EU Sanctions Against Russia: Technical Correction Affecting Companies with Commercial Links

Key data

Spanish companies with operations in Russia or with Russian counterparties cannot ignore this correction. The Council Decision (CFSP) 2024/1484, adopted on 27 May 2024, establishes restrictive measures against Russia in the context of the conflict in Ukraine. The correction of errors published on 26 June 2026 amends the original text with technical-legal clarifications that affect the coherence and application of the sanctions regime.

The message for compliance, finance and foreign trade departments is clear: a "technical" correction is not harmless. If it modifies the identification of a sanctioned person or entity, it can change who is or is not on the list. Operating with a sanctioned counterparty—even by mistake—exposes the company to serious sanctions.

What does this regulation establish?

The correction of errors amends Council Decision (CFSP) 2024/1484. The modifications are of a technical-legal nature: they aim to ensure the accuracy and coherence of the original regulatory text, not to expand or reduce the scope of the underlying sanctions.

The restrictive measures regulated by this Decision include two main types:

• Asset freezing: the funds and economic resources of designated persons and entities are blocked. No company may make funds or economic resources available to them, directly or indirectly.
• Travel bans: natural persons included on the list cannot enter or transit through the territory of EU Member States.

The technical correction may affect identifying data of listed subjects (names, dates of birth, nationalities, passport numbers or other identification data). Although the text of the correction does not expand the number of sanctioned parties, it may modify the way they are identified, which has direct implications for counterparty screening systems.

Economic and operational impact

The impact is not theoretical. Companies operating with Russian counterparties—directly or indirectly—assume a real risk if they do not update their verification processes following each correction or modification of the sanctions regime.

The main vectors of economic and operational risk are:

• Blocking of payments and collections: if a counterparty appears on the list of sanctioned entities, any financial transaction is automatically blocked by banking entities.
• Immobilization of goods: exporters and importers may see their shipments held in customs if the recipient or sender is sanctioned.
• Administrative and criminal sanctions: non-compliance with the EU sanctions regime can result in high fines, disqualifications and, in serious cases, criminal liability for directors.
• Reputational damage: operating with sanctioned entities, even involuntarily, can compromise relationships with correspondent banks and international business partners.

Financial entities have especially strict obligations: they must apply enhanced due diligence measures and block any transaction involving designated persons or entities.

Who does it affect?

• Financial entities (banks, savings banks, payment entities, asset managers) with Russian clients or counterparties or with assets linked to Russia.
• Spanish exporters who sell products or services to buyers in Russia or to intermediaries operating with Russia.
• Spanish importers who purchase goods or raw materials of Russian origin or from companies with Russian links.
• Companies with subsidiaries, joint ventures or shareholdings in entities based or operating in Russia.
• Advisors, consultants and lawyers who provide services to designated Russian persons or entities.
• Carriers and logistics operators who manage goods with origin or destination in Russia.
• Compliance departments of any company with direct or indirect exposure to Russia.

Practical example

A Spanish industrial machinery company has a supply contract with a Russian company with which it has been operating since 2022. Following the publication of the technical correction of Decision (CFSP) 2024/1484, the compliance department conducts a new verification in the EU sanctions tool and detects that the identifying data of its counterparty have been updated on the consolidated list.

If the company had not reviewed the list following the correction, it could have processed a payment to an entity whose identification had changed on the sanctions list. The correspondent bank would have blocked the transfer, generating a contractual breach and exposing the company to an investigation by the competent authorities. Proactive review avoids this scenario and protects both the company's cash flow and reputation.

What should companies do now?

1. Review the consolidated EU sanctions list: access the official EU sanctions tool (Sanctions Map) and verify whether any current counterparty appears on the updated list following the correction.
2. Update screening systems: ensure that the counterparty verification tools used by the compliance department incorporate the corrected version of the Decision (CFSP) 2024/1484 list.
3. Review contracts and ongoing operations: identify all active contracts with Russian parties or with exposure to Russia and verify that no counterparty is designated on the updated list.
4. Inform the finance department and banking entity: communicate the regulatory update to those responsible for international payments so they apply the corresponding controls before processing any transfer related to Russia.
5. Document the verification process: record the checks performed and their results. In case of inspection, documentation of due diligence is the main defense against administrative sanctions.
6. Consult with specialized legal advisor: if there is any doubt about whether a counterparty or a specific operation is affected by sanctions, consult with a lawyer specializing in foreign trade and international sanctions before proceeding.

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=OJ:L_202690524