EU Regulation 2026/2281: 1,569 new Russia sanctions listings to screen and freeze

Council Implementing Regulation (EU) 2026/2281 of 12 October 2026 amends Annex I to Regulation (EU) No 269/2014, the EU's asset-freeze list over actions against Ukraine's territorial integrity, sovereignty and independence. It adds 826 entities and 743 persons. The Council adopted it together with Council Decision (CFSP) 2026/2279 and calls it the largest-ever package of listings under this regime, which now holds close to 4,600 listings.

The entities appear on a list recently drawn up by the Russian Government that identifies them as part of Russia's military-industrial complex and entitles them to state subsidies. The persons act as executives of those entities. According to the Council and the Commission, the companies are mid-level suppliers of components for missiles, drones and aircraft, with a combined annual turnover of at least €20 billion and more than 250,000 employees. The Council cites Russia's continued and escalating aggression, including its campaign against civilian infrastructure.

A second act of the same date, Council Implementing Regulation (EU) 2026/2292, adds 77 persons to the same Annex I. The Council considers that Russia's organisation of State Duma elections in September 2026 in the temporarily occupied territories of Ukraine breaches Ukrainian and international law. All 77 entries are natural persons, and the act also enters into force on its publication in the Official Journal.

Regulation 2026/2281 entered into force on the date of its publication in the Official Journal, 12 October 2026, and is directly applicable in all Member States. There is no transition period. The date of listing in the annex is also 12 October 2026, so any match in a firm's client base is caught from that day.

Under Article 2 of Regulation 269/2014, all funds and economic resources belonging to, owned, held or controlled by a listed person must be frozen, and no funds or economic resources may be made available to them, directly or indirectly. The base regulation also requires firms to supply any information that helps compliance to the competent authority without delay. See our study note on financial sanctions.

In practice, compliance and AML teams should make sure their screening tool has loaded both annexes, rescreen clients, beneficial owners, authorised signatories and payment or transfer counterparties, and investigate every potential match. CASPs and payment institutions should also check pending transfers. Record the steps taken and the outcome of each alert.