EU Sanctions Against Russia 2026: What Companies and Financial Entities Must Verify

Key data

If your company operates with Russian counterparties, finances operations with links to Russia or manages supply chains with components of Russian origin, the Commission Implementing Regulation (EU) 2026/1710 affects you from today. The regulation updates the lists of persons and entities sanctioned under Regulation (EU) 2024/2642, and its entry into force is immediate: there is no grace period.

The mechanism is simple but has serious consequences: the EU adds new names to the sanctions lists, and any commercial or financial relationship with those designated individuals becomes illegal at the moment of publication. Ignoring the update does not exempt from liability.

What does this regulation establish?

Commission Implementing Regulation (EU) 2026/1710 applies the sanctions framework of Regulation (EU) 2024/2642, which establishes restrictive measures against activities attributed to Russia considered destabilizing to the security of the EU and its Member States.

The specific measures it introduces are two:

• Asset freezing: all funds and economic resources belonging to the persons and entities included in the updated lists are immobilized. No company or individual in the EU can make funds available to them, directly or indirectly.
• Prohibition of entry into the EU: designated natural persons cannot enter or transit through the territory of the European Union.

The regulation updates the lists of designated persons under Regulation (EU) 2024/2642 by adding new natural and legal persons. The complete text with the specific names of the newly designated individuals is contained in the Official Journal of the EU, which is the source that companies must consult for verification.

Non-compliance with these measures is classified and sanctioned by the legislation of each Member State, and may result in both administrative and criminal sanctions, depending on the severity and applicable national legislation.

Economic and operational impact

The impact is not theoretical. Operating with an entity or person included in the sanctions lists exposes the company to direct and immediate consequences:

• Operational blockade: any financial transaction with a designated individual is automatically paralyzed. Pending payments, credit lines or ongoing contracts may be frozen without prior notice.
• Legal and reputational risk: non-compliance may result in investigations, administrative fines and, in the most serious cases, criminal liability for managers or executives who authorized the operations.
• Compliance costs: companies must allocate resources to review and update their counterparty screening processes, especially those with complex supply chains or financial relationships with third countries linked to Russia.

The impact is particularly significant for financial entities, which have enhanced control obligations, and for exporters with operations to or through Russia or intermediary countries.

Who does it affect?

• Financial entities (banks, insurance companies, fund managers, payment entities): obliged to block assets of designated individuals and not conduct operations with them.
• Exporters and importers with supply chains that include suppliers, customers or intermediaries with links to Russia.
• Companies with active contracts with Russian legal entities or with subsidiaries of Russian groups established in third countries.
• Advisors and consulting firms that provide services to entities with exposure to Russia: advising a sanctioned individual may also be restricted.
• CFOs and financial directors responsible for authorizing international payments or managing relationships with foreign counterparties.
• Compliance departments of any company with international activity.

Practical example

A Spanish industrial components company maintains a supply contract with an intermediary company registered in a third country, which in turn has a Russian legal entity as its majority shareholder. On 13 July 2026, that Russian company is included in the updated lists of Regulation (EU) 2026/1710.

From that same day, the Spanish company cannot make any pending payments or receive goods under that contract without incurring a breach of the sanctions regime. If the Compliance department does not detect the list update and authorizes a payment, the company is exposed to administrative sanctions and, potentially, to criminal liability of its administrators, according to Spanish transposition legislation.

The key: the problem is not just having a direct relationship with Russia, but also with entities that, through intermediary structures, are controlled by designated persons or companies.

What should companies do now?

1. Immediately consult the updated lists: access the complete text of Regulation (EU) 2026/1710 in the Official Journal of the EU and identify whether any of the newly designated individuals appear in the company's counterparty database.
2. Review the supply chain and financial relationships: not just direct relationships with Russia, but also with intermediaries, subsidiaries or shareholders that may be linked to the newly sanctioned individuals.
3. Preventively block any pending operations with counterparties that show signs of connection with the newly sanctioned individuals, until their status is confirmed.
4. Update counterparty screening systems to include the most recent lists. If automated compliance tools are used, verify that they have already incorporated the update of 13 July 2026.
5. Document the verification process: in case of inspection or investigation, the company must be able to prove that it carried out the relevant checks at the appropriate time.
6. Consult a legal advisor specialized in international sanctions if there is any doubt about the company's exposure, especially if it operates with complex corporate structures or in dual-use sectors.

Official source

Consult complete 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:32026R1710