EU Sanctions Against Russia 2026: What Companies Must Do

Key data

Any company that has partners, clients or suppliers with links to Russia must act today. The Implementing Regulation (EU) 2026/1147, published and in force on 26 May 2026, updates the list of natural and legal persons subject to restrictive measures under Regulation (EU) 2024/1485. It is not a future regulation: its effects are immediate from the date of publication.

The risk is not theoretical. Operating with an entity or person listed in the updated list—even involuntarily—exposes the company to administrative and criminal sanctions determined by each Member State. Ignorance of the list does not exempt from responsibility.

What does this regulation establish?

Regulation 2026/1147 is an implementing regulation: it does not create a new sanctions regime, but rather updates the list of subjects to which the restrictive measures already established by Regulation (EU) 2024/1485 apply. The two specific measures that apply to listed subjects are:

• Asset freezing: all funds and economic resources belonging to the listed persons or entities are blocked.
• Prohibition of making funds available to them: no European company or entity may transfer, pay, assign or provide economic resources to the subjects included in the list, directly or indirectly.

The update of the list means that new natural persons (executives, owners, intermediaries) and new legal persons (companies, holdings, subsidiaries) may have been added that were not previously restricted. Companies that maintained relationships with those subjects must cease any operations immediately.

The sectors with the highest identified exposure in the regulation are: energy, logistics, technology and international trade with links to Russia or neighbouring countries.

Economic and operational impact

The impact is not only legal: it is operational and financial. Affected companies must assume direct and indirect costs arising from compliance:

• Cost of immediate review: urgent audit of the database of partners, clients and suppliers against the updated list.
• Cost of system updates: automated screening tools (AML, KYC, compliance) must incorporate the new list without delay.
• Cost of breaking commercial relationships: if any partner or supplier is listed, the company must terminate the relationship immediately, with the impact on supply chain or client portfolio that this entails.
• Risk of sanctions for non-compliance: sanctions are determined by each Member State and may include both administrative fines and criminal consequences for those responsible at the company.

Financial entities have especially high exposure: they must update their screening systems immediately to avoid processing transactions with listed subjects, which could constitute a breach of international sanctions regulations.

Who does it affect?

• Energy sector companies with contracts, supplies or intermediaries linked to Russia or countries in its orbit.
• Logistics and transport companies with routes, operators or clients in the region.
• Technology companies that export software, hardware or services to Russian entities or related entities.
• Importers and exporters with international trade activity that includes counterparties in Russia or neighbouring countries.
• Financial entities (banks, asset managers, insurers, fintechs) that process payments, financing or investments with Russian links.
• Advisors and consultancies that provide services to clients with exposure to Russia (due diligence obligation on their own clients).
• Compliance and legal departments of any company with international activity in the region.

Practical example

A Spanish logistics company regularly works with a freight forwarder based in a Baltic country that, in turn, operates routes to Russia. Following the publication of Regulation 2026/1147, the compliance officer performs routine screening and detects that one of the intermediary companies of that freight forwarder has been added to the updated list.

At that point, the Spanish company has the obligation to immediately suspend any operation involving that entity, including pending payments, ongoing contracts and new transport orders. If it does not—even through ignorance of the list update—it incurs a breach of EU restrictive measures, with the administrative and criminal consequences that each Member State has established.

This scenario is especially frequent in supply chains with multiple intermediaries, where the sanctioned entity is not the direct supplier but a more distant link in the chain.

What should companies do now?

1. Update screening systems immediately: incorporate the list published in Regulation 2026/1147 into all compliance, AML and KYC tools. Do not wait for the next scheduled update cycle.
2. Review the database of partners, clients and suppliers: perform an urgent cross-check of all active counterparties against the new list, especially in the energy, logistics, technology and international trade sectors.
3. Suspend operations with listed subjects: if any match is detected, immediately cease any transaction, payment or service provision. Document the decision and the time it was made.
4. Review existing contracts: identify whether any active contract directly or indirectly involves persons or entities included in the updated list.
5. Inform the legal department and management: non-compliance can result in criminal sanctions for those responsible at the company, not just fines to the entity.
6. Establish a continuous update protocol: implementing regulations on sanctions are published frequently. It is necessary to have an alert system that notifies each new update to the list.

Official source

Consult full regulation in official source

Notice: 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:32026R1147