EU Sanctions against Russia 2026: What Exporters and Banks Must Do

Key data

Companies with operations linked to Russia have a new urgent obligation from 23 April 2026. The EU Council has published Regulation (EU) 2026/506, which amends Regulation (EU) No 833/2014 and expands the scope of restrictive measures motivated by the conflict in Ukraine. The regulation is directly applicable in all Member States, including Spain, without the need for transposition.

What changes is not just the list of prohibited products: the regulation expressly strengthens mechanisms to prevent sanctions from being circumvented through third countries, affecting companies that operate with Russia indirectly.

What does this regulation establish?

Regulation (EU) 2026/506 introduces the following amendments to the current sanctions framework of Regulation 833/2014:

• Expansion of lists of prohibited goods and services: Export and import prohibitions are extended to new goods, services and sectors. Companies must check their current operations against the updated lists published in the official text of the regulation.
• Strengthening of anti-evasion mechanisms: Controls are tightened to prevent sanctions from being circumvented through operations channelled through third countries. Any operation with Russia carried out indirectly is equally subject to the prohibitions.
• Strengthened due diligence obligations: Financial entities and exporting companies must update their internal compliance control and due diligence procedures.
• Review of supply chains and contracts: European companies are required to review their supply chains and contracts with Russian counterparties to ensure compliance.
• National sanctions regime: Non-compliance may result in administrative and criminal sanctions according to the legislation of each Member State. The regulation does not set single amounts at European level.

This regulation is part of the succession of sanctions packages that the EU has been approving since 2014 against Russia, and represents a new expansion of the scope of applicable restrictions.

Economic and operational impact

The impact of this regulation translates into direct and indirect operating costs for affected companies:

The cost of adaptation varies depending on the size and exposure of each company. For companies with active operations in Russia or with suppliers in countries that act as a bridge (such as some Central Asian or Caucasus countries), the impact can be significant: contract review, possible terminations, search for alternative suppliers and update of compliance systems.

Who does it affect?

This regulation directly affects:

• Exporting companies that sell goods or services to Russia, directly or through intermediaries in third countries.
• Importing companies that acquire goods or services of Russian origin, even indirectly.
• Financial entities (banks, insurance companies, asset managers) that finance, insure or intermediate operations with Russian counterparties.
• Commercial operators with any contractual or supply chain link with Russia.
• Companies operating through third countries that may act as intermediaries to circumvent sanctions (the regulation expressly strengthens this point).
• Directors and compliance officers of any of the above entities, who may incur personal liability for non-compliance.

Practical example

A Spanish industrial machinery manufacturer has a supply contract with a distributor in Kazakhstan that, in turn, resells part of the equipment to customers in Russia. With Regulation (EU) 2026/506, this operation may fall within the scope of prohibitions if the goods are on the expanded lists, even though the Spanish company does not sell directly to Russia.

The strengthening of anti-evasion mechanisms requires this company to:

1. Verify whether the goods exported to Kazakhstan are on the new prohibition lists.
2. Include contractual clauses that expressly prohibit resale to Russia.
3. Perform due diligence on the final destination of the products.
4. Document the entire process to prove compliance in the event of an inspection.

Non-compliance, even if due to ignorance of the distribution chain, may result in administrative and criminal sanctions under Spanish legislation.

What should companies do now?

1. Review the updated lists of prohibited goods and services published in Regulation (EU) 2026/506 and compare them with the company's product and service catalogue.
2. Audit active contracts with Russian counterparties or with operators in third countries that may act as intermediaries to Russia.
3. Analyze the supply chain to identify indirect exposure through bridge countries (Central Asia, Caucasus, others).
4. Update due diligence procedures to include specific controls on the final destination of exported goods and services.
5. Include anti-evasion clauses in contracts with distributors and customers in third countries, expressly prohibiting resale or retransfer to Russia.
6. Train compliance, export and finance teams on the scope of new prohibitions and the risks of non-compliance.
7. Document all actions taken to prove compliance in the event of an inspection or investigation by the competent authorities.