Key data
| Regulation | Council Decision (CFSP) 2026/1149 of May 26, 2026 — amends Decision (CFSP) 2024/1484 |
|---|---|
| Publication | May 26, 2026 |
| Entry into force | May 26, 2026 (immediate effect) |
| Affected parties | Companies and individuals with commercial, financial or personal links with Russia |
| Category | European Regulation |
| Fiscal year | 2026 |
| Amended regulation | Decision (CFSP) 2024/1484 — sanctions framework against Russia for the war in Ukraine |
| CELEX reference | 32026D1149 |
If your company exports, imports, finances or maintains any contractual relationship with Russia, this update affects you from the day of its publication. Council Decision (CFSP) 2026/1149, adopted on May 26, 2026, amends the sanctions framework established by Decision (CFSP) 2024/1484 and expands or adjusts existing restrictions against Russia in the context of the war in Ukraine. There is no adaptation period: the regulation applies immediately.
What does this regulation establish?
The EU Council has amended Decision (CFSP) 2024/1484, which constitutes the European sanctions framework against Russia. This update adjusts and/or expands the restrictions already adopted. According to available data, the restrictive measures in the sanctions package may cover three major areas:
| Type of restrictive measure | Description |
|---|---|
| Asset freezing | Blocking of funds and economic resources of designated persons and entities |
| Travel bans | Restrictions on entry and transit in EU territory for designated persons |
| Commercial restrictions | Limitations on the export, import or transit of certain goods and services related to Russia |
| Financial restrictions | Prohibitions on transactions, financing or provision of financial services to designated entities or persons |
The regulation directly amends Decision (CFSP) 2024/1484. This means that the applicable text is not the 2024 version, but the result of applying the changes introduced by this 2026 Decision. Companies that have compliance protocols based on the 2024 version must update them to incorporate the modifications of May 2026.
Economic and operational impact
The impact is not only legal: non-compliance with EU restrictive measures can result in administrative and criminal sanctions in Member States, including Spain. This translates into direct economic risks for any company that has not reviewed its exposure:
- Risk of administrative fines for operating with entities or persons included in sanctions lists.
- Criminal risk for administrators and managers responsible for commercial or financial decisions.
- Operational blockade: ongoing contracts with Russian counterparties may be suspended or unenforceable if the counterparty becomes designated.
- Reputational risk and banking correspondent risk: banks may refuse operations if they detect links with sanctioned entities.
For financial entities, the impact is especially critical: they must update their counterparty screening systems and sanctions lists to reflect the changes introduced on May 26, 2026.
Who does it affect?
This regulation directly affects:
- Financial entities (banks, insurance companies, fund managers) with exposure to Russian assets, clients or counterparties.
- Exporters and importers with commercial operations related to Russia or with companies that have links with Russia.
- Companies with subsidiaries, shareholdings or contracts with entities established in Russia.
- Advisors, consultants and lawyers providing services to designated Russian persons or entities.
- CFOs and financial directors managing accounts, transfers or investments with Russian counterparties.
- Natural persons with personal or patrimonial links with Russia that may be affected by travel bans or asset freezing.
Practical example
A Spanish industrial machinery company has a supply contract signed in 2024 with a Russian company. Until now it operated under the framework of Decision (CFSP) 2024/1484 and had verified that its counterparty was not on sanctions lists. With the entry into force of Decision (CFSP) 2026/1149 on May 26, 2026, it must:
- Verify again whether its Russian counterparty has been added to the lists of designated persons or entities in the 2026 update.
- Review whether the goods subject to the contract are now subject to new export restrictions.
- Consult with its banking entity whether the payment operation associated with the contract can be executed without restrictions under the new framework.
If the company does not conduct this review and executes the contract with a now-sanctioned entity, it exposes itself to administrative and criminal sanctions, regardless of whether the contract was valid under the previous regulation.
What should companies do now?
- Immediately review the list of Russian counterparties: verify whether any person or entity with which you operate has been added to the updated sanctions lists by Decision (CFSP) 2026/1149.
- Update compliance protocols: if internal compliance procedures referenced Decision (CFSP) 2024/1484, they must incorporate the changes from the 2026 version.
- Review ongoing contracts: identify all active contracts with Russian counterparties or with companies that have links with Russia and assess their situation under the new framework.
- Alert the financial and treasury team: any transfer, payment or transaction related to Russia must pass through an updated sanctions filter before execution.
- Consult with a specialized legal advisor if there is significant exposure, to assess the specific risk and document the diligence performed (sanctions due diligence).
- Financial entities: update customer and counterparty screening systems to reflect the lists in force from May 26, 2026.
Frequently asked questions
What changes with Decision (CFSP) 2026/1149 compared to the previous regulation?
Decision (CFSP) 2026/1149 amends Decision (CFSP) 2024/1484, which was the European sanctions framework against Russia in force until now. The update adjusts or expands the restrictions previously adopted, which may include asset freezing, travel bans and commercial and financial restrictions. The consolidated text applicable is the result of the 2024 Decision with the changes introduced in May 2026.
What happens if my company fails to comply with EU sanctions against Russia?
Non-compliance with EU restrictive measures may result in administrative and criminal sanctions in Member States, including Spain. This affects both the company and its administrators and managers responsible for the decisions. In addition, it may result in the blocking of banking operations and reputational damage.
When do the new 2026 sanctions against Russia come into force?
Decision (CFSP) 2026/1149 came into force on the same day of its publication: May 26, 2026. There is no adaptation period, so obligations are enforceable from that date.
Which companies must review their compliance with these sanctions?
All companies and individuals with commercial, financial or personal links with Russia must review their compliance. This includes especially financial entities, exporters and importers with operations related to Russia, companies with subsidiaries or contracts with Russian entities, and advisors providing services to designated Russian persons or entities.
Where can I consult the updated list of sanctioned persons and entities?
The consolidated list of persons and entities subject to EU restrictive measures is published in the Official Journal of the EU (EUR-Lex) and is updated with each new Council decision. It can also be consulted on the financial sanctions portal of the EU Council website.
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:32026D1149