Key data
| Regulation | Commission Implementing Regulation (EU) 2026/1817 of 23 July 2026 |
|---|---|
| Legal basis | Article 8a, paragraph 1, of Regulation (EC) No 765/2006 |
| Publication | 23 July 2026 |
| Entry into force | 23 July 2026 (immediate effect) |
| Affected parties | Companies and individuals with commercial or financial links to Belarus or Russia |
| Category | European Regulation — Restrictive measures |
| Year | 2026 |
| OJEU Reference | OJ:L_202601817 |
If your company exports to Belarus, operates with financial entities linked to that country, or maintains any commercial relationship with Russian or Belarusian counterparties, this regulatory update affects you directly. Commission Implementing Regulation (EU) 2026/1817, published and in force on 23 July 2026, expands the list of individuals and entities subject to restrictive measures under the Regulation (EC) No 765/2006, which has regulated sanctions against Belarus since the 2006 political crisis and has been progressively tightened since the Russian invasion of Ukraine.
There is no transition period: compliance obligations are enforceable from the same day of publication.
What does this regulation establish?
Commission Implementing Regulation (EU) 2026/1817 applies Article 8a, paragraph 1, of Regulation (EC) No 765/2006, which allows the EU Council to add individuals and entities to the list of sanctioned subjects through implementing regulations with immediate application.
The restrictive measures applied to the new subjects included in the list are as follows:
- Asset freeze: all funds and economic resources belonging to or under the control of listed individuals and entities are blocked. No EU company or individual can make funds available to them.
- Entry ban: individuals included in the list cannot enter or transit through the territory of any EU Member State.
The reason justifying these new inclusions is Belarus's participation in the Russian aggression against Ukraine, in line with the progressive sanctions policy that the EU has been applying since 2022. This update adds to successive expansions of the sanctions regime that have incorporated new political, military, business and financial officials linked to the Lukashenko regime.
| Measure | Description | Recipients |
|---|---|---|
| Asset freeze | Blocking of funds and economic resources. Prohibition of making funds available to sanctioned parties. | Listed natural and legal persons |
| Entry and transit ban | Veto on access to the territory of any EU Member State. | Listed natural persons |
Economic and operational impact
The direct impact for companies is not a fee or fixed cost: it is the risk of non-compliance. Operating with an entity or individual included in the sanctions list—even unintentionally—can result in:
- Administrative sanctions imposed by the competent authorities of the Member State (in Spain, the State Secretariat for Trade and the Bank of Spain, depending on the type of operation).
- Criminal sanctions for company officials, depending on applicable national legislation.
- Blocking of ongoing operations: payments, transfers, supply contracts or exports that are halted because they affect a sanctioned subject.
- Reputational damage and possible regulatory investigations, particularly relevant for financial entities subject to supervision.
The immediate operational cost falls on compliance, legal and finance departments, which must update their sanctions list verification processes (screening) to incorporate the new subjects included by this regulation.
Who does it affect?
- Financial entities: banks, insurance companies, fund managers and any entity that processes payments or maintains accounts with Belarusian or Russian counterparties. This is the group with the greatest obligation for continuous screening.
- Exporters and importers: companies that trade with Belarus or that have suppliers or customers linked to the country in their supply chain.
- Companies with subsidiaries or holdings in Belarus or Russia: any corporate structure that involves transfer of funds or economic resources to entities in those territories.
- Advisors and consultancies: law firms, business consultancies and tax advisors providing services to clients with exposure to Belarus or Russia must update their due diligence protocols.
- Logistics and transport companies: operators managing goods originating from or destined for Belarus may be affected if any counterparty appears in the updated list.
Practical example
A Spanish industrial company maintains a supply contract for components with a Belarusian company. On 23 July 2026, Commission Implementing Regulation (EU) 2026/1817 enters into force, including that Belarusian company—or its majority owner—in the list of sanctioned subjects.
From that moment on, the Spanish company cannot make any payment or transfer economic resources to that counterparty. If it has blocked funds in transit, it must notify the competent authorities. If it continues to operate with that entity without verifying the updated list, it incurs non-compliance with Regulation (EC) No 765/2006, with the administrative and criminal consequences that apply under Spanish legislation on the application of international sanctions.
This scenario is entirely avoidable with an updated screening process that checks commercial counterparties against the EU sanctions list, available on the EU Sanctions Map and in the EEAS consolidated repository.
What should companies do now?
- Update the counterparty screening process: incorporate the new list of sanctioned subjects published in Regulation (EU) 2026/1817 into internal verification systems. The consolidated EU sanctions list is available in the EEAS official repository.
- Review active contracts and commercial relationships with Belarus and Russia: identify whether any counterparty—company, owner, beneficial owner or intermediary—appears among the newly sanctioned subjects.
- Preventively block any pending payment or transfer to Belarusian or Russian counterparties until confirming they are not included in the updated list.
- Notify the competent authorities if you detect that you own or control funds of a sanctioned subject. In Spain, the reference body is the State Secretariat for Trade.
- Update due diligence protocols (KYC/AML) for financial entities, incorporating the new risk criteria associated with Belarus and its links to Russia.
- Document all verifications performed: in case of inspection or investigation, the traceability of the compliance process is the main defense against an accusation of non-compliance.
Frequently asked questions
From when are the new sanctions of Regulation (EU) 2026/1817 mandatory?
The measures apply immediately from 23 July 2026, the date of publication and entry into force of the regulation. There is no transition period: any operation with the newly sanctioned subjects is illegal from that same day.
What happens if my company operates with a Belarusian entity that has just been sanctioned without knowing it?
Lack of knowledge does not exempt from responsibility. Non-compliance with Regulation (EC) No 765/2006 can result in administrative and criminal sanctions in the Member State where the company operates. This is why it is critical to maintain a continuous and updated screening process against the EU consolidated sanctions list.
Where can I consult the updated list of sanctioned individuals and entities?
The consolidated EU sanctions list, which includes all subjects affected by the restrictive measures regime against Belarus (Regulation EC 765/2006 and its updates), is available on the EU Sanctions Map and in the EEAS (European External Action Service) repository.
Which companies have the greatest risk of non-compliance with this update?
The entities with the greatest exposure are: financial entities that process payments or maintain accounts with Belarusian or Russian counterparties, exporters and importers with commercial activity in those markets, and companies with subsidiaries or holdings in Belarus or Russia. Also advisors and consultancies providing services to clients with that exposure.
What specific measures apply to the newly sanctioned subjects?
The newly included subjects are subject to two measures: asset freeze (blocking of all their funds and economic resources, with prohibition of making funds available to them) and entry and transit ban through the territory of any EU Member State, in the case of natural persons.
Official source
View complete regulation in official source — EUR-Lex OJ:L_202601817
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_202601817