EU Sanctions Against DRC 2026: What Companies and Financial Entities Must Verify

Key data

European companies and financial entities with links in the Democratic Republic of the Congo must act now: Regulation (EU) 2026/2374, published on 27 October 2026, modifies the sanctions regime in force since 2005 and updates the annexes of designated persons and entities. Maintaining any financial or commercial relationship with listed subjects is illegal from the entry into force of this regulation.

The regulation modifies Council Regulation (EC) No 1183/2005, which is the basic framework for EU restrictive measures related to the situation in the DRC. This update may involve the incorporation of new persons or entities into the annexes, the removal of some already existing, or the modification of previous entries.

What does this regulation establish?

Regulation (EU) 2026/2374 maintains and updates two types of restrictive measures on designated persons and entities linked to the conflict in the DRC:

• Asset freezing: all funds and economic resources belonging to persons and entities listed in the annexes must be immediately immobilized.
• Prohibition on making funds available: it is prohibited to transfer, assign or make available, directly or indirectly, funds or economic resources in favor of designated subjects.

The modification updates the annexes of Council Regulation (EC) No 1183/2005, which contain the list of natural and legal persons subject to these measures. Any change in those annexes — additions, removals or modifications of identifying data — has direct and immediate effect on the compliance obligations of all European entities.

Economic and operational impact

Non-compliance with EU restrictive measures is not a minor breach. The consequences are articulated at two levels:

• Administrative sanctions: imposed by the competent authorities of each Member State, may include fines of significant amounts according to applicable national legislation.
• Criminal sanctions: in Spain and other Member States, operating with sanctioned subjects may constitute a crime typified in the Criminal Code, with prison sentences for those responsible and fines for legal entities.

From an operational perspective, companies must assume costs of reviewing and updating their regulatory compliance systems (compliance), including updating counterparty screening databases. Financial entities, moreover, are subject to specific obligations to communicate to the competent authorities when they detect frozen assets.

Reputational risk is also significant: being identified as a counterparty to a sanctioned subject can generate commercial and regulatory consequences that go beyond direct sanctions.

Who does it affect?

• Financial entities: banks, insurance companies, fund managers, payment entities and any financial intermediary with operations that may involve persons or entities in the DRC.
• Exporters and importers: companies with commercial activity in the region, including sectors of raw materials, mining, telecommunications or consumer goods.
• Companies with local subsidiaries or partners: any European company with direct or indirect presence in the DRC, or with Congolese counterparties.
• Advisors and consultants: law firms, consulting firms and advisors providing services to clients with links in the region must verify that their clients are not listed.
• Compliance and legal departments: responsible for updating internal procedures for screening and due diligence of counterparties.

Practical example

A Spanish mineral import company maintains a commercial relationship with a Congolese supplier with which it has been operating for three years. Following the publication of Regulation (EU) 2026/2374, that supplier appears included in the updated annexes of Council Regulation (EC) No 1183/2005.

From that moment on, the Spanish company is prohibited from making any pending payments to that supplier, receiving goods linked to ongoing operations and maintaining any financial relationship with it. If the company does not verify the updated list and executes a payment, it incurs a breach of EU restrictive measures, with the administrative and criminal consequences that correspond according to applicable Spanish legislation.

The solution: incorporate verification of the annexes of Council Regulation (EC) No 1183/2005 — in its version updated by Regulation (EU) 2026/2374 — as a mandatory step in the due diligence process for any new operation with counterparties in the DRC.

What should companies do now?

1. Review the updated annexes of Council Regulation (EC) No 1183/2005 in its version modified by Regulation (EU) 2026/2374, available in the EU Official Journal, to identify if any current counterparty appears on the list.
2. Update counterparty screening systems to include the new version of the annexes. If automated compliance tools are used, verify that they already incorporate this update.
3. Cautiously suspend any pending operations with counterparties in the DRC until confirming that they are not included in the updated annexes.
4. Communicate to the competent authorities if assets or funds belonging to persons or entities listed are detected, as required by the EU sanctions regime.
5. Review internal due diligence procedures to ensure that verification of sanctions lists is carried out systematically before initiating any new commercial or financial relationship with counterparties in the region.
6. Consult with the legal department or a specialized advisor if there is doubt about whether a specific counterparty is affected or about the notification obligations applicable in Spain.

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_202602374