EU Sanctions Correction Against Russia 2025: What Changes for Companies

Key data

Companies with commercial or financial links to Russia must immediately review their control lists. The corrigendum published on April 15, 2026 corrects formal errors in the Council Decision (CFSP) 2025/963, which in turn amended the restrictive measures regime against Russia established in Decision (CFSP) 2024/2643. Although this is a formal correction, its impact may be material: the corrections may affect lists of sanctioned persons or entities, key definitions of the regime, or applicable procedures.

The entry into force date is retroactive to May 20, 2025, meaning that the corrected obligations apply from that date. Any company that has operated under the previous version of the regulation must verify whether there is any compliance discrepancy.

What does this regulation establish?

This corrigendum corrects formal errors detected in Decision (CFSP) 2025/963, published on May 20, 2025 in the EU Official Journal. This decision amended the restrictive measures regime against Russia for destabilizing activities, whose original framework was established in Decision (CFSP) 2024/2643.

The corrections introduced by this corrigendum may affect three specific areas:

• Lists of sanctioned persons or entities: possible errors in names, identifiers or data of natural or legal persons included in sanctions lists.
• Definitions of the sanctions regime: corrections in the terms or concepts that define the scope of restrictive measures.
• Procedures of the sanctions regime: adjustments in the mechanisms for implementing or managing sanctions.

The restrictive measures regime against Russia for destabilizing activities is an instrument of the EU's Common Foreign and Security Policy (CFSP). Its non-compliance is not managed at the European level, but rather each Member State applies its own administrative and criminal sanctions.

Economic and operational impact

The direct impact of this corrigendum is not a new economic burden, but rather a compliance risk for companies operating with Russian counterparties. If the corrections affect the lists of sanctioned entities, a company could have been operating with an entity that is now clearly included in the list, or vice versa.

The main operational risks are:

• Risk of retroactive non-compliance: the entry into force is May 20, 2025, so operations carried out from that date under the previous version of the regulation must be reviewed.
• Administrative and criminal sanctions: non-compliance may result in legal consequences in the Member State where the company operates. The severity varies depending on the applicable national legislation.
• Asset blocking and transaction freezing: if a counterparty is included in the corrected list, any pending transaction or linked asset must be frozen.
• Cost of review and audit: companies with exposure to Russia must allocate resources to review their control lists and update their compliance systems.

Who does it affect?

This regulation directly affects:

• Export or import companies with commercial activity with Russia or entities linked to Russia.
• Financial entities (banks, asset managers, insurance companies) with exposure to Russian counterparties or assets in Russia.
• Companies in any sector that maintain service contracts, licenses or agreements with Russian persons or entities.
• Legal advisors, compliance officers and risk departments that manage sanctions control lists.
• CFOs and executives responsible for approving transactions with counterparties in markets under sanctions regime.
• Individuals with financial or commercial links to Russia subject to EU sanctions regulations.

Practical example

A Spanish industrial machinery company has a supply contract with a Russian company. Before the correction, it verified that its counterparty was not listed in the sanctioned entities list of Decision (CFSP) 2025/963 and proceeded with the operation.

Following the publication of this corrigendum, the compliance officer must re-verify whether the correction of formal errors has modified any data in the list that affects its counterparty. If the corrected error was, for example, an incorrect identifier of an entity that should have been sanctioned, the company could have carried out a transaction with a sanctioned entity without knowing it.

In that case, the company should: halt any pending operations, freeze linked assets if applicable, and notify the competent authorities of its Member State in accordance with applicable national legislation. Failure to act may result in administrative or criminal sanctions.

What should companies do now?

1. Access the full text of the corrigendum in the EU Official Journal and identify exactly which errors have been corrected: whether they affect lists of entities, definitions or procedures.
2. Compare the corrected version with the previous version of Decision (CFSP) 2025/963 to detect any changes that affect the counterparties with which your company operates.
3. Update internal control lists (screening lists) with the corrected data. If you use automated compliance tools, verify that they already incorporate the corrected version.
4. Review operations carried out since May 20, 2025 under the previous version of the regulation to detect possible compliance discrepancies.
5. Consult with a legal advisor specialized in international sanctions if any operation is detected that could have involved an entity affected by the corrections.
6. Document the review process to demonstrate due diligence in the event of possible inspections or requests from the competent authorities.