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

Key data

Spanish companies with international activity have a new urgent obligation: to verify that none of their commercial or financial counterparties appear on the updated lists by the Implementing Regulation (EU) 2026/1708, published and in force from July 13, 2026. This regulation implements Regulation (EU) 2024/1485 and expands EU restrictive measures against Russia, updating the lists of designated subjects.

This is not a regulation that requires transposition nor a future deadline: it enters into force on the same day of its publication and binds all economic operators in the EU without exception.

What does this regulation establish?

Regulation (EU) 2026/1708 is an implementing regulation, which means it develops and directly applies the measures already provided for in Regulation (EU) 2024/1485. Its central content is the update of the lists of natural and legal persons subject to two types of restrictive measures:

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

As a European regulation, it has direct effect and immediate application in Spain and the rest of the Member States from July 13, 2026, without the need for any national development regulation.

The regulation is part of the EU package of restrictive measures related to the situation in Russia, which has been progressively expanded through successive implementing regulations that update the lists of designated subjects.

Economic and operational impact

The impact is not only for large corporations with direct presence in Russia. Any company operating in international markets can be indirectly affected if any of its counterparties—suppliers, customers, intermediaries, partners—appear on the updated lists.

The main vectors of economic and operational risk are:

• Blocking of ongoing operations: contracts, payments or transfers with designated subjects must be interrupted immediately, with the operational and reputational cost that entails.
• Asset freezing: if a financial entity manages assets of persons or companies included in the list, it is obliged to immobilize them, which can generate claims and litigation.
• Serious administrative and criminal sanctions: non-compliance with restrictive measures can result in consequences in both the administrative and criminal spheres, according to Spanish regulations implementing the European sanctions regime.
• Cost of compliance review and update: companies must allocate resources to update their screening systems, control lists and internal due diligence procedures.

Who does it affect?

• Financial entities: banks, insurance companies, fund managers, payment entities and any financial intermediary with Russian clients or counterparties or with links to Russia.
• Exporting and importing companies: operators with supply chains that include suppliers, distributors or customers with connection to Russia.
• Companies with investments or subsidiaries in Russia: any corporate structure that involves economic relations with designated persons or entities.
• Law firms, consultancies and advisors: that provide services to clients with Russian links and may be indirectly channeling resources to sanctioned subjects.
• Logistics and transport operators: that manage goods or services linked to designated counterparties.
• Any natural or legal person in the EU that maintains commercial, financial or other relations with the new subjects included in the updated lists.

Practical example

A Spanish industrial machinery company maintains a supply contract with a Russian company that, following the publication of Regulation (EU) 2026/1708 on July 13, 2026, appears included in the updated list of designated subjects.

From that same day, the Spanish company is prohibited from executing any pending delivery, receiving payments from that counterparty or making any economic resources available to it. If the compliance department does not detect the designation in time and a transfer or delivery is made after July 13, the company incurs a breach of the European regulation, with the consequent risk of serious administrative and criminal sanctions.

The only way to avoid it is to have an updated screening system that automatically contrasts counterparties with the official lists published in the Official Journal of the European Union and alerts in real time to any new designation.

What should companies do now?

1. Immediately review the updated lists: access the full text of Regulation (EU) 2026/1708 on EUR-Lex and identify whether any of the newly designated natural or legal persons appear among the company's current counterparties.
2. Update screening systems and control lists: incorporate the newly designated subjects into compliance and due diligence systems, both in the financial and commercial areas.
3. Suspend any ongoing operations with designated subjects: immediately interrupt contracts, payments, transfers or pending deliveries with the new counterparties included in the list.
4. Review the regulatory compliance program: verify that internal procedures for controlling international sanctions are updated and sufficient to detect future designations in real time.
5. Document all actions taken: maintain a record of the verifications performed and the decisions adopted, as evidence of due diligence in the event of an inspection or investigation.
6. Consult with specialized legal advice: if there is any doubt about whether a counterparty is affected or how to manage ongoing contracts, consult a professional specialized in European sanctions law before acting.

Official source

Consult complete regulation in 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:32026R1708