EU Sanctions Ukraine 2025: What Companies with Russian Partners Must Review

Key data

Spanish companies with international activity in the Russian or Belarusian environment have a regulatory compliance obligation that admits no errors: operating with an entity sanctioned by the EU, even unknowingly, can have criminal consequences for managers and economic consequences for the company.

The corrigendum published on 27 March 2026 adjusts the Council Decision (CFSP) 2025/1895 of 12 September 2025, which in turn amends the sanctions regime originally established in 2014 through Decision 2014/145/CFSP. These corrections may affect names, identifying data or reasons for inclusion in the lists of sanctioned persons and entities. Any change in that data requires companies to review their counterparty databases.

What does this regulation establish?

The EU's sanctions regime against actions that undermine Ukrainian sovereignty has been in force since 2014. Over the years, Decision 2014/145/CFSP has been amended multiple times to add, remove or update data on persons and entities included in the sanctions lists.

The Decision (CFSP) 2025/1895, adopted on 12 September 2025, introduced a new amendment to that regime. The corrigendum published now adjusts that decision in specific aspects that may include:

• Names or identifying data of natural persons included in the list
• Identifying data of legal entities subject to sanctions
• Reasons for inclusion in the sanctions list

Although a corrigendum may seem like a minor procedural matter, in the field of international sanctions it has direct consequences: if a name or identifier of an entity has been corrected, the compliance systems using the previous data may be outdated and generate false negatives in counterparty controls.

Economic and operational impact

The impact is not a rate or tariff figure: it is a regulatory compliance risk with economic and criminal consequences. Companies that do not update their counterparty controls following this corrigendum are exposed to:

• Administrative sanctions for operating with entities included in EU sanctions lists
• Criminal liability for company managers in case of deliberate or negligent non-compliance
• Blocking of operations and possible freezing of assets linked to affected transactions
• Reputational damage to clients, investors and financial entities

The operational cost of implementing or updating a counterparty control system is significantly lower than the cost of a sanctions penalty. Companies with recurring activity in Eastern European markets should treat this process as a continuous, not occasional, obligation.

Who does it affect?

This regulation directly affects:

• Exporting or importing companies with counterparties in Russia or Belarus
• Companies with commercial partners, distributors or agents of Russian or Belarusian origin
• Companies with activity in Eastern European markets where sanctioned entities may be involved
• Financial entities and insurers that finance or insure operations in those regions
• Advisors, consultancies and law firms managing international operations of clients with exposure to those markets
• CFOs and compliance officers responsible for counterparty controls

Practical example

A Spanish industrial machinery company has a distributor in Moscow with which it has been operating since 2019. In its compliance system, that distributor was verified in 2024 and did not appear on any sanctions list.

Decision (CFSP) 2025/1895 of September 2025 amends the sanctions list. The corrigendum published on 27 March 2026 adjusts the identifying data of several entities included in that decision. If the distributor of this company —or an entity linked to it— appears on the list with corrected data, the company's compliance system may not detect it if it has not updated its reference database.

The result: the company makes a transfer or delivery of goods to a sanctioned entity without knowing it. This constitutes a breach of EU restrictive measures, with the administrative and criminal consequences that entails. The solution is simple: launch a new verification of all active counterparties against the updated list following each publication in the Official Journal of the EU.

What should companies do now?

1. Update the sanctions lists database in the company's compliance system, incorporating the changes published in the corrigendum to Decision (CFSP) 2025/1895.
2. Relaunch verification of all active counterparties with exposure to Russia, Belarus or Eastern European markets against the updated list.
3. Review ongoing contracts and operations with partners in those regions to detect possible links with entities now correctly identified on the list.
4. Document the verification process with date and source used, to demonstrate due diligence in case of inspection or investigation.
5. Establish a periodic update protocol: each publication in the Official Journal of the EU that amends the sanctions lists should automatically trigger a new counterparty verification.
6. Consult with a legal advisor specializing in international trade if there is any doubt about whether a specific counterparty may be affected by the published corrections.