EU Sanctions Against Russia 2026: What Companies with Russian Links Must Do

Key data

Any Spanish or European company operating with Russian, Belarusian counterparties or with entities included in the EU sanctions lists has an active legal obligation as of 23 April 2026. Regulation (EU) 2026/511 amends Regulation (EU) No 269/2014, the EU's reference sanctions framework against those who undermine the territorial integrity, sovereignty and independence of Ukraine.

This is not a future regulation: it entered into force on the same day it was published. Exporters, financial entities and any company with direct or indirect links to Russia or Belarus must immediately verify their situation.

What does this regulation establish?

Regulation (EU) 2026/511 updates the sanctions framework established by Regulation (EU) No 269/2014, adapting it to the evolution of the conflict in Ukraine. The measures established by the sanctions regime are as follows:

• Asset freezing of all natural and legal persons designated on the sanctions list.
• Prohibition of entry into the EU for natural persons included in the lists.
• Prohibition of maintaining commercial or financial relations with sanctioned subjects for any company or person established in the EU.

The amendment possibly expands the list of affected parties and strengthens control mechanisms, adapting the framework to the current situation of the conflict. To find out the updated list of designated persons and entities, you must consult the official text of Regulation (EU) 2026/511 and the EU sanctions database.

Economic and operational impact

The impact is not only legal: operating with a sanctioned entity, even indirectly or unknowingly, exposes the company to administrative and criminal sanctions in Spain and other Member States. This implies reputational risks, blocking of operations and potential criminal liability for administrators.

The most immediate operational effects are:

• Need to review and update due diligence processes and counterparty verification.
• Possible blocking or cancellation of ongoing contracts with Russian or Belarusian entities that have been designated.
• Obligation to freeze assets of customers or partners appearing on the lists, with notification to competent authorities.
• Review of supply chains to detect indirect links with sanctioned subjects.

For financial entities, the operational burden is particularly high: they must monitor updates to the lists in real time and apply freezing measures immediately.

Who does it affect?

• Financial entities (banks, insurance companies, asset managers) with clients, accounts or assets linked to Russia or Belarus.
• Exporters and importers with commercial operations to or from Russia or Belarus.
• Companies with subsidiaries, partners or suppliers from Russia or Belarus, or with participation of designated subjects.
• Logistics and transport companies operating routes or services linked to these territories.
• Advisors, lawyers and consultants providing services to potentially sanctioned Russian or Belarusian entities or persons.
• Any company or natural person established in the EU maintaining commercial or financial relations with subjects included in the lists of Regulation (EU) 269/2014.

Practical example

A Spanish industrial machinery company has a supply contract with a Russian company with which it has been operating since 2021. Following the publication of Regulation (EU) 2026/511 on 23 April 2026, the company must immediately verify whether its Russian counterparty appears on the updated list of entities designated under Regulation (EU) 269/2014.

If the Russian company has been added to the list in this update, the Spanish company is prohibited from executing any pending deliveries, receiving payments or releasing funds linked to that contract. Continuing with the operation, even through contractual inertia, constitutes a breach of the regulation and may result in administrative and criminal sanctions for the company and its administrators in Spain.

The correct action is to halt the operation, consult with a specialized legal advisor and notify the competent authorities if assets are detected that must be frozen.

What should companies do now?

1. Verify counterparties immediately: Consult the updated list of sanctioned persons and entities in the official EU sanctions database and cross-reference it with all clients, suppliers and partners linked to Russia or Belarus.
2. Review ongoing contracts: Identify any active contract with Russian or Belarusian counterparties and assess whether any of them have been designated in the update of Regulation (EU) 2026/511.
3. Halt operations with sanctioned subjects: If a sanctioned counterparty is detected, immediately suspend any delivery, payment or transfer of funds or assets.
4. Notify competent authorities: If assets of sanctioned subjects are detected, report it to the competent national authorities according to the applicable Spanish regulations on the implementation of international sanctions.
5. Update due diligence processes: Implement or strengthen counterparty verification procedures to include periodic consultation of sanctions lists, especially when entering into any new commercial or financial relationship.
6. Specialized legal advice: If you have any doubts about the status of a counterparty or the legality of an operation, consult a legal advisor with experience in international sanctions before acting.