EU Sanctions Against Ukraine 2026: What Companies and Banks Must Do

Key data

If your company operates with Russian, Belarusian or any other jurisdiction counterparties linked to the conflict in Ukraine, this regulation requires you to act today. The Council Implementing Regulation (EU) 2026/2281, published and in force since October 12, 2026, expands the list of natural and legal persons subject to restrictive measures under Regulation (EU) No 269/2014. There is no adaptation period: the obligation to comply is immediate from the date of publication.

What does this regulation establish?

Council Implementing Regulation (EU) 2026/2281 updates the EU sanctions regime against those who threaten the territorial integrity, sovereignty and independence of Ukraine. It applies on the basis of Regulation (EU) No 269/2014, which is the reference European sanctions framework for this conflict.

The concrete measures it establishes are two:

• Asset freezing: all funds and economic resources in EU territory belonging to listed persons and entities are blocked immediately.
• Prohibition on making funds available: no entity or person in the EU can transfer, pay, assign or facilitate in any way economic resources to the listed parties.

The regulation expands or modifies the existing list of sanctioned parties, which means it can include both new additions and changes to existing entries. To know the complete updated list, it is essential to consult the annex of the regulation in the official source of the Official Journal of the EU.

Economic and operational impact

The impact is not only legal: it is operational and economic of the first order for any company with exposure to the affected jurisdictions.

• Immediate compliance costs: financial institutions must update their counterparty screening systems and lists of sanctioned persons without delay. This involves technological costs, compliance personnel and, in many cases, external legal advice.
• Immediate cessation of transactions: companies with active commercial relationships with any newly listed person or entity must halt payments, deliveries and any provision of services immediately, without waiting for judicial or administrative resolution.
• Risk of personal liability for directors: non-compliance affects not only the company as a legal entity. Directors and administrators can incur administrative and criminal liability personally if they do not adopt the necessary measures.
• Blocking of assets in the EU: if the company has assets of third parties listed under its custody or management, it is obliged to block them and notify the competent authorities.

Who does it affect?

• Financial institutions and banks: obligation to update lists of sanctioned persons in their compliance systems (AML/KYC) and block any transaction with newly listed parties.
• Companies with commercial relationships with sanctioned parties: any Spanish or European company that has contracts, pending payments or supply relationships with persons or entities included in the list must cease all activity immediately.
• Asset managers and investment funds: if they manage assets belonging to sanctioned parties, they must proceed to freeze them and communicate to the authorities.
• Logistics, transport and international trade companies: especially those operating routes or having clients in jurisdictions affected by the conflict.
• Legal advisors, consultancies and audit firms: that provide services to potentially listed entities must verify the status of their clients.
• Listed natural persons: directly affected by the freezing of their assets in EU territory.

Practical example

A Spanish industrial machinery company has an active supply contract with a Russian company. On October 12, 2026, that Russian company appears in the annex of Regulation 2026/2281 as a sanctioned entity.

From that same day, the Spanish company is prohibited from:

• Making any shipment of pending merchandise.
• Collecting invoices issued if this involves receiving funds from the sanctioned entity (this situation requires specific legal consultation on the exceptions regime).
• Renewing or expanding the contract.

The general director and CFO of the Spanish company can be held personally liable if, knowing of the listing, they authorize or allow operations to continue. The company must document the moment it became aware of the sanction and the immediate actions taken.

What should companies do now?

1. Access the annex of Regulation 2026/2281 today and verify if any of your current counterparties appear on the updated list of sanctioned parties.
2. Immediately halt any transaction with newly listed entities or persons: payments, shipments, provision of services and any making available of funds or resources.
3. Update compliance and screening systems (especially in financial entities) to incorporate the new list of sanctioned parties in AML/KYC controls.
4. Block and notify assets if your company holds or manages funds or resources of listed persons, communicate it to the competent authority in Spain (State Secretariat for Economy or Bank of Spain, as appropriate).
5. Document all actions taken with date and time: this is key to demonstrating due diligence in case of subsequent inspection or investigation.
6. Consult with specialized legal advice if you have ongoing contracts, pending payments or complex situations that require analysis of exceptions or authorizations.

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=CELEX:32026R2281