EU Sanctions Against Russia 2026: What Companies Must Do

Key data

As of 14 March 2026, operating with certain persons or entities linked to the Ukraine conflict may result in criminal sanctions. The Council Implementing Regulation (EU) 2026/695 expands the list of designated persons under Regulation (EU) No 269/2014, the European framework for restrictive measures related to Ukraine. The regulation is directly applicable in Spain from its date of publication: it requires no transposition and there is no adaptation period.

If your company exports, has suppliers, customers or financial counterparties with links in Russia or Ukraine, this regulation requires you to act today.

What does this regulation establish?

Council Implementing Regulation (EU) 2026/695 applies the sanctions framework of Regulation (EU) No 269/2014, which allows the EU to adopt restrictive measures against persons and entities that undermine or threaten the territorial integrity, sovereignty and independence of Ukraine.

The specific measures it imposes on the newly designated persons are:

• Asset freezing: all funds and economic resources belonging to the persons and entities included in the expanded list are blocked. No European company or financial entity may make them available to them.
• Prohibition of travel to the EU: natural persons designated cannot enter or transit through the territory of the European Union.

The expansion of the list is the central action of this regulation. The text does not modify the general conditions of the sanctions regime under Regulation 269/2014, but rather incorporates new names and entities into the existing list of designated persons.

Economic and operational impact

The impact is not merely reputational: non-compliance with EU sanctions has direct economic and criminal consequences in Spain.

• Criminal sanctions: operating with sanctioned persons or entities may constitute a crime under Spanish legislation implementing international sanctions.
• Serious administrative sanctions: competent authorities may impose fines and other administrative measures on companies that fail to comply with asset freezing obligations or maintain prohibited relations with designated persons.
• Immediate operational cost: companies must invest in updating their compliance systems and sanctions control lists. For financial entities, exporters and companies with exposure to Russia or Ukraine, this process must be completed without delay from 14 March 2026.
• Risk of transaction blocking: any transfer of funds, payment, delivery of goods or provision of services to a designated person is automatically blocked. Lack of knowledge does not exempt from liability.

Who does it affect?

The compliance obligation is universal for all economic operators established in the EU, but the real risk is concentrated in:

• Financial entities: banks, insurance companies, fund managers and any entity that processes payments or manages assets with counterparties in Russia or Ukraine.
• Exporters and importers: companies that trade in goods, technology or services to or from Russia, or with entities with links in those countries.
• Companies with subsidiaries, partners or suppliers in Russia or Ukraine: any active contractual relationship must be verified against the updated list of designated persons.
• Advisors and consultants: law firms, consulting firms and tax advisors providing services to clients with exposure to these jurisdictions.
• CFOs and compliance officers: responsible for ensuring that internal sanctions control systems are updated and operational.

Practical example

A Spanish industrial machinery company has a distributor in Russia with which it maintains an active supply contract. On 14 March 2026, Council Implementing Regulation (EU) 2026/695 enters into force, expanding the list of sanctioned persons.

If that distributor, or any of its partners or executives, is among the newly designated persons, the Spanish company is prohibited from:

• Sending any pending merchandise for delivery.
• Collecting outstanding invoices if this means making funds available to the sanctioned person.
• Renewing or executing the contract in any form.

If the company has not updated its sanctions control list and executes a delivery or collection without verification, it incurs non-compliance with Regulation (EU) No 269/2014, with risk of serious criminal and administrative sanctions in Spain. The key is that the obligation to verify is prior to any transaction, not subsequent.

What should companies do now?

1. Immediately update sanctions control lists: incorporate the expanded list from Council Implementing Regulation (EU) 2026/695 into your screening systems. The compliance date is 14 March 2026.
2. Review all active counterparties with links in Russia or Ukraine: customers, suppliers, distributors, partners and ultimate beneficiaries must be verified against the new list of designated persons.
3. Preventively suspend any pending transactions with unverified counterparties: do not execute payments, deliveries or services until you confirm that the counterparty is not on the list.
4. Review existing contracts: identify sanctions compliance clauses and activate suspension or termination mechanisms if appropriate.
5. Train your compliance team and commercial managers: ensure that those managing relations with Russia or Ukraine understand the new obligations and know how to act when an alert is triggered.
6. Document the verification process: in case of inspection or investigation, documentation of the controls performed is the main defense against administrative or criminal sanctions.
7. Consult with a legal advisor specializing in international sanctions if you have doubts about your company's specific exposure or how to manage ongoing contracts with affected counterparties.

Official source

Council Implementing Regulation (EU) 2026/695 of 14 March 2026

Disclaimer: This article provides general information about Council Implementing Regulation (EU) 2026/695 and is not legal advice. The content is for informational purposes only and does not constitute professional legal or compliance advice. Companies must consult with qualified legal advisors specializing in international sanctions to assess their specific situation and obligations. The author and publisher assume no liability for the use or misuse of this information or for any damages arising from reliance on this content. Compliance with EU sanctions is the sole responsibility of each economic operator.