knowledge 30 October 2026 |

EU-Russia Sanctions Update – 22nd round of EU Sanctions

The package imposes sanctions on a further 1,569 individuals and entities, including 826 Russian companies and 743 individuals, increasing the total number of designations to 4,600¹. These measures were introduced in light of Russia’s ongoing aggression against Ukraine, particularly its recent attacks on civilian infrastructure which has inflicted intense suffering to the civilian population. Over half of the new package targets the manufacturers and production chains of ballistic missiles and drones.

Despite the scale of the new sanctions listings, the package introduces no material new restrictions under the separate framework of Council Decision 2014/512/CFSP and Regulation (EU) No 833/2014, relating to restrictions on trade, finance, crypto and other key sectors.

Defence listings: Military-Industrial Complex

The EU has taken a more holistic approach in targeting not only the major defence manufacturers through this package, but also their wider supply chain. In that regard, the package imposes sanctions on mid-level suppliers, regarded as the core of Russia’s military-industrial complex, who have been recognised as collectively generating a combined annual turnover of at least €20 billion and employing more than 250,000 people.

These companies are targeted due to their involvement in the supply of essential components used in several of Russia’s most advanced weapons systems, including missiles, UAVs and military aircraft. The components these companies produce are broad ranging and include electronics, communications equipment, radar systems, aviation technology, satellite and missile systems, explosives and ammunition, and navigation systems.

Another significant feature is the decision to designate 743 individuals serving as senior executives, directors and chief executives of the newly listed companies. The Council’s rationale is that these individuals support Russia’s military-industrial complex through their leadership and management of entities within this sector.

The package reflects a further chapter in the EU’s strategy of targeting component manufacturers, technology suppliers and ancillary businesses contributing to the production of military equipment.

Democratic violations: Russia’s Illegal Elections in Ukraine

The Council also adopted restrictive measures against 77 individuals involved in the illegal so-called ‘Russian State Duma’ elections held in September 2026 in the temporarily and illegally occupied Ukrainian territories.

The listings include 74 candidates who stood for election for various parties in these areas, including the so called “Donetsk People’s Republic” and “Luhansk People’s Republic”. By participating in or organising these elections, those listed actively contributed to efforts to legitimise Russia’s occupation of Ukrainian territory.

Impact

Individuals and entities designated under this sanctions’ regime are subject to asset freeze measures and a ban on direct or indirect provision of funds or economic resources to them or for their benefit. In addition, listed individuals are subject to an EU travel ban.

EU Support for Ukraine

In addition to strengthening sanctions against Russia, the EU continues to financially support Ukraine’s military defence. On 25 September 2026, EU member states reached agreement to mobilise €6.6 billion for Ukraine under the European Peace Facility (EPF). Established in March 2021, the EPC finances actions under the Common Foreign and Security Policy (CFSP) aimed at preventing conflicts, preserving peace and strengthening international security and stability.

The EU has also mobilised €3.5 billion in ‘extraordinary revenues’ generated from Russian frozen assets (the so-called “windfall profits”), which through the EPF, are used to support Ukrainian priority needs of ammunition, air defence, and drones.

Comment

The 22nd package marks a notable intensification of the EU’s sanctions designation strategy, and the EU’s latest commitment to financially support Ukraine’s military defence confirms its firm support for Ukrainian independence and sovereignty.

The latest package focuses on a substantial expansion of the asset-freeze regime under Regulation (EU) No 269/2014 to target the underlying systems and logistics of Russia’s military, rather than broad sector-wide restrictions under Regulation (EU) No 833/2014. The individual designation of a large number of senior business executives is likely to complicate sanctions compliance, particularly for businesses operating across multiple jurisdictions or within complex corporate structures. Due diligence efforts will need to carefully assess ‘control’ in line with EU guidelines on ‘Ownership and Control’ in respect of any other entity with whom business is being carried out. This includes assessing whether these individuals exercise significant influence (e.g. board dominance, operational management, or other veto rights), even where the entity in question is not part of the military-industrial complex.

For further information or tailored advice on compliance with EU sanctions, please contact your usual McCann FitzGerald LLP representative.

 

¹ The list of designated persons and entities is enacted under Regulation (EU) No 269/2014, implemented through Council Decision (CFSP) 2026/2279 and Council Implementing Regulation (EU) 2026/2281.