Key data
| Regulation | Council Decision (CFSP) 2026/1845, of 23 July 2026 |
|---|---|
| Amends | Decision 2014/145/CFSP on restrictive measures concerning actions undermining the territorial integrity, sovereignty and independence of Ukraine |
| Publication | 23 July 2026 |
| Entry into force | 23 July 2026 (immediate effect) |
| Affected parties | Companies and financial entities with commercial links to Russia or occupied territories of Ukraine |
| Category | European Regulation — International sanctions |
| Official source | EU Official Journal — OJ:L_202601845 |
If your company operates with counterparties in Russia, Belarus or occupied territories of Ukraine, this update affects you from today. Council Decision (CFSP) 2026/1845, published on 23 July 2026 in the EU Official Journal, amends Decision 2014/145/CFSP and may involve the incorporation of new subjects to the sanctions list, the modification of identification data of persons already included or the adjustment of applicable measures. It is not a newly created rule: it is an update of the sanctions regime that has been in force since 2014 and is reviewed periodically.
Compliance is not optional. Operating with a sanctioned subject—even through lack of knowledge—exposes your company to serious legal consequences in any EU Member State.
What does this regulation establish?
Decision 2014/145/CFSP is the European framework for individual sanctions against natural and legal persons responsible for actions undermining the territorial integrity, sovereignty or independence of Ukraine. This regulation is updated periodically through amending decisions such as the present one.
The July 2026 update may incorporate any of the following modifications:
- Incorporation of new subjects (natural or legal persons) to the sanctions list.
- Modification of identification data of subjects already included (names, dates of birth, passports, addresses).
- Adjustment of restrictive measures applicable to certain subjects.
The restrictive measures established by the regime are of two types:
| Type of sanction | What it consists of | Who it applies to |
|---|---|---|
| Asset freezing | Prohibition of making available funds, financial assets or economic resources to listed subjects | Companies, financial entities, any legal or natural person in the EU |
| Travel ban | Denial of entry or transit through EU territory | Natural persons included in the list |
The full text with affected subjects and specific modifications is available in the official publication on EUR-Lex.
Economic and operational impact
The impact is not theoretical. The consequences of operating with a sanctioned subject are direct and can be very costly:
- Administrative sanctions: each Member State sets its own penalties for non-compliance with the sanctions regime. In Spain, Law 10/2021 on the control of foreign trade in defence and dual-use material establishes a sanctioning regime that can result in high-value fines.
- Criminal liability: non-compliance can constitute a criminal offense in some Member States, with consequences for company managers and executives.
- Blocking of operations: banks and financial entities are obliged to block any transaction with sanctioned subjects, which can paralyze collections, payments and credit lines linked to those counterparties.
- Reputational damage: appearance in investigations for non-compliance with international sanctions has a reputational cost that is difficult to quantify but real.
The cost of preventive review—updating counterparty screening processes—is always lower than the cost of a sanction or a blocked operation at the most inopportune moment.
Who does it affect?
- Financial entities: banks, insurance companies, fund managers and any entity that processes payments or manages assets with counterparties in Russia or occupied territories.
- Exporters and importers: companies that trade with Russia, Belarus or the occupied territories of Ukraine (Crimea, Donetsk, Luhansk, Zaporizhzhia, Kherson).
- Companies with subsidiaries or partners in the region: any business group with direct or indirect presence in the affected areas.
- Advisors and consultancies: law firms, business consultancies and tax advisors providing services to companies with links in the region.
- Logistics service providers: carriers, freight forwarders and logistics operators managing goods originating from or destined for sanctioned areas.
Practical example
A Spanish industrial machinery company has a distributor in Russia with which it has been operating since 2018. Following the update of the sanctions list on 23 July 2026, that distributor—or its legal representative—could have been incorporated into the list of Decision 2014/145/CFSP.
If the company does not perform an updated verification of its counterparty and processes a payment or sends merchandise, it would be in breach of the European sanctions regime from the very day of publication. The bank could block the transfer, and the company could face an administrative or criminal investigation.
The solution is simple but must be done systematically: verify the name of the distributor and its representatives in the official EU sanctions tool (EU Sanctions Map) before each relevant operation, and especially after each update to the list.
What should companies do now?
- Review the updated sanctions list: access the official publication on EUR-Lex (OJ:L_202601845) and identify whether any of your current counterparties—customers, suppliers, partners, representatives—appear on the modified list.
- Update screening processes: if you do not have an automated counterparty verification process against sanctions lists, implement it urgently. There are compliance tools that integrate official EU lists in real time.
- Preventively suspend ongoing operations: if there is reasonable doubt about whether a counterparty may be on the list, halt the operation until you confirm its status. It is preferable to delay a transaction than to incur non-compliance.
- Inform the legal and compliance department: communicate this update to the compliance team so they can assess the impact on existing contracts and planned operations.
- Document verifications performed: in case of inspection or investigation, the company must be able to prove that it performed the relevant checks. Keep dated records of each verification.
- Consult with a specialized advisor: if your company has significant exposure to Russia or occupied territories, request a compliance review from a law firm specializing in international sanctions.
Frequently asked questions
Where can I consult the updated list of persons and entities sanctioned by the EU in relation to Ukraine?
The complete and updated list is available on the EU Sanctions Map and in the EU Official Journal (OJ:L_202601845). After each update such as that of 23 July 2026, the consolidated list is automatically updated in these official sources.
What specific sanctions does the EU apply to persons included in the list of Decision 2014/145/CFSP?
The restrictive measures are of two types: asset freezing (prohibition of making available funds or economic resources to listed subjects) and travel ban to the EU (denial of entry or transit through the territory of Member States). Both measures apply immediately from the date of publication of each update.
What happens to my company if it operates with a sanctioned subject without knowing it?
Lack of knowledge does not exempt from liability. European companies are obliged to verify that their counterparties do not appear on sanctions lists before each operation. Non-compliance can result in administrative and criminal sanctions in each Member State, in addition to blocking of operations by the financial entities involved.
From when is it mandatory to comply with this sanctions update?
Council Decision (CFSP) 2026/1845 entered into force on the same day as its publication: 23 July 2026. There is no adaptation period. Obligations are enforceable from that date for all companies and financial entities established in the EU.
Does this regulation affect only companies that export to Russia, or also those that have Russian partners or suppliers?
It affects any commercial or financial relationship with subjects included in the list, regardless of its nature. This includes exports, imports, service contracts, distribution agreements, shareholdings and any transfer of funds or assets. Financial entities that process payments related to sanctioned subjects are also directly affected.
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=OJ:L_202601845