EU Sanctions Against Russia 2026: What Exporters and Companies with Commercial Links Must Review

Key data

Spanish companies with any commercial or financial link to Russia have an immediate obligation: review their operations. The Regulation (EU) 2026/1805, published and in force since 16 July 2026, amends Regulation (EU) No. 833/2014, which is the central legal framework for European economic sanctions against Russia since the beginning of the conflict in Ukraine.

This is not a forward-looking regulation: it entered into force on the same day as its publication. Any operation carried out from that date onwards must already comply with the new expanded restrictions.

What does this regulation establish?

Regulation (EU) 2026/1805 introduces amendments to Regulation (EU) No. 833/2014, which constitutes the central pillar of the EU's economic sanctions regime against Russia. The areas affected by this amendment are as follows:

The regulation also requires consultation of updated lists of designated persons and entities before conducting any transaction with Russian or Belarusian counterparties. These lists are dynamic and updated with each new sanctions package.

Compared to the previous regulation, Regulation (EU) No. 833/2014 already established a broad framework of restrictions. Regulation 2026/1805 expands and adjusts that framework, tightening conditions in the four sectors mentioned. Companies that already had compliance procedures adapted to 833/2014 must update them to incorporate the new changes.

Economic and operational impact

The impact is not only legal: it has direct consequences on the daily operations and compliance costs of affected companies.

• Exporters: Must verify that no dual-use goods or restricted products reach Russia, either directly or through third-country intermediaries. The cost of a robust export control program can be significant, but is less than the risk of sanctions.
• Financial entities: Must update their counterparty screening systems to incorporate new financial sector restrictions. Any transaction with designated entities is blocked.
• Transport companies: Are explicitly identified as a priority attention sector. Must review routes, clients and contracts involving Russian or Belarusian entities.
• Companies with complex supply chains: The risk of indirect exposure is high. A second or third-tier supplier may be linked to designated entities without the company knowing.

Non-compliance with these measures may result in administrative and criminal sanctions under Spanish national implementing regulations. This means that responsibility does not fall only on the company as an entity: it can reach executives and compliance officers on a personal basis.

Who does it affect?

• Exporting companies of dual-use goods or products with restrictions to Russia or territories under its influence.
• Financial entities (banks, insurance companies, asset managers) with exposure to Russian or Belarusian counterparties.
• Transport and logistics companies with operations involving Russia or Belarus.
• Energy sector companies with contracts, supplies or business relationships linked to Russia.
• Service providers to Russian or Belarusian entities (consulting, technology, engineering, etc.).
• Companies with supply chains that include suppliers with direct or indirect links to designated entities.
• Advisors and law firms providing services to any of the above: have an obligation to verify their clients' compliance.

Practical example

A Spanish industrial machinery company that exports components with dual civil and military use has a distributor in Kazakhstan who, in turn, resells part of the material to customers in Russia. Although the Spanish company does not sell directly to Russia, the operation may fall within the scope of Regulation (EU) 2026/1805 restrictions if the Kazakh distributor is on the list of designated entities or if the Spanish company knew or should have known the final destination.

In this case, the company must: (1) verify that its distributor does not appear on updated lists of designated persons and entities, (2) include contractual clauses prohibiting resale to sanctioned destinations, and (3) document that due diligence process. Without that documentation, in an inspection, the company could not prove that it acted in good faith.

What should companies do now?

1. Review all active operations with Russian or Belarusian counterparties: contracts in force, orders in progress, pending payments. Identify which are affected by the new restrictions.
2. Consult updated lists of designated persons and entities before conducting any new transaction. These lists are available in the consolidated Regulation (EU) 833/2014 on EUR-Lex and on the EU sanctions portal.
3. Update internal compliance procedures to incorporate the changes introduced by Regulation 2026/1805 in the dual-use, energy, finance and services sectors.
4. Review supply chains to identify second and third-tier suppliers with possible links to designated entities.
5. Include contractual clauses in new contracts that expressly prohibit resale or final use in Russia or Belarus where applicable.
6. Document all due diligence performed. In case of inspection or investigation, documentation is the main defense against administrative or criminal sanctions.
7. Consult with legal advisors specialized in foreign trade and international sanctions if there is any doubt about the company's specific exposure.

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:32026R1805