EU Sanctions Against Russia: Technical Correction You Must Verify If You Operate With Russian Entities

Key data

If your company has any commercial, financial or service relationship with Russia or Russian entities, this correction requires you to take action. The Council Regulation (EU) 2024/1485, published on 27 May 2024, establishes the framework of restrictive measures currently in force against Russia. The error correction published on 26 June 2026 introduces adjustments of a technical or formal nature, without modifying the material scope of the sanctions, but which may affect the wording of lists of persons, entities or assets subject to restrictions.

Compliance with European sanctions is not optional: it is a legal obligation for all operators established in the EU, regardless of their size or sector.

What does this regulation establish?

The error correction published under reference OJ:L_202690523 affects Regulation (EU) 2024/1485, which is the main legal instrument through which the EU Council imposes restrictive measures related to the situation in Russia.

The key aspects of this correction are as follows:

• Nature of changes: The corrections are of a technical or formal nature. They do not expand or reduce the material scope of sanctions already in force.
• Possible impact on lists: The corrections may affect the wording of lists of natural persons, legal entities or categories of assets subject to restrictions. It is essential to review the updated consolidated text.
• Mandatory nature: Compliance is mandatory for all economic operators established in the EU, without exception based on size or sector.
• Consequences of non-compliance: Non-compliance with EU sanctions against Russia may result in serious criminal and administrative consequences, according to the legislation of each Member State.

The correction does not introduce new sanctions or eliminate existing ones, but requires you to always work with the most recent consolidated text to ensure that the lists your company uses are up to date.

Economic and operational impact

Although the correction is technical, its operational impact for affected companies is real and immediate:

• Risk of unintentional non-compliance: If your company works with outdated lists of sanctioned entities, it may be operating in violation of sanctions without knowing it. This is especially critical in payment operations, exports, service provision or financial relationships with Russian counterparties.
• Cost of review and compliance: Companies with exposure to Russia must allocate resources to review their counterparty screening processes, update their internal databases and, if necessary, consult with specialists in international sanctions.
• Criminal and administrative consequences: The text expressly warns of serious criminal and administrative consequences in case of non-compliance. In Spain, violations of international sanctions can result in very high fines and, in serious cases, criminal liability for company managers.
• Impact on due diligence: Any M&A operation, financing or contracting involving parties with Russian links requires enhanced review in light of the updated consolidated text.

Who does it affect?

• Export or import companies with operations in Russia or with Russian counterparties.
• Financial entities (banks, asset managers, insurers) with exposure to Russian assets or clients.
• Logistics and transport companies with routes or clients linked to Russia.
• Professional service providers (consulting, legal, accounting) with Russian clients.
• Technology companies that supply software, hardware or digital services destined for Russia.
• Any operator established in the EU that maintains commercial, financial or contractual relationships with Russian natural or legal persons included in sanctions lists.
• Compliance, legal and finance departments of multinational groups with subsidiaries or suppliers in Russia.

Practical example

Imagine a Spanish industrial machinery company that maintains a supply contract with a Russian company. Its compliance department conducts periodic reviews of counterparties against EU sanctions lists. Following the publication of this error correction on 26 June 2026, the legal team must:

1. Access the updated consolidated text of Regulation (EU) 2024/1485 on EUR-Lex to verify whether the correction has modified the wording of any relevant list.
2. Check whether the Russian entity with which it operates appears or could be affected by any change in the description of restricted persons or entities.
3. Document the review carried out and the conclusion reached, as evidence of due diligence in case of inspection.

If the company omits this review and, due to an error in the previous text, the Russian counterparty was incorrectly identified in the lists, it could have been operating in non-compliance without knowing it. The technical correction may be precisely the one that remedies that incorrect identification, making the restriction now unequivocal.

What should companies do now?

1. Access the updated consolidated text: Consult Regulation (EU) 2024/1485 in its most recent consolidated version on EUR-Lex to identify exactly what has changed with this correction.
2. Review the lists of restricted persons and entities: Check whether any of your current or potential Russian counterparties appear in the updated lists or whether their description has been modified by the correction.
3. Update internal screening systems: If your company uses compliance tools or sanctions databases, verify that they are synchronized with the most recent version of the regulation.
4. Document the review: Keep written record that verification has been carried out following the publication of the correction. This documentation is key in case of inspection or investigation.
5. Consult with a specialist in international sanctions: If you have doubts about whether any specific operation may be affected, do not wait: the criminal and administrative consequences of non-compliance are serious and liability can reach company managers.
6. Establish regulatory alerts: Set up a system to track changes to Regulation (EU) 2024/1485 so you do not miss future corrections or amendments.

Official source

Consult full regulation on 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_202690523