Sanctions on Russia: Compliance updates

On October 12, 2026, the Council of the European Union (EU) adopted what it described as its “largest-ever package of listings”: 1,569 individuals and entities in Russia’s military-industrial complex. The new listings bring the EU’s Ukraine-related sanctions regime to close to 4,600 individuals and entities, according to the Council.

This article covers what the October 2026 package contains, how quickly we made it available for screening, and the key measures the US, EU, UK, and other jurisdictions have imposed on Russia since its full-scale invasion of Ukraine on February 24, 2022.

The EU’s October 2026 package of Russia listings

The Council of the EU adopted the package through Council Decision (CFSP) 2026/2279 and Implementing Regulation (EU) 2026/2281. It targets the companies that supply Russia’s missile, drone, and aircraft production, and the people who run them. This is the EU’s 22nd sanctions package against Russia. The package includes:

• 826 Russian companies that supply components for missiles, unmanned aerial vehicles (UAVs), and aircraft, including electronics, communications equipment, explosives, and navigation systems.
• 743 individuals who serve as chief executives of those companies.
• An asset freeze on every listed party and a prohibition on making funds or economic resources available to them.
• An EU travel ban for listed individuals.

Why was this package difficult to process?

The EU doesn’t publish sanctions designations as structured data files. It publishes legal acts, with names, aliases, and company identifiers set out in free text alongside official terminology. The legal text for this package ran to almost 1,000 pages in a single document. Turning it into screenable records means extracting every name and identifier, then checking data quality before anything reaches production.

Background: The invasion of Ukraine and the first sanctions in 2022

On February 24, 2022, Russian forces crossed Ukraine’s borders, with attacks reported across the country. While President Putin claimed Russia did not intend to occupy the country, Ukraine called the attack “a full-scale invasion.” Ukrainian President Volodymyr Zelensky imposed martial law across the country and barred men aged 18-60 from leaving.

On February 27, 2022, President Putin placed Russia’s nuclear deterrent forces on high alert, condemning “aggressive statements” from NATO. Peace talks between the two sides in Belarus in early March 2022 produced few signs of a significant breakthrough.

What sanctions were imposed on Russia in 2022?

The three main sanctions regimes targeting Russia in 2022 were the US, the EU, and the UK. The sections below set out what these sanctions were and how they affected organizations.

US sanctions on Russia

Announcing new sanctions on February 24, 2022, President Biden pledged to make Vladimir Putin “an international pariah,” according to the Wall Street Journal. Taken together, the Office of Foreign Assets Control (OFAC) said the actions targeted 80% of Russia’s banking assets. The measures announced included:

Sanctions on Russia’s central bank and largest banks

• Russia’s two largest financial institutions – Public Joint Stock Company Sberbank of Russia (Sberbank) and VTB Bank Public Joint Stock Company (VTB Bank) – could no longer process payments through the US financial system. Sberbank, which held almost a third of all bank assets in Russia, had correspondent and payable-through account sanctions imposed on it. “Within 30 days, OFAC is requiring all U.S. financial institutions to close any Sberbank correspondent or payable-through accounts and to reject any future transactions involving Sberbank or its foreign financial institution subsidiaries.”
• On April 6, 2022, sanctions against Sberbank were extended to full blocking sanctions, alongside Alfa Bank. Exceptions remained for energy purchases.
• VTB Bank, which held almost 20% of Russia’s banking assets, also had full blocking sanctions imposed, freezing its assets held in US financial institutions. OFAC described it as “one of the largest financial institutions Treasury has ever blocked.”
• Blocking sanctions were also imposed on three Russian financial institutions – Otkritie, Novikom, and Sovcom – that together held assets worth $80 billion.
• On February 28, 2022, the US confirmed it would impose sanctions on Russia’s central bank, the National Wealth Fund of the Russian Federation, and the Ministry of Finance, with immediate effect.

Debt and equity prohibitions on major state-owned and private entities

OFAC expanded its debt and equity restrictions to more of Russia’s economy. Specifically, OFAC would “prohibit transactions and dealings by U.S. persons or within the United States in new debt of longer than 14 days maturity and new equity of Russian state-owned enterprises, entities that operate in the financial services sector of the Russian Federation economy, and other entities determined to be subject to the prohibitions in this directive.” The directive covered 13 major firms, including six of Russia’s largest financial institutions.

General licenses

OFAC also issued several general licenses to “minimize unintended consequences on third parties,” with energy a key focus. The licenses authorized certain transactions related to international organizations, the COVID-19 pandemic, emergency flights, energy, derivative contracts, the rejection of transactions involving certain blocked persons, and the wind-down of transactions involving certain blocked persons.

Actions targeting Russian elites

A number of “elites close to Putin” were also targeted. OFAC said many of these individuals “participate in, or benefit from, the Russian regime’s kleptocracy,” while others “serve in leadership roles of companies designated or identified today.” Some, including Ivanov and Patrushev, had been designated before and were redesignated. The individuals listed included:

• Sergei Borisovich Ivanov, whom the US Treasury considered a close confidant of Putin, designated with his son under Executive Order 14024.
• Nikolai Platonovich Patrushev, Secretary of the Russian Federation Security Council, and his son, also under E.O. 14024.
• Igor Ivanovich Sechin, CEO and Chairman of the Board of Rosneft and a former Deputy Prime Minister of Russia.
• Senior executives at state-owned banks, including VTB Bank.
• Dmitry Peskov, President Putin’s press secretary.
• Alisher Usmanov, founder of the Russian mining company Metalloinvest.
• Nikolay Tokarev, chief executive of the energy company Transneft, with his wife, his daughter, and two associated real estate companies.
• Brothers Boris and Arkady Rotenberg and several family members.
• Katerina Tikhonova and Mariya Putina, President Putin’s daughters.
• Dmitry Medvedev, former President and Prime Minister of Russia.
• Russian Prime Minister Mikhail Mishustin.

State of the Union announcements

In his State of the Union address in March 2022, President Biden announced that the US Department of Justice was building a task force “to go after the crimes of Russian oligarchs,” citing the seizure of apartments, yachts, and private jets. He also confirmed the US would close its airspace to all Russian flights.

Energy restrictions

On March 8, 2022, President Biden announced a US ban on imported Russian oil. Europe’s greater reliance on Russian energy made this an area of less alignment among Western powers. The UK pledged to phase out Russian oil imports by the end of 2022. On April 7, 2022, Congress approved a bill to ban imports of oil, gas, coal, and other energy products from Russia.

US sanctions enforcement

As the conflict continued, US authorities turned their attention to enforcing the sanctions imposed. On March 31, 2022, OFAC designated 21 entities and 13 individuals as part of a crackdown on Kremlin illicit procurement networks and technology companies helping Russia evade US sanctions. These included TsNIIKhM, which was involved in a 2017 cyberattack on a Middle Eastern petrochemical facility.

EU sanctions on Russia

European Commission President Ursula von der Leyen said EU sanctions “will target the strategic sectors of the Russian economy by blocking access to technologies and markets that are key for Russia.” Specific measures announced in 2022 included:

• Sanctions on 351 members of the Russian State Duma who voted to recognize the independence of Donetsk and Luhansk.
• Sanctions on 27 individuals and entities who had “contributed to the undermining or threatening of the territorial integrity, sovereignty, and independence of Ukraine.”
• Limits on the Russian state’s access to EU capital and financial markets.
• The exclusion of several major banks from the SWIFT payment messaging system.

On February 24, 2022, the EU also agreed on further sanctions on Russia’s financial, energy, and transportation sectors, along with export controls, visa restrictions, and sanctions on more Russian individuals. On February 25, 2022, the EU confirmed it would freeze the assets of President Putin and Foreign Minister Sergey Lavrov.

On February 27, 2022, President von der Leyen announced three new tranches of sanctions, including a ban on all Russian aircraft in EU airspace, measures targeting the Russia Today and Sputnik media outlets, and wider sanctions on Belarus. On March 3, 2022, she said the EU would assess the impact of existing sanctions before adding more, and that further steps could include targeting crypto-assets.

On March 9, 2022, the European Commission announced sanctions on 160 more individuals to bring the EU’s sanctions programs against Russia and Belarus into closer alignment. This included SWIFT prohibitions “similar to those in the Russian regime” and clarified that crypto-assets fall within the scope of “transferable securities.”

On March 15, 2022, the EU sanctioned individuals including Roman Abramovich and Konstantin Ernst, head of Russia’s Channel One, where Marina Ovsyannikova had staged a widely shared anti-war protest. The EU also banned investment in Russia’s energy sector and exports to Russia of luxury goods, including precious stones, clothes, and carpets, worth more than €300.

EU energy sanctions

Much attention focused on how the EU would extend sanctions to the energy sector, given many European countries’ reliance on Russian energy. On April 8, 2022, the EU announced its fifth sanctions package. The fifth package included:

• A ban on importing or transferring coal and other solid fossil fuels into the EU if they originate in or are exported from Russia, effective from August 2022.
• A ban on EU port access for vessels registered under the Russian flag, with exceptions for energy, humanitarian, agricultural, and food shipments.
• Export bans on jet fuel, quantum computers, advanced semiconductors, high-end electronics, software, and transportation equipment, and import bans on wood, cement, fertilizers, seafood, and liquor.
• An extended prohibition on deposits to crypto-wallets.
• A full transaction ban on four Russian banks that together made up 23% of the country’s banking sector.
• Sanctions on companies whose “products or technology have played a role in the invasion,” along with oligarchs, businesspeople, Kremlin officials, and “proponents of disinformation and information manipulation.” The Council also said it would sanction family members of already sanctioned individuals to “ensure EU sanctions are not circumvented.”

UK sanctions on Russia

Then-Prime Minister Boris Johnson said the UK would impose its “largest ever” set of economic sanctions on Russia. These included a push to end Russia’s use of the SWIFT payment system, asset freezes on all major Russian banks, limits on deposits held by Russian nationals in UK banks, and sanctions on more than 100 individuals and entities. Aeroflot was banned from landing in the UK.

The government also brought forward its economic crime bill to target assets more effectively and improve ownership transparency. Then-Foreign Secretary Liz Truss said the UK had compiled a “hit list” of oligarchs who would face sanctions. Those sanctioned in the first weeks included:

• Kirill Shamalov, former son-in-law of President Putin.
• Denis Bortnikov, chair of the VTB Bank management board.
• Yury Slyusar, director of the United Aircraft Corporation.
• Gennady Timchenko, a Putin ally with business interests across energy, transportation, and construction.
• Igor Rotenberg, a shareholder in Gazprom Drilling.
• Alisher Usmanov and Igor Shuvalov.
• Roman Abramovich, then owner of Chelsea Football Club.
• Igor Sechin, chief executive of Rosneft.
• Five Russian banks: Rossiya, the Black Sea Bank for Development and Reconstruction, Genbank, Promsvyazbank, and IS Bank.

The UK also sanctioned President Putin and Foreign Minister Lavrov. Truss announced an Oligarch Taskforce of ministers and officials from several government departments to coordinate cross-government work on sanctions and build cases against oligarchs identified as targets.

On February 28, 2022, then-Chancellor Rishi Sunak announced the UK would join the European Central Bank and Federal Reserve in sanctioning Russia’s central bank, barring UK persons from transactions with the central bank, finance ministry, and wealth fund. The Atlantic argued that central bank sanctions “could potentially bankrupt the entire Russian banking system and push the ruble into worthlessness.”

On March 9, 2022, Truss set out new powers to detain Russian aircraft and a ban on exports of aviation and space-related goods and technology.

On March 15, 2022, the UK announced sanctions on 370 more Russian and Belarusian individuals and entities, including 51 oligarchs and their families with an estimated combined net worth of more than £100 billion. Defense Minister Sergei Shoigu, former President Dmitry Medvedev, and Mikhail Fridman, founder of Alfa Bank, were among those sanctioned.

Sanctions on Belarus

On March 1, 2022, Truss announced the UK’s first sanctions on Belarus for its support of Russia’s invasion. Belarus’s Chief of the General Staff, three deputy defense ministers, and two military enterprises were sanctioned.

UK energy sanctions

On April 6, 2022, the Foreign Secretary announced a suite of new measures to end the UK’s imports of Russian energy and sanction more individuals and businesses. The measures included:

• A pledge to end the UK’s dependence on Russian coal and oil by the end of 2022, with an end to gas imports “as soon as possible thereafter.”
• Asset freezes on Sberbank and Credit Bank of Moscow.
• A ban on new outward investment to Russia, worth more than £11 billion in 2020.
• Sanctions on eight more oligarchs, including Viatcheslav Kantor and Andrey Guryev, leading businessmen in the fertilizer industry.
• Sanctions on Leonid Mikhelson, founder and CEO of the natural gas producer Novatek.
• Sanctions on Alexander Dyukov, CEO of the state-owned oil producer Gazprom Neft.

Canada’s sanctions on Russia

Then-Prime Minister Justin Trudeau announced two tranches of sanctions against Russia. The measures included:

• Financial restrictions on 31 individuals and 27 banks connected to Russia’s elite.
• The suspension of export permits worth $750 million across sectors including aerospace, IT, and minerals.
• Participation in coordinated action against Russia’s central bank.

On March 3, 2022, Canada became the first country to revoke Russia and Belarus’s status as preferential trading partners, applying a 35% tariff on all imports from the two countries. 

On March 7, 2022, Trudeau sanctioned 10 individuals close to President Putin, based on a list compiled by opposition leader Alexei Navalny. On March 15, 2022, Canada sanctioned 15 more officials, mainly Russian defense officials, ahead of an address by Ukraine’s president to the Canadian parliament. On March 21, 2022, Canada’s foreign minister said the country would impose new sanctions on Russia.

Sanctions on Russia from other jurisdictions

• Japan: Japan imposed sanctions on Russian financial institutions, military entities, and individuals, along with restrictions on chip exports. On February 27, 2022, it joined the US and others in blocking certain Russian banks’ access to the SWIFT messaging system, and extended $100 million in humanitarian aid to Ukraine. In response, Russia said it would discontinue peace treaty talks with Japan over the Kuril Islands dispute.
• Singapore: Singapore‘s Foreign Ministry said Russia’s invasion “contravenes the UN Charter and is a clear and gross violation of international law.” Singapore imposed export controls on items that could be used as weapons, restricted crypto transactions that posed a sanctions evasion risk, and imposed “targeted financial measures” on key banks. Financial institutions were barred from providing services that could help Russia’s government raise funds. It was only the second time Singapore had taken such action against another country without UN Security Council approval, and it made Singapore the first ASEAN country to join the coordinated sanctions.
• Australia: Foreign Minister Marise Payne said Australia would join the UK, US, and EU in sanctioning President Putin and Foreign Minister Lavrov, along with eight oligarchs, 339 members of Russia’s parliament, and senior Belarusian figures. Australia also sanctioned 25 senior military personnel, Promsvyazbank, Industrial Savings Bank, Genbank, and the Black Sea Bank for Development and Reconstruction, and banned exports of alumina and aluminum ores to Russia. Australia had supplied 20% of Russia’s alumina.
• New Zealand: Exports to Russia’s military and security forces were prohibited and travel bans imposed on Russian officials, according to then-Prime Minister Jacinda Ardern. In March 2022, New Zealand passed its Russia Sanctions Act, allowing it to impose economic sanctions on specific people, companies, assets, and services in Russia for the first time.
• Taiwan: Taiwan said it would join international sanctions on Russia, including halting semiconductor exports.

Western sanctions enforcement

Given the scope and scale of sanctions on Russia, Western governments set up several bodies to coordinate enforcement. The European Commission launched a “Freeze and Seize” task force, and the US Justice Department launched Task Force KleptoCapture. Both work alongside the Russian Elites, Proxies, and Oligarchs (REPO) task force, which coordinates finance, justice, home affairs, and trade ministries across Australia, Canada, the EU, France, Germany, Italy, Japan, the UK, and the US.

As well as keeping allies aligned, these bodies – and their high public profile – act as a warning to sanctioned oligarchs and others. They encourage proactive compliance with sanctions and reduce how much governments need to enforce measures directly.

Russian counter-sanctions

On March 15, 2022, Russia sanctioned 13 US officials, including President Biden, Secretary of State Antony Blinken, Defense Secretary Lloyd Austin, and former Secretary of State Hillary Clinton. All were barred from entering Russia, and any assets they held in Russia were frozen. Russia said the sanctions would not affect high-level diplomatic work.

China’s response

By contrast, China opened fully to Russian wheat imports, and a Foreign Ministry spokesperson pointed to Russia’s “legitimate security concerns,” including American arms sales to Kyiv. President Xi Jinping called on Russia to hold high-level talks with Ukraine. China abstained, alongside India and the United Arab Emirates, on a UN Security Council resolution tabled on February 25, 2022, that called on Russia to withdraw all troops from Ukraine.

On February 28, 2022, Bloomberg reported that Gazprom had taken a step toward “potentially its biggest-ever natural gas supply deal” with China, signing a contract to design a pipeline across Mongolia. Analysts argued that while Western powers excluded grain, oil, and gas from sanctions, “the talk of China providing a lifeline to Russia in the short term is not that relevant.”

How do we keep sanctions data current as lists change?

Sanctions on Russia have changed quickly and often since February 2022. As a provider of real-time global sanctions screening, our role at ComplyAdvantage is to give clients accurate coverage as soon as new designations are published. The October 2026 package shows what that looks like at scale: almost 1,600 new listings, available to screen against in under three hours.

How updates reach our data

We capture many sanctions updates automatically from official lists. However, governments sometimes announce new sanctions before they are formally designated, or announce them through non-standard sources such as press releases. Others require changes to legislation, as is the case in the EU, where designations are published in legal acts rather than structured files.

Updates made in 2022

Ensuring data quality

Speed matters, and so does data quality. Our team assesses data before it is pushed into production. This helps account for inaccuracies or discrepancies in source information, which are more likely when governments and regulators are moving quickly.

Sanctions compliance checklist

Systems and controls

Firms should check that their customer and payment screening platforms can detect relevant risks and manage them once detected, for example, by blocking transactions or freezing funds when required. Where sanctioned customers or entities are identified, firms should block transactions, freeze accounts, and allocate the funds to a suspense account, while continuing to meet contractual terms. Financial institutions operating in securities markets should also be able to identify sanctioned persons and entities in executed trades.

Training

Firms should provide compliance staff with training and guidance on the latest sanctions measures and on how to handle affected customers and transactions, with updated communications as the situation evolves. In a volatile situation, well-trained staff can discount alerts that don’t require escalation, so teams spend their time on real risks.

Exposure

Firms should understand their exposure not only to sanctioned entities but also to the wider network around them, and decide whether they have systems to do this or whether it will be a manual exercise. This should include:

• Sweeping customer databases to identify all customers based in Russia or connected to sanctioned individuals and entities.
• Identifying customers with significant business dealings with Russia to decide whether to apply enhanced monitoring to their transactions.
• Reviewing deals in the energy, transport, and construction sectors where customers may have agreements with a Russian counterpart.
• Understanding beneficial ownership structures and the ownership and control thresholds set by different sanctions regimes to identify entities that are not directly sanctioned but are owned or controlled by a sanctioned person or entity.
• Reviewing the terms of securities, money market instruments, and loan and credit agreements identified as being held by sanctioned persons.
• Identifying any licensing requirements.

Continuous monitoring

Compliance teams need a mindset similar to traders watching the markets: monitoring the latest news and alerts in real time is essential. The October 2026 package shows why. Customers who were clean in the morning matched new designations by mid-afternoon.

Holistic understanding

As well as tracking which sanctions are in place, compliance teams should stay up to date on geopolitics, trade, and broader global events. These often converge, creating cross-over sanctions risks.

FAQs

How many individuals and entities did the EU list in October 2026?

The Council of the EU listed 1,569 individuals and entities on October 12, 2026: 826 Russian companies in the military-industrial complex and 743 individuals who serve as their chief executives. The Council described it as its largest-ever package of listings.

How quickly were the October 2026 EU listings available for screening?

Clients could screen against the new listings on all our screening products two hours and 53 minutes after the Council published them. This package was unusually large: the legal text was almost 1,000 pages in a single document.

When did clients receive monitoring alerts for the new listings?

Clients using event-driven monitoring received alerts between 13:55 and 14:08 BST on October 12, 2026, within minutes of data ingestion.

Why are EU sanctions designations difficult to process?

The EU doesn’t publish sanctions designations in structured files. It publishes legal documents in which names, aliases, and identifying details are set out in free text alongside official terminology. Each entry has to be extracted and checked before it can be screened against.

How should firms manage the opacity of shell companies?

At the customer level, firms should make sure they fully understand their customers’ ownership structures. Where they don’t, they can enrich this information by requesting verifiable evidence from the customer or by using an external data or software provider.

At the transaction level, when a firm doesn’t know the ultimate beneficial owner (UBO) of a payment, it should take reasonable steps to carry out due diligence on the parties involved and to understand the nature and purpose of the transaction. Firms can use open-source information where available, request further information and evidence from the customer, or use an external data or software provider.

Who should follow sanctions updates? Are they only relevant to banks?

No. Managing sanctions risk can be especially challenging for smaller firms, such as legal firms, FinTechs, and accounting firms. Large banks have big compliance teams, while some smaller firms have a single compliance officer. These firms should consider whether technology and automation can help them spot risks, since doing so manually is very difficult. Regardless of their size, firms should assume they could be exposed and assess whether they can understand and manage the associated sanctions risks.

How should firms handle the sphere of influence around PEPs?

Systems, controls, and training are essential. Systems and controls should ensure that politically exposed person (PEP) risks can be detected and managed, and that relatives and close associates (RCAs) can be identified. Training makes sure staff across the business, not only in compliance, understand the risks and know what to do when they identify a PEP.

What happened to Russia’s SWIFT access?

In a joint statement on February 26, 2022, the European Commission, France, Germany, Italy, the UK, and the US committed “to ensuring that selected Russian banks are removed from the SWIFT messaging system.” They said this would “ensure that these banks are disconnected from the international financial system and harm their ability to operate globally.” A German government spokesperson said all sanctioned banks would be affected, along with other institutions if necessary.

The BBC reported that more than 1% of SWIFT messages were “thought to involve Russian payments,” and Russia relies on SWIFT for its oil and gas exports. Iran was the only country removed from SWIFT before, which led to it losing 30% of its foreign trade.

Russia’s exclusion from SWIFT could also strengthen China’s alternative, the Cross-Border Interbank Payment System (CIPS). Launched in 2015, CIPS settles international payments in yuan. At least 23 Russian banks were connected to CIPS as of February 2022.

Read our piece on SWIFT, BIC, and sanctions compliance

Could Russia use cryptocurrencies to evade sanctions?

Crypto carries sanctions evasion risk, and Iran offers a precedent. However, crypto alone cannot offset the financial losses Russia has sustained through Western sanctions. It is more likely to become a tool that individual Russians use to protect their wealth as inflation rises and the ruble loses value.

Read our piece on crypto, Russia, and sanctions evasion risks

Protecting against statutory asset freezes and travel bans imposed by governments worldwide has become increasingly important and complex for firms of all sizes.

Read more on the war in Ukraine and sanctions best practices:

• Guide: The evolving use of sanctions
• Putin’s challenge and Western sanctions
• How to ensure Russia sanctions compliance