EU Sanctions Against Belarus 2026: What Companies Must Review

Key data

If your company exports, imports, finances or maintains any contractual relationship with entities or individuals in Belarus, this update affects you from today. The Council Decision (CFSP) 2026/512, published on 23 April 2026, modifies the EU sanctions regime against Belarus in force since 2012, adapting it to the current context of Belarusian support for Russian aggression against Ukraine.

This is not a new regulation: it is an update of the existing sanctions framework, which means that compliance obligations are tightened or expanded on an already operational basis. Companies that already had controls in place must verify that they remain valid. Those that did not have them are at immediate risk.

What does this regulation establish?

This Decision modifies Decision 2012/642/CFSP, which is the basic legal instrument of the EU sanctions regime against Belarus. The modifications introduced in this update may include:

• Changes in the lists of sanctioned persons and entities (incorporation of new names or removal of others).
• Adjustments to import and export prohibitions applicable to specific products or sectors.
• Modifications to financial restrictions applicable to transactions with Belarusian entities or individuals.

The sanctions framework against Belarus has been progressively expanded since 2012, and especially since 2022, in response to the Lukashenko regime's support for the Russian invasion of Ukraine. This April 2026 update is a new layer in that cumulative process.

To know exactly which persons or entities have been added to or removed from the lists, it is essential to consult the full text published in the Official Journal of the EU.

Economic and operational impact

The impact is not only legal: it has direct consequences on the daily operations of any company with Belarusian links.

Financial entities have a special obligation: they must update their compliance control systems to incorporate changes in lists and restrictions. An outdated system is not a valid excuse during an inspection.

Who does it affect?

This regulation affects any company or professional with active links to Belarus, regardless of sector:

• Spanish and European exporters who sell products to Belarus or to Belarusian companies.
• Importers who purchase products of Belarusian origin or from companies based there.
• Financial entities (banks, insurance companies, asset managers) that operate with Belarusian counterparties or finance operations related to that country.
• Logistics and transport companies that manage goods with origin or destination in Belarus.
• Advisors, consultants and law firms that provide services to clients with operations in Belarus.
• Executives and CFOs responsible for regulatory compliance in companies with any of the above links.

Practical example

A Spanish industrial company that exports machinery and maintains a supply contract with a Belarusian company must act as follows after the publication of this Decision:

1. Access the full text of Decision (CFSP) 2026/512 in the Official Journal of the EU and verify whether the Belarusian counterparty company appears in the updated lists of sanctioned entities.
2. If the counterparty appears on the list, the contract must be suspended immediately and no new orders or payments can be made.
3. If the counterparty does not appear on the list, verify whether the exported products are affected by new export prohibitions introduced in this update.
4. Document the verification process to demonstrate due diligence in case of subsequent inspection.

This same process applies to any importing company that works with Belarusian suppliers: verification against the updated list is the first mandatory step as of 23 April 2026.

What should companies do now?

1. Consult the full text of Decision (CFSP) 2026/512 in the Official Journal of the EU to identify exactly which persons, entities, products or financial restrictions have been modified.
2. Review all active Belarusian counterparties (customers, suppliers, partners) against the updated lists of sanctioned persons and entities.
3. Verify existing contracts with entities or individuals in Belarus and suspend any operations with counterparties that appear on the lists.
4. Update compliance control systems, especially in financial entities, to incorporate new restrictions as of 23 April 2026.
5. Document the review process to demonstrate due diligence in the face of possible inspections or requests from competent authorities.
6. Consult with specialized legal advice if there are doubts about whether a specific operation is affected, given that non-compliance may result in criminal and administrative sanctions.