Key data
| Regulation | Council Decision (CFSP) 2026/1333, of 15 June 2026 |
|---|---|
| Modified regulation | Decision 2014/145/CFSP on restrictive measures concerning actions undermining the sovereignty of Ukraine |
| Publication | 15 June 2026 |
| Entry into force | 15 June 2026 (immediate application) |
| Affected parties | Companies and persons with commercial or financial links to sanctioned Russian entities |
| Category | European Regulation — International sanctions |
| Year | 2026 |
As of 15 June 2026, operating with certain persons or entities linked to the destabilization of Ukraine is illegal throughout the EU. The Council Decision (CFSP) 2026/1333 amends Decision 2014/145/CFSP and updates the lists of sanctioned subjects. The regulation applies immediately: there is no adaptation period.
For any company with commercial, financial or investment relationships involving Russian counterparties or those linked to the conflict, the obligation to verify is urgent. Lack of knowledge does not exempt from responsibility.
What does this regulation establish?
Decision 2014/145/CFSP is the EU's sanctioning framework in force since 2014 against persons and entities that threaten the territorial integrity, sovereignty and independence of Ukraine. Decision 2026/1333 is an update to that framework which, following the usual pattern of such amendments, adds new persons or entities to the lists or modifies existing ones.
The restrictive measures that apply to subjects included in the list are two:
- Travel ban to the EU: sanctioned subjects cannot enter or transit through the territory of any Member State.
- Freezing of assets: all funds and economic resources belonging to sanctioned subjects located in the EU are blocked. No company or person can make funds available to them.
The regulation is directly applicable in Spain from its publication in the Official Journal of the European Union, without the need for national transposition.
Economic and operational impact
The impact is not abstract. For a Spanish company, operating with a sanctioned subject—even indirectly or through a subsidiary—may result in:
- Criminal sanctions for administrators and executives responsible for the commercial decision.
- Administrative sanctions for the company, which in Spain are processed through the State Secretariat for Trade and may include substantial fines.
- Blocking of operations and funds if the company has assets linked to sanctioned subjects.
- Reputational damage and possible exclusion from public procurement.
The operational cost of compliance is low compared to the risk of non-compliance: it is fundamentally a matter of reviewing updated lists and cross-checking the database of customers, suppliers and partners.
Who does it affect?
- Exporting or importing companies with counterparties in Russia or territories under Russian control.
- Financial entities and banks with exposure to Russian customers or assets.
- Advisors, lawyers and consultants providing services to potentially sanctioned persons or entities.
- Logistics and transport companies operating routes with involvement in the conflict.
- Investors and funds with shareholdings in Russian companies or linked entities.
- Any company that receives payments or makes transfers to or from entities on the list.
- CFOs and financial directors responsible for compliance risk management.
Practical example
A Spanish industrial machinery company has a distributor in Moscow with whom it has been operating since 2019. Following the publication of Decision 2026/1333 on 15 June 2026, that distributor—or its parent company—appears on the updated list of sanctioned subjects.
From that same day, any payment, shipment of goods or provision of services to that distributor constitutes a breach of the EU sanctions regime. The Spanish company cannot claim ignorance: the obligation to consult updated lists falls on it. The compliance officer (or the CFO, in the absence of one) must have activated verification before executing any pending operations.
If the company has outstanding invoices from that distributor, those funds are also potentially affected by the asset freeze and must be reported to the competent authorities.
What should companies do now?
- Consult the updated list of sanctioned subjects on the EU Sanctions Map and in the official text of Decision 2026/1333 to identify whether any counterparty has been added.
- Cross-check the list with the database of customers, suppliers and partners—including ultimate beneficial owners (UBO) of complex corporate structures, not just the direct entity.
- Preventively suspend any pending operations with counterparties that may be affected until their status is confirmed.
- Notify the competent authorities if assets or funds linked to sanctioned subjects are detected. In Spain, the competent authority for financial sanctions is SEPBLAC and the State Secretariat for Trade.
- Document the verification process with date and result, to demonstrate due diligence in case of subsequent inspection or investigation.
- Review existing contracts with sanctions compliance clauses and activate termination mechanisms if appropriate.
Frequently asked questions
Where can I consult the updated list of persons and entities sanctioned by the EU?
The consolidated list of sanctioned subjects is available on the EU Sanctions Map and in the EU Official Journal. Decision 2026/1333 amends Decision 2014/145/CFSP, so you should consult the updated text of the latter to see the complete current list.
When does Decision 2026/1333 enter into force and is there an adaptation period?
Decision (CFSP) 2026/1333 entered into force on the same day of its publication: 15 June 2026. There is no adaptation period. The obligations not to operate with sanctioned subjects are enforceable from that date.
What sanctions can a Spanish company receive for operating with a subject on the list?
Non-compliance with the EU sanctions regime may result in criminal sanctions for administrators and executives responsible, as well as administrative sanctions for the company. In Spain, foreign trade control regulations and capital laundering prevention establish substantial fines. Lack of knowledge of the list does not exempt from responsibility.
Does this regulation only affect companies with direct operations in Russia?
No. Sanctions apply to any company or person that maintains commercial or financial relationships with sanctioned subjects, regardless of where they are located. This includes indirect operations through subsidiaries, intermediaries or corporate structures in third countries.
What should I do if I have funds or assets linked to a sanctioned subject?
If you detect assets or funds linked to persons or entities included on the list, you are obliged to freeze them and report it to the competent authorities. In Spain, you must report it to SEPBLAC and the State Secretariat for Trade. You cannot dispose of those funds or make them available to the sanctioned subject.
Official source
Consult complete regulation at 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:32026D1333