Key data
| Regulation | Council Decision (CFSP) 2026/1939, of August 7, 2026 |
|---|---|
| Modified regulation | Decision 2014/145/CFSP (sanctioning framework in force since the annexation of Crimea) |
| Publication | August 7, 2026 |
| Entry into force | August 7, 2026 (immediate effect) |
| Affected parties | Companies and individuals with commercial or financial links with Russia or sanctioned entities |
| Applied measures | Asset freezing and prohibition from traveling to the Schengen area |
| Legal framework in Spain | Law 10/2021 (criminal and administrative liability for non-compliance) |
| Category | European Regulation — Restrictive sanctions |
| CELEX reference | 32026D1939 |
If your company operates with Russian counterparties, exports to markets linked with Russia, or manages assets of persons with Russian nationality or residence, this decision affects you from today. Decision (CFSP) 2026/1939, published on August 7, 2026, modifies the European sanctioning framework in force since 2014 and adds new designees to the EU's consolidated list.
This is not a warning: non-compliance with these sanctions has criminal and administrative consequences in Spain, regulated by Law 10/2021. The obligation to verify and act is immediate.
What does this regulation establish?
Decision 2026/1939 modifies Decision 2014/145/CFSP, the sanctioning framework that the EU established following Russia's illegal annexation of Crimea. Since then, this framework has been updated periodically to add or modify the list of natural and legal persons subject to restrictive measures.
The two restrictive measures that apply to all designees on the list are:
- Asset freezing: all funds and economic resources belonging to the designees, or in their possession or under their control, must be immobilized. No company or entity may make funds available to them.
- Prohibition from traveling to the Schengen area: designees cannot enter or transit through the territory of EU Member States.
The August 2026 update incorporates new natural and legal persons to this list because their actions undermine or threaten the territorial integrity, sovereignty and independence of Ukraine.
| Aspect | Decision 2014/145/CFSP (original) | Decision 2026/1939 (modification) |
|---|---|---|
| Scope | Initial sanctioning framework following Crimea annexation | Same framework, expanded list of designees |
| Measures | Asset freezing + Schengen travel prohibition | Identical measures, new affected subjects |
| Validity | Since 2014, with periodic updates | Immediate effect from August 7, 2026 |
| Liability in Spain | Law 10/2021 | Law 10/2021 (no changes to the sanctioning regime) |
Economic and operational impact
The direct impact for Spanish companies is not a fee or fixed cost: it is the risk of incurring criminal and administrative liability for maintaining relationships with the newly designated parties. Law 10/2021 establishes that non-compliance with EU sanctions can result in criminal and administrative sanctions for the company and its directors.
Real operational costs are concentrated in three areas:
- Review and update of compliance systems: compliance departments must incorporate the new consolidated list into their counterparty screening tools.
- Audit of active commercial and financial relationships: active contracts, pending payments, credit lines or any relationship with entities that may be linked to the newly designated parties.
- Immediate suspension of operations: if a sanctioned counterparty is detected, the company is obligated to freeze the relationship immediately, which may generate costs from contract termination or loss of business.
For financial operators (banks, insurance companies, asset managers, payment entities), the obligation is especially critical: they must block any transaction with the newly designated parties and notify the competent authorities.
Who does it affect?
- Financial operators: banks, savings banks, credit entities, insurance companies, fund managers and payment entities with Russian clients or counterparties.
- Exporters and importers: companies with commercial activity to or from Russia, Belarus or territories controlled by Russia.
- Companies with international activity that maintain contracts, joint ventures or supply relationships with Russian entities or subsidiaries of sanctioned groups.
- Advisors, consultancies and law firms that provide services to natural or legal persons that may be on the list.
- CFOs and financial directors responsible for overseeing sanctions compliance in their organizations.
- Compliance and legal departments of any company with exposure to Eastern European markets.
Practical example
A Spanish industrial machinery company maintains an active supply contract with a Russian company. On August 7, 2026, the EU publishes Decision 2026/1939 and that Russian company —or its majority owner— appears on the new list of designees.
From that same day, the Spanish company has the legal obligation to:
- Suspend any pending delivery, payment or service provision.
- Freeze any funds that the Russian company has in its possession or under its control.
- Notify the situation to the Spanish competent authorities.
- Document all actions taken to demonstrate compliance.
If the Spanish company continues to execute the contract without verifying the updated list, it incurs criminal and administrative liability in accordance with Law 10/2021, regardless of whether the non-compliance was unintentional. Ignorance of the list does not exempt from liability.
What should companies do now?
- Immediately update counterparty screening systems with the new EU consolidated list, available on EUR-Lex and the EU financial sanctions portal.
- Audit all active commercial and financial relationships with Russian, Belarusian counterparties or those linked to territories under Russian control to detect possible matches with the newly designated parties.
- Immediately suspend any pending operation, payment or delivery with counterparties that appear on the updated list.
- Notify the competent authorities if it is detected that assets or relationships are maintained with sanctioned persons or entities.
- Document all verification actions performed: date, source consulted, result and decision adopted. This documentation is key to demonstrating diligence in case of inspection.
- Review active contracts with legal advisors to assess whether the appearance of a counterparty on the active list triggers force majeure clauses or contract termination.
- Train the compliance team and commercial staff on the obligation to verify the list before initiating any new commercial or financial relationship.
Non-compliance with these obligations may result in criminal and administrative liability in Spain in accordance with Law 10/2021, for both the company and its directors and administrators.
Frequently asked questions
Where can I consult the updated list of parties sanctioned by the EU following Decision 2026/1939?
The consolidated list of sanctioned persons and entities is published in the EU Official Journal (EUR-Lex) and is updated on the EU financial sanctions portal. The reference for this update is CELEX:32026D1939, published on August 7, 2026. It is mandatory to always consult the most recent consolidated version, not the original 2014 version.
What happens if my company has an active contract with a company that now appears on the sanctions list?
You must immediately suspend any delivery, payment or service provision. Additionally, you must freeze the funds that entity has under your control and notify the competent authorities. Non-compliance, even if unintentional, can generate criminal and administrative liability in Spain in accordance with Law 10/2021. Verification of the list is a continuous due diligence obligation, not a one-time one.
When did the August 2026 sanctions expansion come into force?
Decision (CFSP) 2026/1939 came into force on the same day as its publication: August 7, 2026. There is no adaptation period or grace period. Verification and compliance obligations are enforceable from that date.
What types of companies in Spain are affected by these sanctions?
Any Spanish company or natural person that maintains commercial, financial or any other type of relationship with the designees on the list is affected. This includes especially financial operators (banks, insurance companies, asset managers), exporters and importers with activity towards Russia or territories controlled by Russia, and companies with contracts or joint ventures with Russian entities. Advisors and consultancies that provide services to persons on the list are also affected.
What specific measures apply to persons and entities included on the list?
The two restrictive measures applied by the EU are: (1) asset freezing, which requires immobilizing all funds and economic resources of the designees and prohibits making funds available to them; and (2) prohibition from traveling to the Schengen area, which prevents their entry or transit through the territory of EU Member States.
Official source
Consult complete regulation on 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:32026D1939