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Client Alert 16 Oct. 2026
Download the full client alert here.
On October 12, 2026, the Council of the European Union announced a new wave of restrictive measures against Russia, centered on what the Council describes as its largest-ever package of individual listings. The measures add 1,569 new listings of individuals and entities which, according to the Council, are involved in Russia’s military and industrial complex.
The Council also added 74 persons who were candidates in the recent Russian legislative elections held in the territories disputed between Russia and Ukraine and 3 members of the Central Election Commission of the Russian Federation organizing such elections.
The newly-added listings bring the total number of active listings under the sanction’s framework supporting Ukraine’s territorial integrity close to 4,600 .
The new measures were adopted through:
Individuals and entities listed in Annex I to Regulation (EU) No 269/2014 are subject to a comprehensive asset freeze, which covers all funds and economic resources belonging to, owned, held or controlled by the listed persons. It is also prohibited to make funds and economic resources available to such listed persons. The terms ‘funds’ and ‘economic resources’ are construed broadly to include assets of any kind. In practice, listed persons cannot access, use, transfer, or otherwise dispose of, any existing or new funds.
In addition, natural persons listed in Annex I to Regulation (EU) No 269/2014 are subject to a travel ban within the Union.
EU sanctions apply, in principle, within the territory of the Union and aboard any aircraft or vessel registered in the Union. Foreign nationals and entities incorporated outside the EU shall comply with EU sanctions in respect of any business done in the EU.
EU nationals and entities incorporated in the EU are required to comply with EU sanctions in all their activities, whether inside or outside the EU. Notably, EU persons and entities are under a best efforts obligation to ensure that any entity incorporated outside the EU that they own or control does not undermine EU sanctions.
Persons and entities listed in Annex I to Regulation (EU) No 269/2014 shall report to the national competent authorities any funds or economic resources within the relevant jurisdiction. The reporting shall take place within 6 weeks from the day of listing.
Persons and entities holding funds and economic resources of listed persons within the Union shall likewise provide information to the national competent authorities.
Newly-added persons and entities to Annex I to Regulation (EU) No 269/2014 may contest their listing by submitting an application for reconsideration to the Council. They can also seek judicial review by filing an application for annulment before the General Court.
Strict deadlines apply in each case, which should be assessed promptly and on an individualized basis.
Economic Sanctions
Gianluca Cattani
Partner
Elena Klonitskaya
Edoardo Zucchelli
Mikhail Bychikhin
Counsel
Alice Venturini
Sofia Forestiere
Associate
Tatiana Gordievskaia
Anastasios Lafaras
Rome
+39 06 6758 2201
Milan
+39 02 7623 2001
Brussels
+32 2 313 37 31
Dubai
+971 4 382 6100
Paris
+33 1 42 68 72 00
The Lindsay Graham Sanctioning Russia and Iran Act of 2026 & its Impact on the Scope of the Executive’s Authority