Key data
| Regulation | Commission Implementing Regulation (EU) 2026/1361 of the Council, of 15 June 2026 |
|---|---|
| Legal basis | Regulation (EU) No 269/2014 |
| Publication | 15 June 2026 |
| Entry into force | 15 June 2026 (immediate effect) |
| Affected parties | European companies and financial entities with links to sanctioned persons or entities |
| Category | European Regulation — Restrictive measures |
| Year | 2026 |
If your company operates with Russian, Belarusian or any other counterparties linked to the conflict in Ukraine, this regulation affects you directly from today. Commission Implementing Regulation (EU) 2026/1361, published and in force on 15 June 2026, updates the annex to Regulation (EU) No 269/2014 by adding or modifying entries in the EU's consolidated list of sanctioned parties.
There is no adaptation period: the regulation applies immediately. Any ongoing transaction with a newly designated party must be interrupted from the date of publication.
What does this regulation establish?
Commission Implementing Regulation (EU) 2026/1361 amends Annex I to Regulation (EU) No 269/2014, which is the EU's sanctioning framework to protect the territorial integrity, sovereignty and independence of Ukraine. The update consists of adding new entries and/or modifying existing ones in the list of natural and legal persons subject to restrictive measures.
The specific measures applied to all listed parties are two:
- Asset freezing: all funds and economic resources that the designated parties own, control or have in the territory of the EU are blocked immediately.
- Prohibition of travel to the EU: natural persons included in the list cannot enter or transit through the territory of the Member States.
The consolidated list of sanctioned parties is public and is updated in the EU Sanctions Map and in the official EEAS repository. Every company is obliged to consult this list before initiating or maintaining any commercial or financial relationship.
Economic and operational impact
The impact is not only legal: it is operational and financial. These are the direct consequences for companies:
- Immediate blocking of collections and payments: if you have accounts receivable or active contracts with a newly designated party, those cash flows are frozen. You cannot receive or transfer funds.
- Urgent review of customer and supplier portfolio: any company with counterparties in the affected jurisdictions must check its database against the updated list.
- Compliance costs: updating screening systems, reviewing contracts and consulting with legal advisors has a direct cost that varies depending on the size and exposure of the company.
- Risk of sanctions for non-compliance: the regulation refers to the legislation of each Member State. In Spain, non-compliance with EU restrictive measures may result in serious administrative penalties and even criminal liability for company directors.
Financial entities have especially high exposure: they must update their transaction screening engines and their lists of "risk persons" (PEP/sanctioned) immediately, as any operation processed after 15 June with a newly designated party constitutes a breach.
Who does it affect?
- Financial entities (banks, insurance companies, fund managers, payment platforms): required to update their screening systems and block any operation with the newly designated parties.
- Export and import companies with counterparties in Russia, Belarus or territories linked to the conflict.
- Companies in any sector that maintain supply, distribution, consulting or service contracts with persons or entities included in the list.
- Advisors, lawyers and consultants providing services to sanctioned persons or entities: may incur liability if they do not verify the status of their clients.
- Compliance and CFO departments responsible for ensuring that the company does not operate with sanctioned parties.
- Companies with subsidiaries or partners in third countries that may act as intermediaries with the designated parties.
Practical example
Imagine a Spanish industrial machinery company that has an active supply contract with a Russian company. On 15 June 2026, that Russian company appears in the updated list of Regulation (EU) 2026/1361.
From that same day, the Spanish company has the following specific obligations:
- Cease any transaction with that counterparty: you cannot send goods, issue invoices or receive payments.
- Block the assets of the Russian company that you may have in your possession (for example, a security deposit or an advance payment received).
- Notify the competent authorities in Spain (the State Secretariat for Trade acts as the national authority on economic sanctions) about the frozen assets.
- Document the entire process to prove compliance in case of inspection.
If the Spanish company continues to operate with that counterparty without taking these measures, it exposes itself to serious administrative penalties and, potentially, to criminal liability of its directors under Spanish legislation.
What should companies do now?
- Review the EU consolidated list of sanctioned parties today: access the EU Sanctions Map and check your current clients, suppliers and partners against the new entries in Regulation 2026/1361.
- Suspend any transaction immediately with the newly designated parties: payments, collections, delivery of goods or provision of services must cease without delay.
- Block and document the assets of sanctioned parties that are under your control: funds, guarantees, deposits or any economic resource must be frozen and recorded.
- Notify the competent authority: in Spain, report the frozen assets to the State Secretariat for Trade. Each Member State has its own procedure.
- Update screening systems: if you use automated counterparty verification tools (AML, KYC), ensure they incorporate the updated list as of 15 June 2026.
- Review ongoing contracts: identify force majeure or termination clauses that may be activated and consult with your legal advisor on the management of affected contracts.
- Train the compliance team: ensure that those responsible for Compliance, Finance and Operations understand the scope of the update and the internal procedures to follow.
Frequently asked questions
What happens if my company already had a contract signed with a sanctioned party before 15 June 2026?
Entry into force is immediate: from 15 June 2026, any transaction with the newly designated parties is prohibited, regardless of when the contract was signed. You must suspend contract execution and consult with a lawyer specializing in sanctions to manage the termination and any blocked assets.
Where can I consult the updated list of sanctioned parties by the EU following Regulation 2026/1361?
The consolidated list is available in the EU Sanctions Map (sanctionsmap.eu) and in the European External Action Service repository. It is updated with each new implementing regulation, so you should verify it periodically and, in any case, after each publication in the EU Official Journal.
What sanctions can a Spanish company receive for non-compliance with these restrictive measures?
Regulation (EU) 2026/1361 refers to the legislation of each Member State to determine the specific sanctions. In Spain, non-compliance with EU restrictive measures may result in serious administrative penalties and, in the most serious cases, criminal liability for company directors. The severity depends on the volume of operations carried out and whether the non-compliance was intentional or negligent.
Do financial entities have additional obligations compared to other companies?
Yes. Banks, insurance companies, fund managers and payment platforms must immediately update their transaction screening systems and their internal lists of risk persons (PEP and sanctioned). Any operation processed after 15 June 2026 with a newly designated party constitutes a breach, regardless of whether the alert system detected it or not.
What should I do if I detect assets of a sanctioned party in my company's possession?
You must block those assets immediately and prevent any disposal of them. You must then notify the competent authority in Spain, which is the State Secretariat for Trade. It is mandatory to document the entire process to prove regulatory compliance in case of inspection or subsequent request.
Official source
Consult the 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:32026R1361