Key data
| Regulation | Commission Implementing Regulation (EU) 2026/2193 of the Council, of 28 September 2026 |
|---|---|
| Base regulation that applies | Regulation (EU) 2024/1485 on restrictive measures against Russia |
| Publication | 28 September 2026 |
| Entry into force | 28 September 2026 (immediate effect) |
| Affected parties | Companies and financial entities with commercial links to Russia or Russian counterparties |
| Category | European Regulation |
| Year | 2026 |
| Official source | EUR-Lex CELEX:32026R2193 |
If your company has commercial relationships with Russia or entities linked to that country, this regulation affects you from today. Commission Implementing Regulation (EU) 2026/2193, published and in force on 28 September 2026, updates the list of natural and legal persons subject to restrictive measures under Regulation (EU) 2024/1485. This is not a future warning: it is an active obligation from its publication.
The mechanism is straightforward but has serious consequences: if any of your commercial counterparties—a supplier, a customer, a financial intermediary—appears on the updated list, you are obliged to block any economic relationship with that entity. Continuing to operate with it constitutes a breach of European sanctions regulations.
What does this regulation establish?
Commission Implementing Regulation (EU) 2026/2193 applies Regulation (EU) 2024/1485, which is the EU's general framework of restrictive measures against Russia. What this new implementing regulation does is update the list of natural and legal persons subject to two types of measures:
- Asset freezing: all funds and economic resources belonging to the listed persons or entities must be blocked. No company or financial entity can make funds, goods or services of economic value available to them.
- Prohibition of entry into the EU: natural persons included on the list cannot access the territory of the European Union.
The resulting obligations are direct and do not require national transposition: as a European Regulation, it applies immediately in Spain and all Member States from the date of its publication.
The updated list is available from the official source of EUR-Lex. The summary of the regulation does not detail the specific names of the newly listed persons—that information is found in the annexes of the full text published in the EU Official Journal—so direct consultation of the regulation is essential to identify those affected.
Economic and operational impact
The impact is not only legal: it is operational and financial. Companies that do not conduct an immediate review of their counterparties are exposed to:
- Administrative sanctions imposed by the competent Spanish authorities (in Spain, the Ministry of Foreign Affairs and the State Secretariat for Economy have competence in this matter).
- Criminal sanctions under national legislation, which may include fines and liability of directors.
- Blocking of banking operations: financial entities are obliged to block funds of listed persons. If your company operates with a sanctioned entity, your bank may be forced to halt linked transactions.
- Reputational damage and possible claims from third parties if it is proven that you knowingly operated with a sanctioned entity.
For financial entities—banks, insurance companies, fund managers—the obligation is even stricter: they must actively block the funds and economic resources of any listed person or entity, and report to the competent authorities.
Who does it affect?
- Export and import companies with direct or indirect commercial activity with Russia.
- Financial entities: banks, savings banks, credit cooperatives, insurance companies and fund managers with exposure to Russian counterparties.
- Companies with international supply chains that include suppliers, distributors or intermediaries with Russian links.
- Law firms and advisors providing services to clients with operations in Russia or with Russian counterparties.
- Companies with existing contracts with Russian entities or with subsidiaries of Russian business groups established in third countries.
- CFOs and financial directors responsible for managing regulatory compliance risks.
Practical example
Imagine a Spanish industrial machinery company that has a supply contract with a Russian company. On 28 September 2026, Regulation (EU) 2026/2193 enters into force. If that Russian company—or its parent company, or one of its controlling shareholders—has been added to the updated list of sanctioned entities, the Spanish company has the immediate obligation to:
- Suspend any pending delivery of goods or provision of services.
- Block any pending collection from that entity (or notify its financial entity to manage it).
- Not execute any payment to that counterparty.
- Notify the competent authorities if it detects blockable assets.
If the Spanish company continues to operate normally without having verified the list, it incurs a breach of sanctions regulations, regardless of whether it knew about the list or not. Due diligence is an obligation, not an option.
What should companies do now?
- Consult the updated list of sanctioned persons in the full text of Regulation (EU) 2026/2193 published on EUR-Lex. Identify whether any of your current or potential counterparties appear in the annexes.
- Review your entire supply chain, not just direct suppliers. Sanctions may affect intermediary companies or controlling shareholders of your counterparties.
- Audit existing contracts with Russian entities or companies with Russian links. If there are ongoing contracts with listed entities, suspend their execution immediately.
- Alert the finance department and banking entity about any pending transactions with potentially affected counterparties, to prevent the bank from blocking operations reactively and without prior notice.
- Implement a periodic screening process of counterparties against EU sanctions lists. The list can be updated at any time; compliance must be continuous, not one-off.
- Consult with a legal advisor specializing in foreign trade and international sanctions if there is any doubt about the company's exposure. Non-compliance can result in administrative and criminal sanctions under Spanish legislation.
Frequently asked questions
Where can I consult the updated list of persons and entities sanctioned by the EU against Russia?
The complete list is found in the annexes of Commission Implementing Regulation (EU) 2026/2193, available on EUR-Lex. Additionally, the European Commission maintains a consolidated search tool for sanctioned persons and entities on the official EU sanctions portal.
What happens if my company operates unknowingly with an entity that is on the sanctions list?
Lack of knowledge does not exempt you from responsibility. Companies have an obligation to conduct due diligence on their counterparties. Non-compliance can result in administrative and criminal sanctions under Spanish national legislation, regardless of whether the company knew about the list at the time of the transaction.
When does Regulation (EU) 2026/2193 enter into force and from when must I comply with it?
The regulation entered into force on the same day as its publication: 28 September 2026. There is no transitional period. Obligations are enforceable from that date, which means that any transaction carried out from 28 September with a listed entity constitutes a breach.
Do financial entities have additional obligations compared to ordinary companies?
Yes. Financial entities—banks, insurance companies, fund managers—are obliged not only to refrain from operating with those listed, but to actively block all funds and economic resources of the persons and entities included on the list, and to notify the competent authorities. Their level of obligation is stricter and more proactive than that of an ordinary commercial company.
Does this regulation only affect companies that operate directly with Russia?
No. The regulation may affect companies that operate with third countries if those counterparties have links with listed Russian persons or entities. It is essential to review not only direct suppliers or customers, but also the entire supply chain and the controlling shareholders of counterparties.
Official source
Consult full regulation on 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:32026R2193
