) consult with a legal advisor specializing in international sanctions, and (4) report the situation to the competent authority in Spain (State Secretariat for Trade / Treasury, depending on the type of asset). Failure to act has criminal consequences for the administrator and sanctions for the company.

What should companies do now?

1. Immediately update screening lists: verify that compliance systems (KYC, AML, sanctions tools) have incorporated the new designations from Decision (CFSP) 2026/1364. If an external provider is used, confirm that they have updated their database.
2. Review the portfolio of current clients, suppliers and partners: cross-reference active counterparties with the updated list of designated parties. Pay special attention to complex corporate structures where a sanctioned party may have indirect participation.
3. Block any pending operations with newly designated parties: payments, transfers, delivery of goods or provision of services must be stopped immediately if the counterparty appears on the updated list.
4. Notify the financial entity: if assets of a designated party are detected, the legal obligation is to communicate it to the bank and to the competent authority of the Member State.
5. Document all actions taken: in case of inspection or investigation, the traceability of measures adopted is the company's and its executives' main defense.
6. Consult with a legal advisor specializing in international sanctions if there is any doubt about the company's exposure or about ongoing operations with counterparties in risk areas.

Official source

Consult complete regulation on official source

Notice: 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:32026D1364