EU Sanctions against Russia 2026: what companies must verify

Key data

If your company has commercial or financial relations with Russian counterparties, this regulatory update affects you directly and immediately. The Council Implementing Regulation (EU) 2026/647, published and in force since 16 March 2026, updates the list of natural and legal persons subject to restrictive measures under Regulation (EU) 2024/2642, which regulates sanctions for destabilising activities by Russia.

This is not a declarative rule: it is directly applicable in Spain and throughout the EU from the same day of its publication. Operating with any entity or person included in the updated list may result in serious criminal and administrative consequences for the company and its directors.

What does this regulation establish?

Regulation 2026/647 is an implementing regulation, which means it applies and develops the measures already provided for in Regulation (EU) 2024/2642. Its specific function is to update the list of natural and legal persons designated as subjects of restrictive measures.

The measures applied to all designated persons on the list are:

• Asset freezing: all funds and economic resources belonging to designated persons and entities are blocked.
• Prohibition of making funds available: no company or person under European jurisdiction may transfer, pay, assign or make available to designated persons funds or economic resources, directly or indirectly.

The updated list includes both natural and legal persons linked to activities that the EU considers destabilising by Russia. The full text with the names and designated entities is available in the Official Journal of the EU through EUR-Lex.

Economic and operational impact

The impact is not just formal compliance: it has direct consequences on the daily operations of any company with exposure to Russian counterparties.

• Review of existing contracts: if a counterparty appears on the updated list, ongoing contracts are de facto suspended. No payments or deliveries can be made.
• Blocking of collections: if the Spanish company is a creditor of a sanctioned entity, it also cannot receive funds from that entity without specific authorisation.
• Compliance costs: updating screening systems, contracting sanctions list verification tools and strengthening due diligence processes represents a real operational investment, especially for SMEs with limited compliance resources.
• Reputational risk: being identified as a company operating with sanctioned entities has consequences that go beyond the economic sanction.

Who does it affect?

The regulation affects all companies and natural persons under European jurisdiction that maintain or are about to initiate relations with Russian entities. With particular intensity:

• Financial sector: banks, credit institutions, fund managers, insurance companies and any intermediary that processes payments or financing with Russian counterparties.
• Energy sector: companies importing or distributing energy with contractual links to Russian entities.
• Technology sector: suppliers and buyers of technology, software or hardware with origin or destination in designated Russian entities.
• Transport sector: logistics operators, shipping companies, freight forwarders and land transport companies with routes or clients in Russia.
• Any exporting or importing company that has Russia as a market of origin or destination, regardless of sector.
• Advisors, consultancies and law firms that provide services to Russian entities or that manage assets of designated persons.

Practical example

A Spanish technology company has a software supply contract with a Russian company it has been working with for three years. On 16 March 2026, Regulation 2026/647 enters into force, which includes that Russian company in the updated list of sanctioned entities.

From that moment on, the Spanish company cannot issue any invoice, receive any payment or deliver any product or service to that counterparty, even though the contract is in force and there are pending obligations to be fulfilled. Continuing to operate with it, even to collect a previous debt, constitutes a breach of the regulation and may result in serious administrative and criminal sanctions for the company and its responsible directors.

The only legal avenue would be to request specific authorisation from the competent authority, which in Spain is the State Secretariat for Economy or the body authorised to manage exceptions to the sanctions regime.

What should companies do now?

1. Consult the updated list: access the full text of Regulation 2026/647 on EUR-Lex and verify if any of your current or potential counterparties are among the designated persons.
2. Review your portfolio of clients, suppliers and partners: conduct an immediate screening of all entities with which you maintain commercial or financial relations with Russian links.
3. Suspend operations with sanctioned entities: if you identify a counterparty on the list, halt any pending transaction until you receive specific legal advice.
4. Update compliance systems: implement or update automatic verification tools against sanctions lists (sanctions screening) so that controls are continuous, not occasional.
5. Strengthen due diligence: apply enhanced due diligence procedures in all new contracts with counterparties with exposure to Russia, including verification of ultimate beneficial owners.
6. Document the controls performed: maintain a record of the verifications carried out. In case of inspection or investigation, documentation of the compliance process is a mitigating factor.
7. Consult with a specialised legal advisor: if you have ongoing contracts with potentially affected entities, seek advice before making any decision on continuity or contract termination.