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Situation report for companies, Blockades directly

Russia sanctions in 2026: circumvention, the contract clause and tougher criminal law

· Helfen statt Blockieren editorial team

Anyone supplying third countries in 2026 needs to know more precisely where the goods end up. In October the EU adopted its largest listing round so far, and since February sanctions breaches carry heavier criminal penalties in Germany. A situation report for companies without their own sanctions department.

What is new in 2026

On 23 July 2026 the Council adopted the 21st sanctions package (Regulations (EU) 2026/1844, 2026/1846 and 2026/1848). It adds, among other things, import bans on copper, nickel and lead ores, zinc products, glassware and car parts from Russia, further export bans on metal powders, alloys and drone technology, and listings of 51 companies in China, Türkiye, India, Kazakhstan, Kyrgyzstan and the United Arab Emirates. More than 100 Russian banks are subject to transaction restrictions.

On 12 October 2026 a further 1,569 entries followed, 743 individuals and 826 companies, mainly from the military-industrial complex. This round is the listing package of 12 October 2026; it contains no new trade restrictions. The 22nd package has been announced. The Russia regime has been extended to 22 September 2029.

What this means for contracts

Since 20 March 2024, Article 12g of Regulation (EU) No 833/2014 requires a clause in contracts for certain goods going to third countries: re-export to Russia and for use in Russia must be contractually prohibited. The goods concerned include those in Annexes XI, XX, XXXV and XL, among them aviation goods, firearms and common high priority items such as semiconductors. Deliveries to the partner countries in Annex VIII, such as the United States, Japan, the United Kingdom and Switzerland, are exempt. The Commission offers model wording in its FAQ. A similar obligation applies to Belarus under Article 8g of Regulation (EC) No 765/2006.

What is a criminal offence in Germany

Since 6 February 2026, the amended Foreign Trade and Payments Act has implemented EU Directive 2024/1226. Certain acts of circumvention, such as concealing frozen funds, are now criminal offences. Reckless breaches of certain export bans on dual-use items can be punished with up to three years in prison. The former grace period of two working days after new listings are published has been abolished. The maximum corporate fine for sanctions offences committed by managers rises from 10 to 40 million euros. Humanitarian aid remains exempt from punishment in certain cases.

What companies should check now

  • Is the Article 12g clause in every affected contract, including framework agreements and contracts with distributors?
  • Are customers and their owners screened again after every publication in the Official Journal, not only at the next order?
  • Is there a documented plausibility check of quantity and end use for deliveries to countries with a high risk of circumvention?

Due diligence is mandatory. It does not require companies to refuse permitted business with customers who have no link to Russia at all. This line between obligation and excessive caution is what Helfen statt Blockieren is about. This report is not legal advice for individual cases.

Sources

All online sources accessed on 3 November 2026.

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