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On October 12, 2026, the EU substantially expanded its Russia sanctions lists.
On October 12, 2026, the Council of the European Union adopted the largest expansion of individual sanctions since Russia launched its war of aggression against Ukraine. The Council listed 826 companies and 743 individuals linked to Russia’s military-industrial complex. This brings the total number of listings under the Russia sanctions regime to nearly 4,600.
The new measures primarily target suppliers of key components for missiles, drones, and aircraft. These include electronics and semiconductors, communications technology such as radar and antennas, aviation, satellite, and missile systems, explosives and ammunition, and optics and navigation. The assets of all listed parties are frozen. Third parties are prohibited from making funds or economic resources available to the listed individuals, entities, and bodies.
The new listings reach well beyond companies that deal directly with Russian counterparties. Every business, and especially those with international supply chains and multi-tier business relationships, should check whether existing business partners, beneficial owners, or other parties to a transaction are affected.
Screening the name of the direct counterparty is not always enough. Ownership and control structures must also be taken into account.
The latest measures make clear that sanctions screening cannot stop at onboarding. Existing business partners and established supply chains must also be rescreened whenever relevant changes occur.
Businesses should update their sanctions screening and run delta screening alongside full list screening. Delta screening checks new or amended list entries against existing business partner data. Any potential match must be investigated to confirm whether the business partner is in fact listed. All screening steps and results should be carefully documented.
The expansion of the EU sanctions lists once again shows how important regular sanctions screening is. Effective compliance requires businesses to track sanctions developments closely and act on them promptly.
Beyond the latest list expansions, other EU measures against Russia also matter for businesses. A key element is Regulation (EU) No 833/2014.
Baker Tilly helps businesses review their sanctions screening and compliance processes, identify relevant risks, and adapt existing screening procedures to new developments. Contact our experts to find out more.
Sebastian Billig
Partner
Attorney-at-Law (Rechtsanwalt)
Sven Pohl
Director
Mareike Höcker
Manager
Attorney-at-Law (Rechtsanwältin)
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