EU Sanctions on Russia Corrected: What Companies with Russian Activity Must Review

Key data

If your company operates with Russia—whether exporting, importing, financing operations or managing logistics—the text you must comply with has just formally changed. The correction published on 29 April 2026 rectifies material or formal errors detected in Regulation (EU) 2024/1745, which in turn amended Regulation (EU) 833/2014, the central framework for the EU's restrictive sanctions measures against Russia for the destabilization of Ukraine.

This type of correction in sanctions regulations is common to ensure legal precision of the text. However, it has direct practical consequences: the prohibitions and restrictions in force must be interpreted and complied with in accordance with the corrected text, not the original.

What does this regulation establish?

The correction published under reference OJ:L_202690332 rectifies material or formal errors detected in Council Regulation (EU) 2024/1745 of 24 June 2024. That regulation amended Regulation 833/2014, which is the EU's principal legal instrument for imposing restrictive measures against Russia in the context of the war in Ukraine.

The key points you need to understand about this correction:

• It does not alter the substantive content of sanctions: the prohibitions and restrictions in force do not change in their essence.
• It does ensure legal precision of the text: the formal or material errors corrected may affect how certain provisions are interpreted and applied.
• The corrected text is the valid text: for regulatory compliance purposes, companies must use the corrected version, not the original published in June 2024.
• Corrections in sanctions regulations are common: the technical and legal complexity of these texts means that errors or inaccuracies are corrected through specific publications in the EU Official Journal.

The Regulation 833/2014 has been amended multiple times since its adoption, accumulating successive sanctions packages. Regulation 2024/1745 was the last major package of amendments before this correction.

Economic and operational impact

Although a formal correction may seem like a minor procedural matter, it has real operational implications for affected companies:

• Risk of unintentional non-compliance: if your company applies compliance procedures based on the original text of Regulation 2024/1745, it may be operating on an outdated legal basis.
• Review of contracts and ongoing operations: any operation with Russian counterparties or those linked to Russia must be verified against the corrected text.
• Consequences of non-compliance: failure to comply with sanctions can result in serious administrative and criminal sanctions. The regulation does not specify concrete amounts in this correction, but the sanctioning framework of Member States may include substantial fines, disqualifications and criminal liability.
• Cost of internal review: companies with active compliance programs will need to update their risk matrices and verification procedures with the corrected text.

Who does it affect?

This correction affects all companies and natural or legal persons with relations linked to Russia in any of these dimensions:

• Exporting companies that sell or have sold goods or technology destined for Russia or to intermediaries that may re-export to Russia.
• Importing companies that acquire products of Russian origin or with Russian links.
• Financial entities that manage transactions, financing or financial instruments related to Russian counterparties or assets in Russia.
• Logistics and transport operators that manage supply chains with origin, destination or transit through Russia.
• Legal advisors and consultants that provide services to companies with activity linked to Russia.
• CFOs and financial directors of business groups with subsidiaries, shareholdings or financial exposure to Russia.

Practical example

A Spanish industrial machinery company has a compliance procedure that reviews its exports against the text of Regulation 2024/1745 published in June 2024. Following the publication of this correction on 29 April 2026, the legally valid text is the corrected one, not the original.

If the correction affects, for example, the wording of an exception or the description of a good or entity subject to restriction, the company could be incorrectly interpreting whether an operation is permitted or prohibited. Without having updated its reference basis to the corrected text, any operation approved internally could be based on a misreading of the regulation.

The immediate step for this company is to download the corrected text from EUR-Lex, identify which sections have been corrected and update its compliance procedures and risk matrices accordingly.

What should companies do now?

1. Download the corrected text: access reference OJ:L_202690332 on EUR-Lex and download the official corrected version of Regulation 2024/1745 to have the updated legal basis.
2. Identify the corrected sections: compare the corrected text with the original published on 24 June 2024 to locate exactly which provisions have been modified.
3. Update compliance procedures: if your company has a regulatory compliance program on sanctions, update risk matrices, checklists and internal procedures with the corrected text.
4. Review ongoing operations: verify that active operations with Russian counterparties or those linked to Russia comply with the corrected text, not just the original.
5. Inform the teams involved: communicate the change to the export, finance, legal and logistics departments so they operate with the updated version of the regulation.
6. Consult specialized legal advice: if there are doubts about how the corrections affect specific operations, consult a lawyer specializing in international sanctions law before continuing with those operations.