EU Sanctions Against Russia 2026: What Companies with Links to Russia or Ukraine Must Verify

Key data

Companies with commercial or financial links to Russia or Ukraine have an active and continuous obligation: to verify that their counterparties are not included in the list of persons and entities sanctioned by the EU. The error correction published on 19 June 2026 rectifies Council Decision (CFSP) 2026/696, of 14 March 2026, which in turn modifies the sanctions regime in force since 2014 (Decision 2014/145/CFSP).

Although the corrections are technical in nature and affect the official text published in the Official Journal of the EU, their publication is the ideal time for affected companies to review their compliance. The sanctions regime has not changed in substance, but any modification of the official text may alter the interpretation of which persons or entities are included in the list.

What does this regulation establish?

The EU sanctions regime against Russia, in force since 2014, establishes two main types of restrictive measures:

• Travel bans: Persons included in the list cannot enter or transit through EU territory.
• Asset freezes: All funds and economic resources of listed persons and entities are blocked. No company or individual can make funds available to them, directly or indirectly.

Council Decision (CFSP) 2026/696, published on 14 March 2026, modified this base rule. The error correction published on 19 June 2026 rectifies technical errors in the official text of that decision, without altering the substance of the restrictive measures.

The list of sanctioned persons and entities is consulted and updated centrally on the EU Sanctions Map and in the consolidated list of EU sanctions.

Economic and operational impact

The impact for companies is not the technical correction itself, but the accumulated risk of operating with sanctioned counterparties without knowing it. The consequences of non-compliance are:

• Serious administrative sanctions: Fines that can reach very high amounts according to Spanish legislation implementing EU restrictive measures.
• Criminal liability: Deliberate or grossly negligent non-compliance can result in criminal liability for managers and executives.
• Blocking of operations: Financial entities are obliged to block any transaction with listed persons or entities, which can paralyze ongoing collections and payments.
• Reputational damage: Association with sanctioned entities can seriously affect the company's image with customers, suppliers and investors.

For financial entities, the compliance obligation is particularly strict: they must have automated screening systems that check their customers and beneficiaries in real time against the consolidated list of EU sanctions.

Who does it affect?

• Financial entities: Banks, savings banks, insurance companies, fund managers and any entity that processes payments or manages assets with Russian or Ukrainian counterparties.
• Exporters and importers: Companies that trade with Russia or territories under Russian influence, including operations through third countries.
• Companies with Russian subsidiaries, partners or suppliers: Any corporate or contractual relationship with Russian legal or natural persons or with links in Russia.
• Companies with operations in Ukraine: Those with assets, contracts or personnel in Ukraine must also verify that their counterparties are not listed.
• Advisors and consultants: Those providing services to companies with Russian links have an obligation to alert their clients about compliance with these measures.
• Carriers and logistics operators: Those operating routes with origin or destination in Russia or in affected territories.

Practical example

A Spanish industrial machinery company has a distributor in Russia with which it has been working since 2013. In 2024 it renewed the contract without checking whether the distribution company or its administrators were on the EU list of sanctioned entities.

Following the publication of Decision (CFSP) 2026/696 and its error correction, the legal department decides to conduct a review. When consulting the consolidated list of EU sanctions, it discovers that one of the majority partners of the Russian distributor was added to the list in 2025.

Result: the company must immediately halt any pending payments, notify its financial entity and consult with a compliance specialist to determine whether the contractual relationship can be maintained under any exception or must be terminated. Failure to detect this earlier already poses a risk of administrative sanctions.

What should companies do now?

1. Review the consolidated list of EU sanctions: Check all current counterparties (customers, suppliers, partners, distributors) against the updated list available on the EU Sanctions Map.
2. Update due diligence procedures: Incorporate sanctions verification as a mandatory step in the onboarding of new customers, suppliers and partners, especially if they have links to Russia or Ukraine.
3. Review existing contracts: Identify all active contracts with Russian or Ukrainian counterparties and verify whether they include clauses on compliance with international sanctions.
4. Alert the finance department: Ensure that pending or ongoing payments do not benefit listed persons or entities. Financial entities may block operations without prior notice.
5. Document compliance: Keep evidence of the verifications performed and their date, to be able to demonstrate due diligence in the event of a possible inspection.
6. Consult a specialist if in doubt: If there is any uncertainty about whether a counterparty is or could be sanctioned, consult with a lawyer specializing in compliance before continuing to operate.

Official source

Consult complete regulation in official source

Notice: 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_202690508