EU Sanctions Against Russia 2026: What Companies Must Do

Key data

If your company operates with Russian counterparties, has suppliers, customers or partners of Russian nationality, or manages assets linked to Russia, the Commission Implementing Regulation (EU) 2026/885 affects you as of 21 April 2026. There is no grace period: obligations are enforceable from day one.

This regulation updates the list of natural and legal persons sanctioned under the Regulation (EU) 2024/2642, which establishes the regime of restrictive measures against destabilizing activities attributed to Russia. Each update of this list requires all European companies to review their commercial and financial relationships.

What does this regulation establish?

Regulation 2026/885 is an implementing regulation: it does not create a new regime, but rather updates the list of sanctioned persons and entities within the already existing framework of Regulation (EU) 2024/2642. Its operational content translates into two concrete obligations for European companies:

• Asset freezing: all funds and economic resources belonging to listed persons and entities must be immobilized. No company may release, transfer, convert or make available those assets.
• Prohibition of making funds available: it is prohibited to transfer money, goods or any economic resource to listed persons or entities, directly or indirectly.

The list updated by this regulation includes both natural persons and legal persons linked to destabilizing activities attributed to Russia. The regulation does not publish the individual names of listed parties in the summary, but these appear in the full text of the regulation available in the Official Journal of the EU.

Economic and operational impact

The impact is not only legal: it is operational and reputational. Companies that do not have counterparty verification processes are exposed to three types of consequences:

• Administrative sanctions: imposed by the competent authorities of each Member State. In Spain, the body responsible for monitoring international sanctions is the State Secretariat for Economy.
• Criminal sanctions: deliberate or negligent non-compliance with restrictive measures may result in criminal liability for company administrators and executives.
• Reputational damage: operating with sanctioned entities, even unintentionally, can generate serious reputational impact with customers, investors and financial entities.

For financial entities —banks and insurers especially—, the operational impact is immediate: they must block accounts, cancel transfers and report to authorities any frozen assets. For non-financial companies with commercial ties to Russia, the main obligation is to verify that none of their counterparties appear on the updated list.

Who does it affect?

Regulation 2026/885 affects any company or person established in the EU that maintains relationships with listed persons or entities. The sectors with the highest exposure are:

• Banks and credit institutions: required to freeze assets, block transfers and report to authorities.
• Insurance companies: must verify that their policyholders or beneficiaries do not appear on the list of sanctioned parties.
• Logistics and transport companies: especially those operating routes or having clients linked to Russia or territories under its influence.
• Export and import companies: any operator with commercial relationships with Russian counterparties or Russian nationals.
• Asset managers and investment funds: must verify the beneficial ownership of assets under management.
• Legal, accounting and consulting advisors: providing services to potentially listed persons or entities.

Practical example

A Spanish logistics company providing transport services to a company headquartered in a third country, but whose beneficial owner is a Russian national included in the list updated by Regulation 2026/885, would be making economic resources available to a sanctioned party, even if unaware.

In this case, the company would incur a violation of EU restrictive measures, regardless of whether the contract was signed before or after the list update. The verification obligation is continuous: it is not sufficient to perform a check at the time of contract signature. Each list update —such as the one introduced by this regulation— requires repeating the screening process on all active counterparties.

This scenario is especially relevant for companies operating with complex corporate structures or intermediaries, where beneficial ownership may not be evident at first glance.

What should companies do now?

1. Review the updated list of sanctioned parties: access the full text of Regulation 2026/885 in the Official Journal of the EU and verify if any of the listed persons or entities matches current or potential counterparties.
2. Perform screening of all active counterparties: not only direct customers and suppliers, but also beneficial owners, partners and shareholders of companies with which you operate.
3. Implement a continuous verification process: each new list update requires repeating the process. Consider automated screening tools that alert in real time when a counterparty appears on sanctions lists.
4. Freeze assets and block operations if a match is detected: if a sanctioned party is identified among counterparties, the company must act immediately: halt payments, block assets and notify the competent authorities.
5. Document the compliance process: maintain an updated record of verifications performed. In case of inspection or investigation, documentation is the main evidence of due diligence.
6. Consult with specialized legal advisors: especially if the company has complex corporate structures, operates through intermediaries or has doubts about the beneficial ownership of any counterparty.