EU Sanctions Against Russia 2025: What Changes for Companies with Commercial Links

Key data

Companies with activities related to Russia cannot lower their guard: the Council Decision (CFSP) 2025/931, in force since 20 May 2025, maintains and reinforces the sanctions regime that the EU has applied against Russia since 2014. The error correction published on 29 June 2026 remedies material errors in the published text, but does not modify any of the substantive obligations.

The sanctions regime affects four major areas: financial transactions, exports of dual-use goods, Russian energy sector and defence sector. Any European company—or with presence in the EU—operating in any of these areas and having Russian counterparties must review its compliance position.

What does this regulation establish?

Decision (CFSP) 2025/931 amends Decision 2014/512/CFSP, which is the base instrument of the EU's restrictive measures regime against Russia, established in response to Russian actions destabilizing the situation in Ukraine.

The error correction published in June 2026 introduces no substantive changes: its function is exclusively to remedy material errors detected in the originally published text. This means that company obligations do not change, but the publication of this correction confirms the full and unambiguous validity of the corrected text.

The four pillars of the current sanctions regime are:

The base regulation, Decision 2014/512/CFSP, has been in force for more than a decade and has been amended numerous times to expand and tighten measures. Decision 2025/931 is one of those amendments, and this error correction ensures that the current text contains no ambiguities arising from formal errors.

Economic and operational impact

For affected companies, the impact is not new in terms of content, but the publication of this correction has clear operational consequences:

• Confirmation of legal basis: The correction eliminates any possible argument of textual ambiguity in the sanctions regime. Compliance departments must update their internal documentation with the corrected text.
• Risk of non-compliance: Non-compliance with the sanctions regime may result in administrative and criminal sanctions in Member States. In Spain, Law 12/2009 on the control of foreign trade in defence and dual-use material, together with criminal regulations, establishes serious consequences for violations.
• Four sectors in the spotlight: Finance, energy, defence and dual-use goods are the areas with the greatest exposure. Companies in these sectors must maintain updated counterparty verification processes.
• Impact on existing contracts: Any contract with Russian counterparties in the affected sectors must be reviewed to ensure it does not violate current restrictions.

Who does it affect?

• Financial entities (banks, insurance companies, fund managers) with exposure to Russian counterparties or assets
• Exporters of dual-use goods or technology destined for Russia or intermediaries that may re-export to Russia
• Energy companies with contracts, investments or joint projects in the Russian energy sector
• Defence sector companies or related industry with any link to Russian entities
• Importers and distributors that acquire products of Russian origin subject to restrictions
• Legal advisors, consultancies and audit firms that provide services to companies with exposure to Russia
• Investors and funds with holdings in companies or assets located in Russia

Practical example

A Spanish engineering company that supplied industrial components to a Russian customer before 2022 and maintains pending settlement contracts must verify, with the corrected text of Decision (CFSP) 2025/931, whether those components are classified as dual-use goods.

If the components fall into the category of dual-use goods—that is, with possible military or strategic application—the company cannot execute those contracts without express authorization from the competent Spanish authority (the State Secretariat for Trade). Doing so without such authorization exposes the company to administrative sanctions and, in serious cases, to criminal liability for its executives.

The error correction published in June 2026 opens no window for renegotiation nor modifies the restrictions: it simply consolidates the legal text applicable since 20 May 2025.

What should companies do now?

1. Update compliance documentation with the corrected text of Decision (CFSP) 2025/931, available on EUR-Lex, to eliminate any reference to the text with material errors.
2. Review the map of Russian counterparties: verify whether any entity or person with which you operate is included in the designated lists of the EU sanctions regime.
3. Audit existing contracts in the four affected areas (finance, energy, defence and dual-use goods) to detect possible violations of the sanctions regime.
4. Consult a specialist in foreign trade or regulatory compliance if there is any doubt about whether a specific operation is permitted or requires authorization.
5. Train procurement, sales and finance teams on the obligations of the sanctions regime, especially regarding dual-use goods and financial transactions with Russian counterparties.
6. Document all verifications performed: in case of inspection, the company must be able to prove that it acted with due diligence in complying with sanctions.

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:32025D0931R(01)