EU Sanctions against the DRC in 2026: What Banks and Exporters Must Verify

Key data

Banks, exporters and companies with operations linked to the Democratic Republic of the Congo have an immediate obligation: to verify whether any of their clients, suppliers or counterparties appear on the updated list of subjects sanctioned by the EU. Council Implementing Regulation (EU) 2026/2191, published on 29 September 2026 and in force since 28 September, applies updated restrictive measures under the Regulation (EC) No 1183/2005.

This is not a new regulation: it is an update to the sanctions regime already in force. What changes is the list of individuals and entities affected. Any active commercial or financial relationship with those subjects must be blocked immediately.

What does this regulation establish?

Council Implementing Regulation (EU) 2026/2191 updates the restrictive measures applied in the context of the armed conflict and humanitarian crisis in the Democratic Republic of the Congo. The two main measures are:

• Asset freezing: all funds and economic resources belonging to the listed persons and entities must be immobilized. No European entity may make funds or economic resources available to them, directly or indirectly.
• Travel ban: individuals included on the list cannot enter or transit through the territory of EU Member States.

The criteria for inclusion on the list are: being responsible for serious human rights violations in the DRC, or obstructing the peace process and stabilization of the country. The EU Council is the body that decides inclusions and exclusions through this type of implementing regulation.

The regulation is part of the sanctions regime established by Regulation (EC) No 1183/2005, which has been regulating EU restrictive measures with respect to the DRC for more than two decades. This implementing regulation updates it, but does not replace it.

Economic and operational impact

The direct impact for European companies is not a fee or fixed cost: it is the risk of non-compliance. Operating with a sanctioned subject—even unknowingly—can result in:

• Administrative sanctions imposed by the competent authorities of each Member State (in Spain, the State Secretariat for Economy and the Bank of Spain, depending on the type of entity).
• Criminal sanctions for those responsible at the company or financial entity, in the most serious cases.
• Immediate operational blockade of transactions in progress with the listed subjects, with the consequent impact on the payment or supply chain.

The real cost depends on each company and the severity of the non-compliance detected. What is quantifiable is the cost of not acting: in the EU sanctions regime, ignorance does not exempt from responsibility. Financial entities, in particular, have enhanced due diligence obligations in the field of money laundering prevention that overlap with this regime.

Who does it affect?

• Financial entities (banks, savings banks, payment entities, fund managers) with clients, accounts or transactions linked to the DRC or to Congolese nationals.
• Exporters and importers with commercial operations in the DRC or with companies domiciled there.
• Companies with subsidiaries, partners or suppliers in the region that may be linked to the listed subjects.
• Logistics and transport companies that operate routes to or from the DRC.
• Advisors and consulting firms that provide services to clients with exposure to the region: they must inform their clients of the update.
• Compliance departments of any company with international activity that includes Central Africa.

Practical example

A Spanish bank that manages accounts for companies importing minerals from the DRC receives a transfer from a Congolese supplier. Before executing the payment, the compliance department must check the name of the payer and beneficiary against the updated list of sanctioned subjects published in Council Implementing Regulation (EU) 2026/2191.

If the supplier appears on the list, the bank is obliged to freeze the funds and notify the competent authority. Executing the transfer without that verification—even if the bank did not know the supplier was sanctioned—may constitute a breach of the EU sanctions regime, with the administrative and criminal consequences that entails.

The same principle applies to a machinery exporter that has a distributor in Kinshasa: if that distributor or its legal representatives appear on the list, any shipment of goods or pending collection must be blocked immediately.

What should companies do now?

1. Access the updated list of sanctioned subjects published in Council Implementing Regulation (EU) 2026/2191 and in the EU Sanctions Map, which centralizes all current lists.
2. Check the list against the database of clients, suppliers and counterparties that have any link to the DRC. This verification must be immediate, given that the regulation entered into force on 28 September 2026.
3. Block any transaction in progress with subjects appearing on the list and notify the competent authority of the Member State.
4. Update sanctions screening systems (if automated compliance tools are used) to incorporate the new list. Many sanctions list providers update automatically, but it is advisable to verify this.
5. Document the verification process: in case of inspection or investigation, the company must be able to demonstrate that it performed due diligence. Keep evidence of the queries made and their results.
6. Inform the compliance team and management of the update, especially if the company has active exposure to the region. Lack of knowledge does not exempt from responsibility before the authorities.

Official source

Consult full regulation at 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_202602191