Key data
| Regulation | Commission Implementing Regulation (EU) 2026/2490 of 3 November 2026 — amends for the 364th time Regulation (EC) No 881/2002 |
|---|---|
| Publication | 4 November 2026 |
| Entry into force | 3 November 2026 |
| Affected parties | Financial entities, companies and persons with possible links to those listed |
| Category | European Regulation |
| Year | 2026 |
| Amendment number | 364th amendment to Regulation (EC) 881/2002 |
| International framework | Coordinated by the UN and the EU as part of the fight against terrorism and jihadist financing |
If your company operates in the financial sector, carries out international transfers, maintains relationships with counterparties in risk zones or simply has customers or suppliers with names that may match those listed, this update affects you directly. Commission Implementing Regulation (EU) 2026/2490 amends for the 364th time Regulation (EC) No 881/2002, the EU's central instrument for implementing United Nations sanctions against persons and entities associated with Daesh (ISIL) and Al-Qaeda.
The regulation entered into force on 3 November 2026, with immediate effect. There is no transitional period. From that moment on, any financial or commercial relationship with those newly listed constitutes an infringement.
What does this regulation establish?
Regulation (EC) 881/2002 is the European legal framework that transposes UN Security Council Sanctions Committee sanctions against persons and entities linked to Daesh and Al-Qaeda into EU law. Each update of that UN list is incorporated into European law through a Commission Implementing Regulation.
This 364th amendment introduces the following specific changes to the consolidated list:
| Measure | Description |
|---|---|
| Freezing of financial assets | All funds, financial assets and economic resources of those listed are frozen. No entity may make them available to the affected parties or benefit them directly or indirectly. |
| Prohibition on making funds available | It is prohibited to transfer, pay, assign or provide funds or economic resources to the persons and entities included in the updated list. |
| List update | New persons and entities associated with Daesh (ISIL) and Al-Qaeda are incorporated, in accordance with the designation of the UN Sanctions Committee. |
The complete and updated consolidated list is available in the official text published in the EU Official Journal. It is essential to consult it directly to identify the specific names added in this 364th amendment.
Economic and operational impact
The impact is not only legal: it is operational and reputational. The consequences of non-compliance include:
- Serious administrative sanctions imposed by the competent authorities of each Member State (in Spain, the Ministry of Economy and SEPBLAC for financial entities).
- Criminal liability for collaboration with terrorist financing, as defined in the Spanish Criminal Code.
- Blocking of operations and possible freezing of own accounts if the entity is investigated.
- Severe reputational damage and loss of licenses in regulated sectors.
The operational cost of verification is low compared to the risk. Sanctions list screening tools (integrated into most compliance systems) must be updated to incorporate the new listings from this 364th amendment.
Who does it affect?
- Financial entities: banks, savings banks, credit cooperatives, payment entities, fund managers, insurance companies and any financial intermediary with an obligation to apply due diligence measures.
- Companies with international activity: importers, exporters, distributors or any company with suppliers, customers or partners in regions at risk associated with Daesh or Al-Qaeda.
- Advisors and consultancies that provide services to persons or entities that could be listed.
- Payment platforms and fintech that process international transactions.
- Companies in any sector that, in the course of their activity, may maintain business relationships with natural or legal persons included in the list.
Practical example
A Spanish financial entity regularly processes transfers to countries in North Africa and the Middle East. Following the publication of Commission Implementing Regulation (EU) 2026/2490 on 4 November 2026, the compliance team must immediately update its screening database with the new names included in the list.
If in the days following entry into force (3 November 2026) a transfer is processed to a person or entity recently added to the list without having updated the system, the entity incurs a breach of European restrictive measures. This may result in an investigation by SEPBLAC, serious administrative sanctions and, in the worst case, criminal liability for terrorist financing.
The same risk applies to an industrial company that has a raw material supplier whose name or business name matches one of the newly listed: any payment made after 3 November 2026 without having verified the updated list constitutes a breach.
What should companies do now?
- Access the updated list: Consult the full text of Commission Implementing Regulation (EU) 2026/2490 in the EU Official Journal to identify the new names included in this 364th amendment.
- Update screening systems: Incorporate the new listings into compliance tools and counterparty verification. This update must be carried out immediately, as the regulation entered into force on 3 November 2026.
- Review active business and financial relationships: Cross-reference your database of customers, suppliers and partners with the new names included in the list. Pay special attention to counterparties in risk regions.
- Suspend any pending operations with persons or entities identified as listed until receiving specific legal advice.
- Document the verification process: Keep written records of the checks carried out, the date and the result. This documentation is essential in case of inspection or subsequent investigation.
- Consult your legal or compliance team if there is any doubt about whether a counterparty could be affected by the new designations.
Frequently asked questions
When does this update to the list of sanctioned persons enter into force?
Commission Implementing Regulation (EU) 2026/2490 entered into force on 3 November 2026, one day before its official publication in the EU Official Journal (4 November 2026). There is no transitional period: obligations are enforceable from the same day of entry into force.
What happens if my company makes a payment to someone on the new list?
Any transfer of funds or making available of economic resources in favor of a listed person or entity constitutes a breach of Regulation (EC) 881/2002. The consequences include serious administrative sanctions and possible criminal liability for terrorist financing, according to applicable Spanish law.
Where can I consult the complete and updated list of sanctioned persons?
The consolidated list of persons and entities subject to restrictive measures is published in the Official Journal of the European Union. The consolidated EU sanctions list can also be consulted on the official European Commission portal dedicated to restrictive measures.
Does this regulation only affect banks or also non-financial companies?
It affects any natural or legal person operating in the EU, regardless of sector. Financial entities have additional due diligence obligations, but an industrial company, a consultancy or a distributor also incurs a breach if it carries out operations with those listed.
How many times has Regulation 881/2002 been amended and why is this relevant?
This is the 364th amendment to Regulation (EC) 881/2002 since its entry into force. The frequency of updates reflects the dynamics of the UN Sanctions Committee, which continuously adds or removes persons and entities. This is why it is essential to have systems for automatic updates of sanctions lists.
Official source
Consult complete 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_202602490
