EU Sanctions Against Russia 2025: What Companies with Russian Commercial Links Must Review

Key data

Companies with commercial or financial links to Russia should be aware that the EU sanctions regime in force since 2014 has just received a formal errata correction. The Council Decision (CFSP) 2025/1495, adopted on 18 July 2025 and which amended Decision 2014/512/CFSP, has been subject to an error correction published in the EU Official Journal with reference OJ:L_202690620.

The correction is formal in nature: it introduces no substantive changes to the applicable restrictive measures. However, from a regulatory compliance perspective, legal and compliance teams must always work with the consolidated and corrected version of the text, not with earlier versions that may contain the errata.

What does this regulation establish?

The EU sanctions regime against Russia, in force since 2014 and successively strengthened, establishes three main types of restrictive measures:

The Decision 2025/1495 amended the parent regulation (Decision 2014/512/CFSP) in July 2025. The error correction now published corrects drafting errata in that amending text, without altering the content of the prohibitions or the lists of sanctioned persons and entities.

The lists of persons and entities subject to asset freezes and entry bans are published and continuously updated on the EU Sanctions Map and in the consolidated text of Decision 2014/512/CFSP on EUR-Lex.

Economic and operational impact

Although this correction does not modify the substantive measures, it has direct operational consequences for compliance teams:

• Reference version: Internal compliance procedures must be updated to reference the corrected version of the text, not the original version with errata.
• Non-compliance risk: Working with erroneous texts can generate incorrect interpretations of obligations, with legal consequences in Spain in both administrative and criminal proceedings.
• Review cost: Legal and compliance departments must dedicate time to verify that their risk matrices and counterparty screening procedures are aligned with the corrected text.
• No change in sanctions scope: The lists of sanctioned entities and persons, restricted sectors and trade prohibitions do not vary from what was established by the original Decision 2025/1495.

Non-compliance with the EU sanctions regime against Russia in Spain can result in administrative and criminal sanctions, according to Spanish regulations for the application of international restrictive measures. Risks include fines, disqualification and criminal liability of company directors.

Who does it affect?

• Export or import companies with operations in Russia or with Russian counterparties in any sector.
• Financial entities and banks that manage accounts, transfers or financing linked to Russian persons or entities.
• Service companies (consulting, logistics, technology, energy) that provide services to Russian clients or partners.
• Compliance and legal departments of any company with exposure to Russia, required to keep their procedures updated.
• CFOs and financial directors who oversee operations with counterparties in Russia or in territories under Russian control.
• Legal advisors and consultants who provide services to companies with Russian links.
• Natural persons included or potentially included in the EU sanctions lists.

Practical example

A Spanish logistics company in the industrial machinery sector has among its clients a Russian company not included in the sanctions lists. Its compliance department works with a downloaded copy of Decision 2025/1495 in its original version, published on 19 July 2025.

Following the publication of this error correction, the reference text has formally changed. If in an inspection or compliance audit it is detected that internal procedures cite or are based on the version with errata, the company could face questions about the robustness of its compliance program. The correct action is to download the corrected version from EUR-Lex, update internal documentation and record the change in the legal department's regulatory version register.

This type of update, although it does not involve substantive changes, is part of good practices in sanctions risk management required by supervisory bodies and external auditors.

What should companies do now?

1. Download the corrected version of Decision (CFSP) 2025/1495 from EUR-Lex and replace any earlier version in regulatory compliance files.
2. Verify internal compliance procedures to ensure they reference the corrected text and not the original version with errata.
3. Review updated sanctions lists on the EU Sanctions Map to confirm that no Russian counterparty has been recently added.
4. Update risk matrices and customer and supplier screening procedures with exposure to Russia.
5. Inform operational teams (sales, finance, logistics) that the reference text has been corrected, although substantive measures do not change.
6. Consult with specialized legal advisors if there is any doubt about the specific application of restrictive measures to specific operations, as non-compliance can result in administrative and criminal sanctions in Spain.

Official source

View 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=OJ:L_202690620