EU Sanctions Against Russia 2026: What Spanish Companies Must Do Now

Key data

Spanish companies with activities linked to Russia face an urgent problem. The Regulation (EU) 2026/1848, published and in force since 23 July 2026, amends Regulation 833/2014 — the central pillar of the EU's economic sanctions regime against Russia — and tightens compliance obligations for all European companies.

This is not a future warning: the regulation is applicable from the day of its publication. Any commercial, financial or contractual operation with Russian counterparties that does not comply with the new framework may result in violations with criminal and administrative consequences.

What does this regulation establish?

Regulation (EU) 2026/1848 amends Regulation (EU) No 833/2014, which is the central legal instrument for EU economic and commercial sanctions against Russia in the context of the conflict in Ukraine. The amendment acts on several axes:

• Expansion of restricted goods lists: The lists of products whose export or import to or from Russia are prohibited or subject to prior authorization are updated.
• Expansion of restricted services lists: The categories of services that European companies cannot provide to Russian entities or persons are extended.
• Update of sanctioned persons and entities: New natural and legal persons subject to restrictions (asset freezing, transaction prohibition) are incorporated.
• Strengthening of compliance obligations: Companies must strengthen their internal control procedures and conduct more thorough due diligence on their counterparties.

Economic and operational impact

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

• Ongoing contracts: Existing contracts with Russian counterparties must be reviewed to verify that the goods, services or agreed conditions are not now prohibited. If they are, the company must suspend execution.
• Supply chains: Companies that buy or sell through intermediaries must trace the origin and final destination of goods to avoid indirect evasion of sanctions.
• Financial relations: Transfers, payments or financial instruments linked to now-sanctioned entities or persons are blocked immediately.
• Compliance costs: Updating internal programmes, reviewing contracts and strengthened due diligence represent a direct operational cost, especially for SMEs with limited legal advisory resources.
• Sanction risk: Non-compliance may result in administrative and criminal sanctions in accordance with applicable Spanish law implementing the European sanctions regime.

Who does it affect?

This regulation affects any Spanish or European company with any link — direct or indirect — to Russia. Specifically:

• Exporting companies of goods or services to Russia or through third countries with final Russian destination.
• Importing companies of products of Russian origin or transiting through Russia.
• Financial entities with exposure to Russian counterparties: banks, funds, insurers, asset managers.
• Companies in the energy sector with supply, transport or distribution contracts linked to Russia.
• Companies in the technology sector that export software, hardware or components that may have dual use (civilian and military).
• Companies in the transport and logistics sector with routes including Russian territory or Russian counterparties.
• Any company with dual-use goods in its product catalogue.
• Advisors, consultancies and law firms providing services to clients with exposure to Russia.

Practical example

A Spanish technology company that exported electronic components to a distributor in a third country (for example, Turkey or Kazakhstan) with final destination to Russian customers must act immediately.

If those components are now included in the new restricted goods lists of Regulation 2026/1848, the company cannot claim ignorance of the final destination. The regulation requires strengthened due diligence on the distribution chain: if there are reasonable indications that the good will end up in Russia, the operation is prohibited even if the contract is formally with an intermediary in a third country.

Non-compliance — even involuntary — may result in administrative and criminal sanctions under applicable Spanish law. Reviewing the contract with the distributor and updating the compliance programme are immediate and unavoidable steps.

What should companies do now?

1. Immediately review the updated lists of goods, services, persons and sanctioned entities incorporated by Regulation 2026/1848, comparing them with the company's product catalogue and portfolio of clients and suppliers.
2. Audit existing contracts with Russian counterparties or with intermediaries operating in Russia: identify which operations may have become prohibited since 23 July 2026.
3. Preventively suspend any ongoing operation that may be affected until its legality is confirmed with specialized legal advice.
4. Update the internal compliance programme to incorporate the new strengthened due diligence criteria required by the regulation, including procedures for verifying counterparties and final destination of goods.
5. Train the team in procurement, sales, finance and operations on the new restrictions, especially in the energy, technology, transport and dual-use goods sectors.
6. Document all verifications carried out: in case of inspection or investigation, the company must be able to prove that it acted with the due diligence required by the regulation.

Official source

Consult full regulation at official source — EUR-Lex: Regulation (EU) 2026/1848

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=OJ:L_202601848