Key data
| Regulation | Council Implementing Regulation (EU) 2026/613 |
|---|---|
| Publication | 16 March 2026 |
| Entry into force | 16 March 2026 (immediate) |
| Affected parties | Companies, financial entities and persons with commercial links to Russia or Ukraine |
| Category | European Regulation |
| Base regulation | Regulation (EU) No 269/2014 |
| Applied measures | Asset freezing, fund prohibition, travel restrictions |
If your company operates with Russian or Belarusian counterparties, you have an immediate obligation: verify that none of them appear on the updated list of Council Implementing Regulation (EU) 2026/613, published on 16 March 2026. There is no grace period. The regulation entered into force on the same day of its publication.
This update is part of the sanctions regime under Regulation (EU) No 269/2014, which the EU uses to designate persons and entities that undermine or threaten the territorial integrity, sovereignty and independence of Ukraine. Each update adds new names to that list and generates immediate obligations for the European business community.
What does this regulation establish?
Regulation 2026/613 expands the list of designated persons under Regulation 269/2014 with new natural and legal persons. For all newly listed parties, three types of measures are automatically applied:
| Measure | What it consists of | Who must comply |
|---|---|---|
| Asset freezing | All funds and economic resources of the designated parties are blocked | Financial entities, banks, asset managers |
| Prohibition on making funds available | It is prohibited to transfer, pay or provide economic resources to listed parties | Any company or natural person in the EU |
| Travel restrictions | Designated parties cannot enter or transit through EU territory | Border control authorities |
The regulation does not establish a public list of names in the available summary, but the full text of the regulation on EUR-Lex includes the annexes with all newly designated parties. It is mandatory to consult those annexes to verify counterparties.
Economic and operational impact
The direct impact for companies is not a fee or fixed cost: it is the risk of non-compliance. Operating with a designated party, even unintentionally, can result in:
- Criminal sanctions for those responsible at the company in Spain.
- Serious administrative sanctions which may include high fines and disqualifications.
- Blocking of operations and possible freezing of the company's own assets if deemed complicit.
The real operational cost is that of updating compliance systems: counterparty screening tools, review of existing contracts and training of compliance and export teams. For companies without an active sanctions program, this is the time to implement one.
Financial entities also have the obligation to block assets of newly designated parties if they hold them in custody, with corresponding notification to the competent authorities.
Who does it affect?
- Financial entities: banks, savings banks, fund managers, insurance companies and any entity that may hold assets of newly designated parties in custody or management.
- Exporters and importers with commercial activity to or from Russia or Belarus, who must verify that their counterparties are not listed.
- Companies with subsidiaries, partners or suppliers in Russia or Belarus, regardless of sector.
- Advisors, lawyers and consultants providing services to entities with links in those geographies.
- Any Spanish or European company making payments, transfers or transactions with persons or entities within the scope of Regulation 269/2014.
Practical example
A Spanish industrial machinery company has a distributor in Russia with which it has been operating for three years. On 16 March 2026, Regulation 2026/613 enters into force. If that distributor —or any of its partners or owners— has been added to the list of designated parties, the Spanish company is prohibited from that same day:
- Sending any goods or outstanding invoices.
- Collecting or paying any amount related to that commercial relationship.
- Renewing or maintaining the distribution contract.
If the company does not review the updated list and makes a transfer to that distributor on 17 March, it is already in breach of the regulation, regardless of whether it did so in good faith. Lack of knowledge does not exempt from responsibility. That is why verification must be immediate and systematic, not occasional.
What should companies do now?
- Consult the annexes of Regulation 2026/613 on EUR-Lex to identify the new names added to the list of designated parties. The full text is available at this official link.
- Cross-check the updated list with all active counterparties: customers, suppliers, distributors, partners and payment beneficiaries with links to Russia or Belarus.
- Immediately suspend any operations with counterparties listed, including pending payments, shipments and contract renewals.
- Notify your financial entity if you detect that you hold assets of a designated party, as financial entities have the obligation to block them and report to the authorities.
- Update your sanctions screening systems to include the most recent version of the EU consolidated list, and establish automatic alerts for future updates.
- Document all verifications performed to be able to demonstrate due diligence in case of inspection or investigation.
Frequently asked questions
Which companies must review their commercial relationships due to the new EU sanctions of March 2026?
All companies and financial entities with commercial or financial links to Russia or Belarus must review their counterparties. Especially exporters, banks and any entity that may have relationships with newly designated parties on the updated Regulation 269/2014 list as of 16 March 2026.
What happens if my company operates with someone on the EU's list of sanctioned parties?
Non-compliance can result in serious criminal and administrative sanctions in Spain. Measures include asset freezing and prohibition on making funds available to listed parties. It is mandatory to cease any commercial or financial relationship with newly designated parties from 16 March 2026.
When do the new sanctions of Council Implementing Regulation (EU) 2026/613 enter into force?
The new sanctions entered into force on the same day of their publication: 16 March 2026. There is no adaptation period: the obligation to comply is immediate from that date.
Where can I consult the updated list of persons and entities sanctioned by the EU?
The complete and updated list is available on the EUR-Lex website in the annexes to Council Implementing Regulation (EU) 2026/613. You can also consult the consolidated sanctions list maintained by the European Commission's EEAS (European External Action Service) on its official website.
Official source
Council Implementing Regulation (EU) 2026/613 of 16 March 2026 amending Regulation (EU) No 269/2014 concerning restrictive measures in respect of actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. Companies must consult with their legal and compliance advisors to ensure full compliance with applicable sanctions regulations. The information contained herein is based on the regulatory text as of the publication date and may be subject to updates or amendments. CambiosLegales is not responsible for any damages arising from the use or misuse of this information.