22nd Sanctions Package Checklist

🔐 PLAYBOOK: Download the EU Russia 22nd Sanctions Package Compliance Checklist to identify potential exposure, review counterparties and strengthen your sanctions controls.

About this Playbook

The European Union's October 2026 sanctions actions have increased the importance of effective counterparty screening, supply-chain visibility and sanctions due diligence.

On 12 October, the Council adopted its largest-ever single set of listings under the Russia sanctions regime, targeting 1,569 individuals and entities connected to Russia's military-industrial complex. The listings included 826 Russian companies and 743 individuals serving as company CEOs. On 15 October, the Council separately listed three individuals and nine entities involved in sanctions circumvention, including intermediaries connected to logistics, payments, parallel imports and oil trading.

For businesses operating in or trading with the EU, the practical challenge extends beyond checking whether a customer's or supplier's name appears on a sanctions list. Companies must also assess indirect relationships, investigate potential matches and determine whether transactions could involve listed persons or make funds or economic resources available to them.

This Implementation Playbook translates these developments into a structured compliance review. Across five phases, it helps trade compliance professionals update screening controls, assess counterparty exposure, examine supply-chain relationships, investigate potential matches and maintain a defensible audit trail.

Use the accompanying checklist to assign responsibilities, record findings, identify information gaps and track outstanding actions.

Important: This playbook provides an operational framework, not a substitute for legal advice. The applicable EU regulations, current consolidated sanctions lists and any relevant authorisations or exceptions must be checked before decisions are made about individual transactions.

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