EU Sanctions Against Belarus 2026: What Companies with Commercial Links Must Review

Key data

If your company imports, exports, finances, or maintains any contractual relationship with entities or individuals in Belarus, this regulation affects you as of now. The Regulation (EU) 2026/1846, published on July 23, 2026, amends Regulation (EC) 765/2006 and expands the regime of restrictive measures against Belarus for its participation in Russian aggression against Ukraine. The regulation is directly applicable in Spain and the rest of the Member States without the need for any additional national law.

What does this regulation establish?

Regulation (EC) 765/2006 is the European framework for sanctions against Belarus, in force for years and subject to successive updates as the political and military situation evolves. The new Regulation 2026/1846 amends it to expand or update existing restrictive measures.

The measures contemplated by the sanctions framework include three major blocks:

The key for companies is that trade restrictions do not apply to Belarus in general, but to the specific individuals and entities listed as designated. Operating with a counterparty that has been added to those lists—even if the commercial relationship existed before—constitutes a sanctionable breach.

Economic and operational impact

The impact for companies is not only reputational: non-compliance with sanctions entails serious administrative sanctions, the specific amount of which depends on the legislation of each Member State, but in Spain can be very significant depending on the volume of the irregular operation.

From an operational standpoint, companies must assume the following costs and burdens:

• Review of counterparty portfolio: audit of customers, suppliers, partners, and financiers with presence or links to Belarus.
• Update of compliance processes: incorporate screening against EU designated lists on a periodic and automated basis.
• Preventive asset freezing: if a sanctioned counterparty is detected, the company is obligated to block the assets immediately and notify the competent authorities.
• Review of existing contracts: contracts with Belarusian entities must be analyzed to identify whether any of the parties has been designated after the regulation enters into force.
• Risk of supply chain liability: operating with an intermediary that in turn works with sanctioned entities may generate indirect liability.

Who does it affect?

• Exporting or importing companies with commercial activity in Belarus or with Belarusian companies.
• Financial entities and banks that manage transfers, credits, or investments linked to Belarus.
• Logistics and transport companies with routes involving transit through Belarus or with Belarusian clients.
• Advisors, consulting firms, and law firms providing services to Belarusian companies or individuals.
• Companies with subsidiaries, joint ventures, or shareholdings in Belarusian companies.
• Any company that has supply, distribution, or representation contracts with counterparties in Belarus.
• CFOs and financial directors responsible for regulatory compliance in international operations.

Practical example

A Spanish industrial machinery company maintains a supply contract with a Belarusian company that until now has not appeared on any sanctions list. Following the entry into force of Regulation 2026/1846 on July 23, 2026, that Belarusian company is added to the designated list due to its links with the Lukashenko regime.

From that moment on, the Spanish company has the obligation to:

1. Immediately suspend any pending delivery, collection, or payment with that counterparty.
2. Freeze any funds it may hold related to that company.
3. Notify the situation to the competent Spanish authority (the State Secretariat for Trade, in coordination with the Treasury).
4. Not execute any contractual clause that implies transfer of value to the sanctioned entity.

If the Spanish company continued operating with that counterparty ignoring the designation, it would be incurring a serious breach of the EU sanctions regime, with the consequent risk of administrative fines and reputational damage.

What should companies do now?

1. Audit the portfolio of Belarusian counterparties: identify all customers, suppliers, partners, and financiers with presence or links to Belarus and cross-reference them with the official EU designated lists.
2. Consult updated sanctions lists: access the EU Sanctions Map and the European Council database of designated persons and entities to verify the status of each counterparty.
3. Review existing contracts: analyze whether any active contract involves operations with entities that may have been designated after July 23, 2026.
4. Update internal compliance procedures: incorporate periodic and automated screening against sanctions lists in the processes for registering new customers and suppliers.
5. Train the purchasing, sales, and finance teams: ensure that people managing relationships with international counterparties understand the obligations arising from the sanctions regime.
6. Consult specialized legal advice: in case of any doubt about whether a counterparty is or may be linked to sanctioned entities, act with caution and obtain legal guidance before continuing to operate.

Official source

Consult complete regulation on 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=OJ:L_202601846