Key data
| Regulation | Commission Implementing Regulation (EU) 2026/2165 of 24 September 2026 |
|---|---|
| Legal basis | Regulation (EU) 2024/2642 on restrictive measures against destabilizing activities of Russia |
| Publication | 24 September 2026 |
| Entry into force | 24 September 2026 (immediate effect) |
| Affected parties | Companies and individuals with commercial or financial links to Russia or sanctioned entities |
| Category | European Regulation — International sanctions |
| Measures applied | Freezing of assets and prohibition of making funds available to listed persons |
| Official source | CELEX:32026R2165 — EUR-Lex |
If your company exports, imports, finances or maintains any contractual relationship with entities or persons linked to Russia, this regulation affects you as of today. Commission Implementing Regulation (EU) 2026/2165, published on 24 September 2026, updates the lists of sanctioned subjects under the framework of Regulation (EU) 2024/2642, which regulates restrictive measures against destabilizing activities of Russia.
This is not a programmatic rule: it enters into force on the same day of its publication, which means that compliance obligations are enforceable immediately.
What does this regulation establish?
Commission Implementing Regulation (EU) 2026/2165 applies the sanctions framework of Regulation (EU) 2024/2642 by updating the lists of natural and legal persons subject to restrictive measures. The two concrete measures applied to listed persons are:
- Freezing of assets: the funds and economic resources of persons and entities included in the lists are blocked. No European operator can unblock them or make them available to the sanctioned parties.
- Prohibition of making funds available: it is prohibited to transfer, pay, assign or facilitate in any way economic resources to listed persons or entities, directly or indirectly.
The regulation is part of the EU sanctions package aimed at countering destabilizing activities of Russia, a framework that has been progressively expanded since 2022. This implementing regulation is the technical instrument that updates who is on the list, without modifying the general sanctions regime already established by Regulation (EU) 2024/2642.
To know at all times which persons and entities are sanctioned, the mandatory reference is the consolidated list of sanctions of the European Commission, which is updated with each new implementing regulation.
Economic and operational impact
The impact is not only legal: it is operational and financial. Operating with a sanctioned counterparty—even unknowingly—can result in:
- Administrative sanctions imposed by the competent authorities of each Member State (in Spain, the State Secretariat for Economy and the Bank of Spain, depending on the type of infraction).
- Criminal liability for company administrators and executives, according to applicable Spanish criminal law.
- Blocking of operations and possible freezing of company funds if the company is investigated for alleged collaboration.
- Reputational damage and loss of access to bank financing, as financial entities apply their own compliance controls.
The cost of not reviewing the lists is, in practice, unlimited: EU penalties and administrative sanctions for non-compliance with restrictive measures have no fixed cap at European level—each Member State sets its own sanctions regime—but in Spain can include very high fines and, in serious cases, prison sentences for those responsible.
The cost of reviewing the lists, on the other hand, is manageable: there are automated sanctions screening tools that can be integrated into ERP systems and supplier management systems.
Who does it affect?
- Financial operators: banks, credit institutions, fund managers, insurance companies and any entity that processes payments or manages assets with Russian counterparties.
- Exporters and importers: companies that trade with Russia or with entities that may be linked to sanctioned persons.
- Companies with Russian subsidiaries, partners or suppliers: any active contractual relationship with entities domiciled in Russia or controlled by Russian citizens.
- Legal advisors and consultancies: law firms, business consultancies and audit firms providing services to clients with exposure to Russia.
- Logistics and transport companies: operators managing goods with origin or destination in Russia or working with Russian freight forwarders.
- Individuals with financial relationships with Russia: natural persons maintaining accounts, investments or contracts with Russian entities or citizens.
Practical example
A Spanish industrial machinery company has a distributor in Moscow with which it has been operating for five years. Following the publication of Commission Implementing Regulation (EU) 2026/2165 on 24 September 2026, the Russian distributor—or its parent company—appears on the updated list of sanctioned legal persons.
If the Spanish company does not review the consolidated sanctions list of the European Commission and processes a pending transfer of €80,000 for a previous delivery, it would be committing a breach of the sanctions regime: it has made funds available to a sanctioned entity. This can result in an investigation by Spanish authorities, blocking of the transfer by the bank, and potentially administrative or criminal sanctions for the company's administrators.
The solution is simple but urgent: before executing any payment or renewing any contract with Russian counterparties, verify on the EU consolidated sanctions list whether the counterparty—or its beneficial owners—are included.
What should companies do now?
- Immediately review the EU consolidated sanctions list: access the official European Commission tool and verify whether any of your Russian counterparties—customers, suppliers, partners, distributors—appear on the list updated as of 24 September 2026.
- Preventively suspend any pending payment or transfer with Russian counterparties until confirming they are not sanctioned. A payment executed to a sanctioned party is a breach, even if it predates knowledge of the list.
- Update international sanctions control systems: if your company uses third-party screening tools (ERP, compliance systems, banking platforms), ensure they are synchronized with the updated consolidated list.
- Review active contracts with Russian entities: identify whether any active contract obligates you to make future payments to counterparties that may be sanctioned and consult with legal advisors before executing them.
- Document all verifications performed: in case of inspection, proof that the company performed the pertinent checks before operating can be decisive in demonstrating absence of intent or gross negligence.
- Consult a legal advisor specialized in international sanctions if you have doubts about your company's specific exposure or if any counterparty appears on the list.
Frequently asked questions
Where do I consult the updated list of persons and companies sanctioned by the EU?
The official consolidated list is published and updated on the European Commission's sanctions portal, accessible at sanctionsmap.eu. Each new implementing regulation—such as 2026/2165—adds new entries to this list. This is the source you should consult before any operation with Russian counterparties.
What happens if my company operates with a sanctioned entity without knowing it?
Lack of knowledge does not exempt from liability under the EU sanctions regime. If your company makes a transfer or maintains a commercial relationship with an entity included on the list, it may face administrative and criminal sanctions under Spanish law. This is why it is essential to verify the lists before each relevant operation and document the checks performed.
When does Commission Implementing Regulation (EU) 2026/2165 enter into force?
The regulation entered into force on the same day of its publication: 24 September 2026. There is no transitional period. Compliance obligations are enforceable from that date, which means that any operation after that date with a listed sanctioned party constitutes a breach.
What type of measures are persons and entities included on the list subject to?
Natural and legal persons included on the list of Regulation (EU) 2026/2165 are subject to two concrete measures: freezing of assets (their funds and economic resources are blocked) and prohibition of making funds available (no European operator can transfer money or economic resources to them, directly or indirectly).
Which companies have the highest risk of non-compliance with this regulation?
The sectors with the highest exposure are financial operators (banks, fund managers, insurance companies), exporters and importers with activity in Russia, companies with Russian subsidiaries or partners, and logistics companies managing goods with origin or destination in Russia. Law firms and consultancies providing services to clients with Russian links are also exposed.
Official source
Consult complete 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:32026R2165
