Key data
| Regulation | Council Decision (CFSP) 2026/1707, of July 13, 2026 |
|---|---|
| Modified rule | Council Decision (CFSP) 2024/2643 on restrictive measures against destabilizing activities of Russia |
| Publication | July 13, 2026 |
| Entry into force | July 13, 2026 (immediate effect) |
| Affected parties | Companies and individuals with commercial or financial links to sanctioned Russian entities |
| Category | European Regulation — Common Foreign and Security Policy (CFSP) |
| Transposition | No transposition required: direct effect in all Member States, including Spain |
| CELEX reference | 32026D1707 |
If your company has commercial, financial or contractual relationships with Russian entities or individuals, this regulation affects you today. Council Decision (CFSP) 2026/1707, published on July 13, 2026, amends the sanctions regime established in Council Decision (CFSP) 2024/2643 and expands the EU's restrictive measures against destabilizing activities attributed to Russia.
This is not a regulation that needs to be transposed or that Spain needs to develop: it has direct and immediate effect in all Member States. Operating with a counterparty listed in the updated lists may constitute a serious breach from day one.
What does this regulation establish?
Council Decision (CFSP) 2026/1707 amends Council Decision (CFSP) 2024/2643, which is the EU's specific sanctions framework for responding to destabilizing activities by Russia (political interference, sabotage operations, disinformation campaigns and other hybrid actions).
The restrictive measures contemplated by this sanctions regime are as follows:
- Asset freezing: the funds and economic resources of listed persons and entities are blocked. No company or individual may make funds or resources available to them.
- Travel bans: natural persons included in the list cannot enter or transit through EU territory.
- Restrictions on entities and natural persons: affects those linked to interference, sabotage or disinformation operations attributed to Russia.
This decision expands or updates the lists of persons and entities already existing under Council Decision (CFSP) 2024/2643. The EU Council periodically reviews and updates these lists; each update has immediate effect and obliges all economic operators to review their current relationships.
The consolidated and updated lists are available in the EU Official Register (EUR-Lex) and in the European Council sanctions database.
Economic and operational impact
The impact for companies is not theoretical: operating with a sanctioned entity or person may result in the immobilization of funds, the nullity of contracts and serious administrative sanctions imposed by the competent national authorities (in Spain, the State Secretariat for Economy and the Bank of Spain, depending on the type of operation).
The main operational effects are:
- Urgent review of counterparties: any contract, payment, transfer or active commercial relationship with Russian entities must be verified against the updated lists.
- Blocking of payments and transfers: banks and financial entities are obliged to block operations with listed entities. If your bank detects an operation with a sanctioned counterparty, it will block it automatically.
- Review of current contracts: contracts in progress with Russian counterparties may be suspended de facto if the counterparty is included in the list.
- Reputational and legal risk: non-compliance, even if unintentional, does not exempt from liability. Documented due diligence is the main defense against an inspection.
Who does it affect?
- Spanish and European companies with active commercial contracts with Russian entities (supply, distribution, licenses, services).
- Financial entities and banks that manage accounts, transfers or financing linked to Russian persons or companies.
- Importers and exporters with relationships with Russian counterparties, especially in industrial, energy or technology sectors.
- Advisors, consultancies and law firms that provide services to clients with Russian links (enhanced due diligence obligation).
- CFOs and financial directors responsible for validating international payments and relationships with foreign suppliers or customers.
- Any company that has partners, shareholders or beneficial owners of Russian nationality or with links to listed Russian entities.
Practical example
A Spanish industrial company has a component supply contract with a Russian company it has been working with since 2022. On July 13, 2026, the EU publishes Council Decision (CFSP) 2026/1707, which expands the list of sanctioned entities.
If that Russian supplier company appears in the updated list, the Spanish company cannot make any pending payments, nor receive goods, nor renew the contract from that same day. Its bank will block any transfer to that entity. If the Spanish company has not reviewed the list and executes a payment, it incurs a breach of the EU sanctions regime, regardless of whether it did so without knowledge.
The only valid defense is to prove that a consultation of the consolidated list was carried out before executing the operation and that the counterparty was not listed at that time. This is why periodic and documented review is essential.
What should companies do now?
- Immediately consult the updated consolidated list on the European Council sanctions portal and on EUR-Lex to verify whether any Russian counterparty appears on it.
- Review all active contracts with Russian entities or individuals: supply, distribution, services, licenses and any ongoing financial relationship.
- Preventively suspend any pending payment or transfer to Russian counterparties until confirming they are not listed.
- Document the review carried out: date of consultation, list used, result. This documentation is proof of due diligence in the event of a possible inspection.
- Implement a periodic screening procedure of counterparties against EU sanctions lists, given that these lists are updated frequently.
- Inform the company's legal and financial department so they can assess the impact on current contracts and the payment chain.
- Consult a specialist advisor in foreign trade or compliance if there is uncertainty about any specific relationship, especially if there are complex corporate structures with Russian participation.
Frequently asked questions
Where can I consult the updated list of entities and persons sanctioned by the EU in relation to Russia?
The consolidated list is available on the European Council sanctions portal and on EUR-Lex under CELEX reference 32026D1707. Council Decision (CFSP) 2026/1707 amends the previous list established in Council Decision (CFSP) 2024/2643. It is essential to always consult the most recent consolidated version, not the original regulation, as the lists are updated periodically.
When does this expansion of sanctions come into force and is there an adaptation period?
Council Decision (CFSP) 2026/1707 came into force on the same day of its publication: July 13, 2026. There is no adaptation period or need for transposition in Spain. The sanctions regime has direct and immediate effect in all EU Member States.
What happens if my company operates with a Russian entity that appears on the list without knowing it?
Lack of knowledge does not exempt from liability. If a company makes payments, transfers or maintains commercial relationships with a listed entity, it incurs a breach of the EU sanctions regime. The only defense is to prove that a consultation of the consolidated list was carried out before executing the operation and that the counterparty was not listed at that time. Therefore, documented and periodic review is essential.
What specific measures does this sanctions regime against Russia include?
The sanctions regime contemplates three types of measures: asset freezing (blocking of funds and economic resources of listed entities and persons), travel bans (natural persons included cannot enter or transit through the EU) and restrictions on entities or natural persons linked to interference, sabotage or disinformation operations attributed to Russia.
Do Spanish companies need to wait for Spain to transpose this regulation?
No. This decision has direct effect in all Member States, including Spain, without the need for transposition or national regulatory development. It is applicable from July 13, 2026 by all Spanish economic operators.
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:32026D1707