New EU sanctions
On 12 October 2026, legal acts were published expanding the list of persons subject to blocking sanctions, including:- Council Implementing Regulation (EU) 2026/2281 (“Regulation No. 2281”) implementing Regulation (EU) No. 269/2014; and
- Council Implementing Regulation (EU) 2026/2292 (“Regulation No. 2292”) implementing Regulation (EU) No. 269/2014.
Both regulations entered into force on 12 October 2026. Taken together, they provide for more than 1,500 new inclusions.
As a reminder, EU blocking sanctions have the following consequences:
- EU PersonsThe EU sanctions are binding: within the EU; on EU citizens regardless of their location; on EU-registered legal entities and their branches and representative offices; on any persons within EU territory, regardless of their nationality; and on board any aircraft or vessel under the jurisdiction of a Member State (jointly – “EU Persons”). are required to block (freeze) funds and economic resources owned, held or controlled by sanctioned persons; and
- EU Persons are prohibited from directly or indirectly making funds and economic resources available to or for the benefit of sanctioned persons.
Restrictions on entry into the EU and transit through its territory also apply to the individuals included on the list.
Russian military-industrial complex
Under Regulation No. 2281 blocking sanctions were imposed on 826 legal entities and 743 individuals. According to the EU’s statements of reasons, the relevant legal entities have been included by the Government of the Russian Federation on the list that identifies them as belonging to the Russian military-industrial complex, and they are therefore entitled to receive subsidies from the Government of the Russian Federation. Although the Regulation does not specify the name or details of the relevant list, it most likely refers to the Consolidated Register of Organisations in the Defence-Industrial Complex, which is maintained by the Russian Ministry of Industry and Trade pursuant to Russian Government Resolution No. 96 dated 20 February 2004.
The legal basis for listing is the criterion set out in Article 3(1)(l) of Regulation No. 269/2014. This allows for the imposition of sanctions against individuals and legal entities forming part of, supporting, materially or financially, or benefitting from Russia’s military and industrial complex, including by being involved in the development, production or supply of military technology and equipment.
The EU Council press release states that the new sanctions target suppliers of components for missiles, UAVs and aircraft, including electronics, communication equipment, aviation and missile systems; explosives and ammunition and optics and navigation systems.
In particular, blocking sanctions were imposed on:
- shipbuilders, ship repair enterprises and marine design bureaux, including PO Sevmash JSC, Admiraltejskie verfi JSC, Sudostroitelnyj zavod severnaja Verf PJSC, Amurskij sudostroitelnyj zavod PJSC, Tsentralnoe konstruktorskoe bjuro morskoj tehniki Rubin JSC and Sankt-peterburgskoe morskoe bjuro mashinostroenija Malahit JSC;
- enterprises in the rocket and space industry and the aviation instrument-making sector, including Obedinennaja raketno-kosmicheskaja korporatsija JSC, Rossijskaja korporatsija raketno-kosmicheskogo priborostroenija i informatsionnyh sistem JSC, Omskoe mashinostroitelnoe konstruktorskoe bjuro JSC, and Ramenskij priborostroitelnyj zavod JSC;
- manufacturers of electronics, communications equipment and optical equipment, including VZPP-Mikron JSC, NPO Angstrem JSC, Svetlana-elektronpribor JSC, Kontsern Okeanpribor JSC, Akvamarin JSC, Voshod-Kaluzhskij radiolampovyj zavod JSC, Zhigulevskij Radiozavod JSC, Zavod Snezhet JSC, Moskovskij elektrolampovyj zavod LLC, Rostovskij optiko-mehanicheskij zavod PJSC, as well as National Research University Moskovskij institut elektronnoj tehniki;
- engineering enterprises and manufacturers of industrial products, including GAZ PJSC, Torgovo-finansovaja kompanija KAMAZ JSC, Motovilikhinskie zavody JSC, Mytischinskij mashinostroitelnyj zavod JSC, Kordiant JSC, Severstal Kanaty JSC and Severstal podemnye tehnologii LLC, Zavod Mosshtamp LLC and Profit LLC;
- manufacturers of materials and components, including Germanij JSC, Narodnoe predprijatie Podolskkabel JSC and Sergievo-posadskij pirotehnicheskij zavod LLC; and
- enterprises in the textile and garment industry, including Borisoglebskaja shvejnaja fabrika LLC, Zolotoe Runo LLC and Schelkovskaja shelkotkatskaja fabrika CJSC.
Among the company executives subject to blocking sanctions are, inter alia, Boris Dubovik (the General Director of Zelinsky Group LLC, the managing organisation of Tambovmash JSC), Andrey Bystrov (Admiraltejskie verfi JSC), Vladimir Dorofeev (Sankt-peterburgskoe morskoe bjuro mashinostroenija Malahit JSC) and Konstantin Golubev (Severnoe proektno-konstruktorskoe bjuro JSC and Tsentralnoe morskoe konstruktorskoe bjuro Almaz JSC).
Elections to the State Duma of the Russian Federation
Under Regulation No. 2292 blocking sanctions were imposed on 77 individuals: 74 candidates in the elections to the State Duma of the Russian Federation and three members of the Central Election Commission of the Russian Federation. According to the EU’s statements of reasons, the grounds for listing were participation in the conduct of the September 2026 elections in Crimea, Sevastopol, the DPR, the LPR, and the Zaporizhzhia and Kherson regions.
Among those included on the sanctions list were, in particular, the former Governor of the National Bank of Ukraine Sergei Arbuzov; the journalist and war correspondent Irina Kuksenkova; and the television presenter Polina Tsvetkova. Among the members of the Russian Central Election Commission, Alena Bulgakova, Anatoly Sysoev and Vasilina Kulieva were subject to sanctions.
EU sanctions under the North Korea programme
Separately, on 12 October 2026, the EU adopted Council Implementing Regulation (EU) 2026/2278 implementing Regulation (EU) 2017/1509, whereby the sanctions list under the programme concerning the DPRK was expanded to include three individuals and four legal entities.
In particular, blocking sanctions were imposed on Samolet Group PJSC and its CEO Anna Akinshina. According to the EU’s statements of reasons, the company has employed workers from the DPRK in its construction projects in Vladivostok in violation of sanctions imposed by the UNSC.
This list also includes the Russian companies PCC Black Horse LLC and Golden Autumn Agroholding LLC, as well as Vladimir Sokolov, in connection with their facilitation of commercial and industrial cooperation projects involving the DPRK.
New UK sanctions
On 8 October 2026, the UK announced the imposition of sanctions against three individuals, 23 legal entities and 12 vessels.In particular, blocking sanctions were imposed on:
- the oil companies Zarubezhneft JSC and INK-Capital JSC;
- entities operating in the financial sector, including CB Stolichny Kredit LLC, Planeta JSC, Xeltox Enterprises Ltd, Processing KG OJSC, TokenSpot CJSC and Tsunami Payments LLC, as well as Ulan Bukabaev; and
- Russian and foreign suppliers of machine tools, electronics and materials for the defence sector, including Prime Top LLC, Phobos Machines LLC, Albion LLC, ENEL LLC, the Turkish company Redwing Metal Uluslararasi Ticaret Anonim Sirketi and the Chinese company Goodway Machine (Wujiang) Co., Ltd. With regard to individuals associated with suppliers, sanctions were imposed, in particular, against Alexander Jan Hendrik Tattersall, a Dutch national.
With regard to the abovementioned financial institutions, in addition to blocking sanctions, UK credit and financial institutions are prohibited from maintaining correspondent banking relationships and processing payments to, from or through such entities.
As a reminder, UK blocking sanctions impose the following obligations on UK PersonsAny individuals within the UK, regardless of nationality; UK citizens, regardless of where they are located; UK-registered legal entities and their branches; any persons on board any aircraft or vessel under the jurisdiction of the UK (jointly – “UK Persons”). UK sanctions restrictions targeting Russia apply to British Overseas Territories (excluding Bermuda and Gibraltar).:
- to freeze (block) the assets of sanctioned persons: cash, securities, immovable and movable property, etc.; and
- to refrain from making funds or economic resources available, directly or indirectly, to sanctioned persons or for their benefit (in the absence of prior authorisation in the form of a licence).
The abovementioned restrictive measures also apply to legal entities that are directly or indirectly owned (more than 50%) or controlled by sanctioned persons.
At the same time, the UK regulator has issued General Licence No. INT/2026/11080040, authorising, subject to compliance with its conditions, the completion of operations and the winding up of transactions with Zarubezhneft JSC and organisations owned or controlled by it. The licence is valid until 21 November 2026.
Furthermore, 12 tankers involved in the transportation of Russian oil and petroleum products (among others, the vessels Alexander Nevskiy, Andrey Pervozvanniy, Pioneer, Vasily Surikov and Bellaris) have been included on the list of vessels subject to shipping and trade restrictions. The restrictions include, inter alia, prohibitions on such vessels entering UK ports, on their chartering and operation, and on the provision and receipt of related services, including technical assistance, crew services, brokering and financial services.
