EU Sanctions Against Taliban Regime 2026: What Companies and Banks Must Do

Key data

If your company operates in foreign trade with Afghanistan, or if your financial entity maintains accounts, transfers or relationships with counterparties in that region, this update affects you directly. The Commission Implementing Regulation (EU) 2026/2138, published on 23 September 2026, amends the annex to Regulation (EU) No 753/2011 and expands the list of designated persons subject to asset freezing and prohibition of entry to the EU.

The regulation entered into force on the same day of its adoption, 22 September 2026, which means that any commercial or financial relationship with the newly designated persons is illegal from that date.

What does this regulation establish?

Commission Implementing Regulation (EU) 2026/2138 applies Article 11, paragraph 4, of Regulation (EU) No 753/2011, the EU sanctions framework against certain persons and entities linked to the situation in Afghanistan. The update amends the annex to that regulation, incorporating new persons, groups, companies and entities to the list of designated persons.

The restrictive measures applied to all those included in the list are as follows:

• Asset freezing: all funds and economic resources belonging to the designated persons, or in their possession or under their control, must be immobilized. No European company or financial entity may make funds available to them.
• Prohibition of travel to the EU: natural persons included in the list cannot enter or transit through the territory of the Member States of the European Union.

This regulation is part of the sanctions regime that the EU has maintained since 2011 against certain actors linked to the Taliban regime and groups related to the security situation in Afghanistan. Each update of the annex expands or modifies the list of designated persons, requiring all European operators to review their relationships.

Economic and operational impact

The direct impact of this update is operational and immediate: any company or financial entity that does not update its screening lists before operating with Afghan counterparties incurs legal risk from 22 September 2026.

The economic consequences of non-compliance can be severe:

• Administrative sanctions imposed by the competent authorities of each Member State (in Spain, the State Secretariat for Economy and the Bank of Spain, depending on the type of entity).
• Criminal sanctions for those responsible for the company or financial entity, depending on applicable national legislation.
• Blocking of ongoing operations if a relationship with a designated person is detected: transfers must be stopped and assets frozen immediately.
• Reputational damage and possible regulatory investigations that may paralyze the company's international activity.

The cost of updating compliance systems is significantly lower than the risk of a sanction. Financial entities with automated screening programs must incorporate the new list into their databases urgently.

Who does it affect?

• Financial institutions: banks, payment entities, fund managers and any entity that processes international transfers or maintains accounts with Afghan counterparties.
• Exporting and importing companies: foreign trade operators with activity in Afghanistan or with supply chains passing through the region.
• Companies with subsidiaries or business partners in Afghanistan: any entity with active contractual relationships in the country.
• Advisors and consulting firms: firms providing services to clients with exposure to Afghanistan must verify that their clients are not affected by the new designations.
• Compliance and legal departments: responsible for updating screening systems and communicating the change to business areas.

Practical example

Imagine a Spanish foreign trade company that exports agricultural machinery and has a distributor in Kabul with which it has been operating for three years. On 22 September 2026, Regulation (EU) 2026/2138 enters into force and that distributor—or one of its partners—appears in the new updated annex of designated persons.

From that moment, the Spanish company cannot execute any pending payment to that distributor, nor send the contracted goods, nor maintain the commercial relationship without incurring a breach of the European sanctions regime. If the company's bank detects the transfer in its screening system and blocks it, the company may also face an investigation by the competent authorities.

The only way to avoid this situation is to have updated the counterparty verification system before executing any operation after 22 September 2026.

What should companies do now?

1. Access the official text of Regulation (EU) 2026/2138 and download the updated annex with the complete list of designated persons, groups, companies and entities.
2. Update counterparty screening systems with the new list, both in automated systems and in manual verification processes.
3. Review all active commercial and financial relationships with counterparties in Afghanistan or with ties to the region to detect possible matches with the newly designated persons.
4. Block immediately any pending operations with counterparties that appear in the updated list and notify the competent authorities according to the procedure established in each Member State.
5. Communicate the change internally to sales, treasury, operations teams and any area that manages relationships with international counterparties.
6. Document the verification process to demonstrate to the authorities that the company has acted with due diligence since the regulation entered into force (22 September 2026).

Official source

Consult complete regulation at 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_202602138