EU Sanctions Against Russia: What Changes with the Correction of Regulation 2025/351

Key data

If your company exports, imports, finances or invests with any link to Russia or Belarus, this notice directly affects you. Regulation (EU) 2025/351, which is part of the European sanctions framework against Russia, has been corrected through an official errata published on 13 March 2026 with reference CELEX:32025R0351R(02).

The corrections are technical or editorial in nature and do not modify the substantive content of the regulation. However, the corrected version is the legally binding and enforceable version. Applying the previous version, even unknowingly, can create compliance problems during an inspection or audit.

What does this regulation establish?

This document is a correction of errors (errata) to Regulation (EU) 2025/351, which integrates the framework of European sanctions related to Russia. Errata are formal corrections that the European Commission publishes when it detects typographical, cross-reference or editorial errors in an already published regulation.

In this specific case, the corrections are technical or editorial in nature and do not modify the substantive regulatory content of the original regulation. That is, the obligations, prohibitions and restrictions established by Regulation (EU) 2025/351 remain exactly the same. What changes is the formal wording of certain sections to correctly reflect the original legislative intent.

What does change in practical terms is that the corrected version published on 13 March 2026 becomes the only officially valid version. Any internal reference, compliance procedure or documentation in your company must be based on this updated version.

Economic and operational impact

The direct impact of this correction is operational, not economic in itself. It does not introduce new obligations or modify amounts or restrictions. However, the indirect impact can be significant if not managed correctly:

• Risk of regulatory non-compliance: Applying an outdated version of the regulation may be considered non-compliance during a compliance audit or regulatory inspection.
• Administrative and criminal sanctions: Non-compliance with the restrictive measures of the sanctions framework against Russia can result in administrative and criminal sanctions, as established by the European regulatory framework on restrictive measures related to Russia. The correction published does not modify this sanctions regime.
• Cost of internal review: Companies with formalized compliance procedures will need to update their internal regulatory references, which involves an operational cost of document review.
• Financial entities especially exposed: Banks, fund managers and entities with operations linked to Russia or Belarus have stricter compliance obligations and must update their control systems with the corrected version of the regulation.

Who does it affect?

This correction is especially relevant for the following profiles:

• Exporting companies that sell or have sold products to Russia or Belarus, or that manage transit operations related to these countries.
• Importing companies with supply chains that include Russian or Belarusian suppliers.
• Financial entities (banks, insurance companies, fund managers) with exposure to assets, customers or counterparties from Russia or Belarus.
• Investment operators with shareholdings, joint ventures or projects linked to the Russian market.
• Compliance and legal departments of any company with commercial links to Russia or Belarus, which must keep their regulatory references updated.
• Advisors and consultants providing services to companies with operations in those markets.

Practical example

A Spanish industrial company that exports machinery and has an internal sanctions compliance procedure based on Regulation (EU) 2025/351 should act as follows:

Its legal department has referenced the original version of the regulation in its customer due diligence procedures and export controls. Following the publication of the correction on 13 March 2026, that version is no longer officially valid.

If the company is subject to a sanctions compliance inspection or audit, and its internal procedures reference the previous version without having incorporated the correction, it may face observations of formal non-compliance. Although the substantive obligations have not changed, the documentary basis of its compliance must always reflect the current version.

The concrete action: update the regulatory reference in internal procedures, replace the regulation document in the compliance repository and communicate it to the team responsible for operations with Russia or Belarus.

What should companies do now?

1. Download the corrected version of Regulation (EU) 2025/351 from EUR-Lex (reference CELEX:32025R0351R(02)) and replace any previous version in internal compliance repositories.
2. Review internal sanctions compliance procedures to ensure they reference the corrected version and not the original.
3. Communicate the change to the compliance, legal and operations team that manages commercial, financial or investment relationships with Russia or Belarus.
4. Verify that export and import controls applied to operations with Russian or Belarusian nexus are based on the current version of the regulation.
5. Consult with a legal advisor specializing in international sanctions if there are doubts about the correct application of the corrected regulation, especially in financial entities with greater regulatory exposure.