Sanctions Essentials: EU Sanctions Developments, Enforcement Changes and Increased Compliance Expectations (July 2026)
Sanctions compliance continues to evolve rapidly, with recent developments highlighting both the expansion of restrictive measures and increasing expectations for businesses to maintain effective, risk-based controls.
This edition of Sanctions Essentials covers important regulatory updates, including Lithuania’s simplified enforcement procedure for sanctions-related fines, the CJEU’s guidance on sanctions screening and customer de-risking decisions, and the EU’s continued expansion and extension of sanctions regimes targeting Russia and other high-risk jurisdictions.
The latest developments demonstrate that sanctions compliance requires not only effective screening processes, but also documented risk assessments, enhanced counterparty due diligence and continuous monitoring of changing regulatory requirements. Businesses should ensure that their internal controls remain aligned with evolving enforcement practices and the increasing focus on sanctions circumvention risks.
- Lithuania Simplifies Enforcement of Sanctions-Related Fines
- CJEU Confirms That OFAC Listing Alone Does Not Automatically Justify Refusal of Basic Payment Accounts
- EU Extends Economic Sanctions Against Russia and Introduces Additional Restrictions
- EU Extends Sanctions Framework Against Destabilising Activities in Haiti
- EU Introduces Additional Sanctions Related to Moldova Destabilisation Activities
- EU Expands Iran Sanctions Related to Maritime Security Risks
- EU Restricts Certain Visa Measures for Somali Nationals
Lithuania Simplifies Enforcement of Sanctions-Related Fines
The Seimas adopted amendments to Article 18 of the Law on the Implementation of Economic and Other International Sanctions, changing the procedure for enforcing fines imposed for sanctions violations.
The amendments entered into force on 30 June 2026.
Under the revised framework, a final decision of a sanctions-supervising authority imposing a fine now constitutes an enforceable instrument itself. Once the decision becomes final, enforcement may proceed directly under the procedures established by the Law on Tax Administration and the Code of Civil Procedure, without requiring a separate court-issued enforcement title.
The new procedure shortens the enforcement process and allows a final sanctions fine decision to be enforced directly against the assets of the person subject to the fine.
Fine decisions adopted and becoming final before 30 June 2026 remain subject to the previous enforcement rules.
Why does it matter?
The amendment significantly changes the practical consequences of sanctions-related enforcement decisions.
Previously, an additional procedural step was required before enforcement could begin. Under the new regime, the period for challenging a fine decision becomes a critical stage, as once the decision becomes final, enforcement may proceed immediately.
For businesses subject to sanctions supervision, this increases the importance of timely internal escalation and legal assessment after receiving a fine decision.
Recommended actions
Businesses should:
- Treat the appeal period as the key timeframe for assessing and, where appropriate, challenging a sanctions-related fine decision.
- Review internal procedures to ensure sanctions enforcement decisions are escalated and assessed promptly.
- Confirm which enforcement regime applies to fines that became final on or before 29 June 2026.
Source: Seimas | Date: 2026-06-30
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CJEU Confirms That OFAC Listing Alone Does Not Automatically Justify Refusal of Basic Payment Accounts
In Case C-81/24 (Jenec), the Court of Justice of the European Union (CJEU) ruled that a customer’s inclusion on a US OFAC sanctions list is not, by itself, sufficient grounds for a bank to refuse opening a basic payment account.
The Court clarified that refusal is only justified following an individual assessment of money laundering and terrorist financing risks.
While inclusion on a third-country sanctions list may be considered as one relevant risk factor, it does not create an automatic prohibition under EU law.
The judgment interpreted the right of access to basic payment accounts under the Payment Accounts Directive together with obligations arising from the EU Anti-Money Laundering framework.
The decision reinforces the EU approach that sanctions and AML compliance decisions must be based on proportionate, individualized risk assessments.
Financial institutions cannot rely solely on automatic exclusion approaches based on non-EU sanctions lists where EU law requires a case-by-case assessment.
The judgment is particularly relevant for banks, payment institutions and EMIs managing customer onboarding and de-risking policies.
Recommended actions
Businesses should:
- Review de-risking and account-refusal policies to ensure they do not rely solely on third-country sanctions listings.
- Document individual risk assessments for customers identified through non-EU sanctions screening.
- Align onboarding refusal procedures with EU AML requirements and risk-based decision-making principles.
Source: EBA | Date: 2026-06-11
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EU Extends Economic Sanctions Against Russia and Introduces Additional Restrictions
The Council of the European Union adopted further sanctions measures against Russia and extended the existing EU economic sanctions framework for another 12 months, until 31 July 2027.
The extension maintains restrictions covering key sectors, including trade, finance, energy, dual-use technologies and certain financial transactions.
The EU also continued restrictions targeting Russian and third-country financial institutions and crypto-asset service providers connected with prohibited activities.
In a separate sanctions package adopted on 15 June 2026, the EU added additional individuals and entities connected with:
- Russia’s military-industrial complex;
- Drone and military-equipment supply chains;
- Shadow-fleet and energy-related activities;
- Hybrid activities and disinformation operations;
- Human rights violations.
The new listings include entities connected with third-country networks and circumvention risks.
Why does it matter?
The developments confirm that the EU sanctions framework against Russia remains active and continues expanding rather than moving towards relaxation.
Businesses should not rely on expiry dates as indicators of reduced compliance obligations. Instead, sanctions exposure should be continuously reassessed, particularly regarding supply chains, counterparties and third-country intermediaries.
The growing focus on circumvention also increases the importance of understanding indirect ownership, control structures and trading routes.
Recommended actions
Businesses should:
- Maintain Russia-related sanctions controls through at least 31 July 2027.
- Screen customers, counterparties, suppliers and ownership structures against newly designated persons and entities.
- Review exposure to third-country intermediaries, shadow-fleet activities and energy-related transactions.
- Ensure crypto-asset transfer controls reflect restrictions applicable to Russian and third-country crypto-related entities.
- Monitor further developments, including potential future sanctions packages.
Source: EU Council| Date: 2026-06-25
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Source: EU Council| Date: 2026-06-15
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EU Extends Sanctions Framework Against Destabilising Activities in Haiti
The Council of the European Union extended the EU restrictive measures against persons responsible for threatening peace, stability and security in Haiti or undermining democracy and the rule of law.
The sanctions framework has been extended until 29 July 2027 following the annual review of the regime.
The current measures apply to nine individuals and one entity and include:
- Asset freezes;
- Prohibition on making funds or economic resources available to listed persons or entities;
- Travel restrictions for listed individuals.
Why does it matter?
Although the Haiti sanctions regime remains limited in scope, the extension confirms that existing designations remain active and require continued screening.
Businesses with relevant geographic exposure should ensure that sanctions controls continue reflecting current EU measures.
Recommended actions
Businesses should:
- Re-screen customers and counterparties against the updated EU Haiti sanctions list.
- Ensure payment screening and transaction-monitoring systems continue treating the regime as active through July 2027.
Source: EU Council| Date: 2026-06-26
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EU Introduces Additional Sanctions Related to Moldova Destabilisation Activities
The Council of the European Union listed six individuals responsible for actions aimed at destabilising the Republic of Moldova.
The listed individuals include members of successor entities linked to the outlawed ȘOR party and associates involved in Russian-funded activities aimed at disrupting Moldova’s democratic processes.
The new listings bring the Moldova sanctions regime to 29 individuals and five entities.
All listed persons and entities are subject to asset freezes, while listed individuals are also subject to travel bans.
Why does it matter?
The decision highlights the expanding scope of EU sanctions beyond traditional financial and trade restrictions, increasingly covering hybrid threats and foreign interference activities.
Businesses with connections to Moldova or related regional networks should consider broader risk indicators when assessing sanctions exposure.
Recommended actions
Businesses should:
- Add the newly designated persons and entities to sanctions screening systems.
- Consider Russia-linked election-interference risks when assessing counterparties and ownership structures.
Source: EU Council | Date: 2026-06-15
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EU Expands Iran Sanctions Related to Maritime Security Risks
The Council of the European Union listed two individuals and one entity under the EU Iran restrictive measures framework.
The designations target activities threatening freedom of navigation and preventing vessels from entering or leaving the Strait of Hormuz.
The measures follow the expansion of the sanctions framework to cover individuals and entities involved in Iran’s actions affecting maritime security, alongside existing concerns related to military support and regional destabilisation.
Why does it matter?
The development demonstrates the increasing relevance of sanctions exposure in maritime, shipping and energy-related sectors.
Businesses operating in international trade should consider not only direct sanctions exposure but also connections through vessels, logistics providers and trading counterparties.
Recommended actions
Businesses should:
- Add new Iran-related designations to sanctions screening systems.
- Review maritime, shipping and energy-sector counterparties for links to designated entities.
- Consider the broader sanctions context when assessing Iran-related exposure.
Source: EU Council | Date: 2026-06-08
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EU Restricts Certain Visa Measures for Somali Nationals
What happened?
The Council of the European Union adopted temporary restrictions affecting visa procedures for Somali nationals following an assessment of insufficient cooperation regarding readmission of persons staying irregularly in the EU.
The measures include restrictions on multiple-entry visas, certain exemptions and longer processing periods.
Why does it matter?
The measure is primarily a migration-related restrictive measure rather than a financial sanctions regime.
However, it demonstrates the broader use of EU restrictive measures as a foreign policy tool beyond traditional asset freezes and financial restrictions.
Source: EU Council | Date: 2026-06-25
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Need assistance?
Our sanctions compliance specialists assist businesses in navigating increasingly complex international sanctions requirements.
We can assist with:
- Sanctions compliance assessments
- Sanctions screening and risk reviews
- Internal policies and procedures
- Supply chain and counterparty risk analysis
- Regulatory investigations and enforcement matters
- Sanctions-related business structuring and compliance advice
Contact us to discuss how evolving sanctions requirements may affect your business.
About the Author:
Inga Karulaitytė is an attorney-at-law, Partner, and Head of Banking, Finance & FinTech at ECOVIS ProventusLaw — a recognised expert in FinTech and digital finance regulation in Lithuania and the Baltics. She is consistently ranked in FinTech Legal by Chambers and Partners and recognised as a Highly Regarded lawyer in Banking and Finance by IFLR1000, Chambers and Partners, and The Legal 500.
Inga is a Certified Anti-Money Laundering Specialist (CAMS), a Certified Global Sanctions Risk Management Specialist, a certified board member (Corporate Governance Certificate by BICG), and a Certified Internal Auditor.
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