Key data
| Regulation | Rectification to Commission Implementing Regulation (EU) 2023/429 of the Council, of 25 February 2023 |
|---|---|
| Base regulation | Regulation (EU) No 269/2014 — restrictive measures relating to Ukraine |
| Publication | 25 September 2026 |
| Entry into force | Not specified in the act |
| Affected parties | Companies and financial entities with operations linked to persons or entities sanctioned by the EU |
| Category | European Regulation |
| Priority sectors | Financial, export and services |
If your company operates in the financial sector, exports goods or provides services with counterparties in Russia or linked to persons designated by the EU, this correction affects you directly. Commission Implementing Regulation (EU) 2023/429, originally published on 25 February 2023 in the Official Journal (L 59 I), implements the restrictive measures of Regulation (EU) No 269/2014 against those who compromise the territorial integrity of Ukraine. The rectification published on 25 September 2026 modifies specific data from that list: names, dates or reasons for designation of sanctioned persons or entities.
This is not a policy change, but a technical correction. But that does not reduce its operational importance: if your screening filters are calibrated with the previous data, they may be failing right now.
What does this regulation establish?
The rectification corrects errors or inaccuracies in the identifying data of persons and entities included in the sanctions list of Regulation (EU) 2023/429. The types of corrections typical in this type of acts include:
- Incorrect names or transliterations of designated natural or legal persons
- Dates of birth, nationalities or other incorrect identifying data
- Reasons for designation that contained inaccuracies
- Data of legal entities (company name, registered office, identifiers)
The rectifying act replaces the incorrect data from Regulation (EU) 2023/429 with the correct data. The base regulation that enables these restrictive measures is Regulation (EU) No 269/2014, which establishes the general framework for sanctions related to Ukraine.
The obligations for companies do not change in nature: it remains mandatory not to make funds or economic resources available to designated persons and entities. What changes is that the identifiers with which you must perform that control are now different—and more accurate—than those published in February 2023.
Economic and operational impact
The direct impact of this correction is not economic in itself, but operational: the risk lies in not updating systems and continuing to use outdated data. The consequences of non-compliance with EU sanctions are:
- Serious administrative sanctions, the amount of which depends on each Member State but can be very high
- Criminal sanctions for company officials, including possible prison sentences under applicable national legislation
- Reputational damage and possible exclusion from public procurement or relationships with international financial entities
- Blocking of operations if a transaction with a sanctioned entity is detected before the company has updated its controls
The cost of updating compliance systems is marginal compared to the risk of a sanction for operating with a designated entity whose data has changed in the official list. The financial, export and services sectors are the most exposed because they have a higher volume of counterparties that must be screened.
Who does it affect?
- Financial entities: banks, fund managers, insurance companies, payment entities — obliged to screen customers and counterparties against sanctions lists
- Export companies: any company that exports goods or technology with possible recipients in Russia or linked to designated persons
- Service companies: consultancies, law firms, audit firms, logistics companies that provide services to persons or entities that may be on the list
- Compliance and legal departments: responsible for keeping control lists and due diligence procedures up to date
- Compliance software providers: that must update their databases with corrected identifiers
Practical example
Imagine your bank has in its screening system the name of a designated person with a transliteration from Cyrillic that turned out to be incorrect in the original Regulation 2023/429. The rectification published on 25 September 2026 corrects that transliteration to the correct name. If your system continues to use the incorrect name, it may not detect a transaction with that person because the name appearing in the operation matches the correct name—the one now appearing in the rectified list—but not the one you had in your filter.
The result: a transaction with a sanctioned person that goes unnoticed in your controls. That is exactly the type of non-compliance that can result in serious administrative and criminal sanctions for the entity and its officials. The solution is simple: update the list as soon as the rectification is published.
What should companies do now?
- Download the updated version of the sanctions list from the EU Official Journal or from the Sanctions Map of the European Commission, which consolidates all current lists.
- Identify what data has been corrected: compare the identifiers from the original Regulation 2023/429 with those from the rectification to locate exactly what names, dates or reasons have changed.
- Update screening systems: transfer the corrected data to counterparty filtering tools (AML software, onboarding systems, internal blacklists).
- Review recent operations: check whether any active transaction or business relationship could be affected by the corrected data, especially in the financial, export and services sectors.
- Document the update: keep internal records of when and how controls were updated, as evidence of due diligence in the event of a regulatory inspection.
- Inform the compliance and legal team: ensure that all those responsible for making decisions about counterparties are aware of the changes introduced by the rectification.
Frequently asked questions
What exactly does Commission Implementing Regulation (EU) 2023/429 correct with this rectification?
The rectification corrects identifying data of persons or entities included in the sanctions list: these may be incorrect names or transliterations, dates of birth, nationalities, reasons for designation or other identifying data of designated natural or legal persons. The act does not add new persons to the list or change sanctions policy, it only corrects inaccuracies in the data already published.
What happens if my company does not update its compliance controls with this correction?
If your screening systems continue to use the incorrect data from the original Regulation and not the corrected data, you may fail to detect an operation with a sanctioned person or entity. This may constitute a breach of EU sanctions, with consequences of serious administrative and criminal sanctions, both for the company and for its individual officials.
Where can I consult the updated list of persons and entities sanctioned by the EU in relation to Russia?
The consolidated and updated list is available on the Sanctions Map of the European Commission and in the EU Official Journal. It is recommended to always consult the consolidated version, which integrates all rectifications and amendments subsequent to the original act.
When does this correction enter into force?
The rectification was published on 25 September 2026. The act does not specify an entry into force date different from publication, which in practice means that the corrected data is what should be applied from that date. Companies must update their controls without delay.
Which sectors have the greatest obligation to update their controls following this rectification?
The sectors most directly affected are the financial sector (banks, fund managers, insurance companies, payment entities), the export sector (companies that export goods or technology) and the services sector (consultancies, logistics, law firms). These sectors have the strictest obligation to perform screening of counterparties against EU sanctions lists and to keep those controls up to date.
Official source
Consult full regulation in 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_202690800
