Key data
| Regulation | Council Decision (CFSP) 2026/1723, of 13 July 2026 |
|---|---|
| Modified rule | Council Decision (CFSP) 2020/1999 — EU sanctions framework on human rights |
| Publication | 13 July 2026 |
| Entry into force | 13 July 2026 (immediate effect) |
| Affected parties | Companies, financial entities and persons with commercial links to subjects sanctioned by the EU |
| Category | European Regulation |
| Year | 2026 |
| CELEX reference | 32026D1723 |
Spanish and European companies operating with international counterparties have a new urgent obligation: to review their lists of customers, suppliers and financial partners against the updated sanctions list by Decision (CFSP) 2026/1723. This regulation modifies the framework established by Decision (CFSP) 2020/1999 and takes effect on the same day of its publication, 13 July 2026.
This is not a regulation for gradual adaptation: non-compliance is immediate at the moment a transaction is carried out with a sanctioned person or entity, regardless of whether the company was aware of the list update or not.
What does this regulation establish?
Decision (CFSP) 2026/1723 modifies Decision (CFSP) 2020/1999, which is the EU's legal instrument for imposing sanctions globally for serious human rights violations and abuses. This modification may involve:
- Addition of new natural or legal persons to the sanctions list.
- Removal of persons or entities that are no longer subject to restrictions.
- Update of identifying data of subjects already included in the list.
The legal effects that are automatically activated for subjects included in the list are:
| Restrictive measure | Description |
|---|---|
| Asset freezing | All funds and economic resources of sanctioned subjects located in EU territory are blocked. |
| Entry prohibition | Sanctioned natural persons cannot enter or transit through the territory of EU Member States. |
| Prohibition on making funds available | No person or entity under EU jurisdiction can transfer funds or economic resources to sanctioned subjects, directly or indirectly. |
The consolidated list of subjects sanctioned under this regime is available and updated on the EU Sanctions Map, managed by the European External Action Service.
Economic and operational impact
The impact for companies is not theoretical: operating with a sanctioned entity or person, even unintentionally, can result in serious consequences:
- Administrative sanctions imposed by the competent authorities of each Member State (in Spain, the State Secretariat for Trade and the Bank of Spain, depending on the type of operation).
- Criminal liability for managers and executives who authorize operations with sanctioned parties.
- Blocking of financial operations and exports in progress, with the operational and reputational cost that this entails.
- Cost of compliance review: updating counterparty screening systems requires time and resources, especially for SMEs without their own legal department.
The cost of inaction far exceeds the cost of review. Fines for non-compliance with international sanctions in the EU have reached millions of euros in documented cases in other Member States.
Who does it affect?
- Financial entities: banks, savings banks, payment entities, fund managers and insurance companies that carry out international transfers or maintain accounts for foreign clients.
- Export and import companies: any operator trading with counterparties outside the EU, especially in high-risk regions.
- Service companies: consultancies, law firms, audit firms and technology companies providing services to international clients.
- Compliance and legal departments: responsible for keeping screening systems and due diligence procedures up to date.
- CFOs and financial directors: who authorize international payments and transfers.
- Foreign trade operators: customs agents, freight forwarders and international logistics operators.
Practical example
A Spanish industrial machinery company has a distributor in a third country with which it has been operating for three years. Following the update of the sanctions list on 13 July 2026, that distributor is included as a sanctioned entity due to its links to serious human rights violations.
If the Spanish company makes a pending payment or sends an order after that date without having updated its counterparty screening system, it incurs a violation of the EU sanctions regime. The fact that the commercial relationship was legitimate until the day before does not exempt it from liability. The financial director who authorized the transfer may face personal liability, in addition to administrative sanctions on the company.
The solution: before executing any international payment or shipment, verify the counterparty against the updated list available on the EU Sanctions Map.
What should companies do now?
- Immediately update screening systems: incorporate the updated sanctions list (Decision 2026/1723) into compliance systems and counterparty verification. This applies from 13 July 2026.
- Review the portfolio of active customers, suppliers and partners: cross-reference data for all international counterparties with the consolidated list of sanctioned subjects available on the EU Sanctions Map.
- Cautiously suspend pending operations with any counterparty that appears on the updated list until obtaining specific legal advice.
- Document the verification process: keep written record that screening has been performed on the date of each operation. This documentation is key in case of inspection or investigation.
- Train operations and finance teams: those responsible for authorizing payments and contracts must know the verification procedure and their legal obligations.
- Consult a legal advisor specialized in foreign trade or international sanctions if there is any doubt about a specific counterparty or about the scope of new inclusions in the list.
Frequently asked questions
Where can I consult the updated list of EU-sanctioned subjects following Decision 2026/1723?
The consolidated list of persons and entities sanctioned under the EU human rights regime (Decision 2020/1999 and its amendments, including 2026/1723) is available on the EU Sanctions Map. It can also be consulted directly in the official text of the Decision on EUR-Lex.
When does the update of the EU sanctions list from July 2026 enter into force?
Decision (CFSP) 2026/1723 entered into force on the same day of its publication: 13 July 2026. There is no transitional period. Any operation carried out from that date with a subject included in the updated list constitutes immediate non-compliance.
What happens if my company operates with a sanctioned party without knowing it?
Lack of knowledge does not exempt from liability under the EU sanctions regime. Companies have an obligation to maintain due diligence systems and counterparty verification. Non-compliance can result in administrative and criminal sanctions in Spain, imposed by the competent authorities depending on the type of operation (State Secretariat for Trade, Bank of Spain, etc.).
What specific effects do sanctions have on persons and entities included in the list?
Subjects included in the list are subject to two main measures: freezing of all their assets in EU territory, and prohibition of entry or transit through Member States. Additionally, no person or company under EU jurisdiction can make funds or economic resources available to them, either directly or indirectly.
How frequently does the EU update its human rights sanctions list?
The list can be updated at any time by a Decision of the EU Council. There is no fixed periodicity. Therefore, compliance systems must be configured to incorporate updates in real time or as frequently as possible, not just in annual reviews.
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=CELEX:32026D1723