CLIENT ALERT

Russia sanctions update: EU adopts its largest-ever round of listings; steel quotas reduced and Fridman and Usmanov delisted

October 13, 2026

Read time: 7 min

Overview

On 12 October 2026, the EU adopted its largest-ever round of Russia-related sanctions listings, adding 1,569 individuals and entities linked to Russia’s military-industrial complex. The new designations significantly expand the scope of EU asset freezes and screening requirements, but do not introduce new sectoral, trade, energy, or financial restrictions.
Two other recent EU sanctions developments are also relevant for businesses:

  • the reduction in import quotas for certain Russian semi-finished steel products;
  • the EU delisting of Mikhail Fridman and Alisher Usmanov.

Separately, the US has temporarily eased certain sanctions relating to Russian-origin diesel following a reported US-Russia supply agreement.

In depth

EU adopts largest-ever round of listings targeting Russia’s military-industrial complex

On 12 October 2026, the EU Council adopted restrictive measures against 1,569 individuals and entities in Russia’s military-industrial complex, comprising 826 Russian companies and 743 individuals serving as their CEOs. Separately, the Council listed 77 individuals involved in the illegal State Duma “elections” held in September 2026 in occupied Ukrainian territories. According to the Council, this is the single largest set of listings ever agreed by the EU, bringing the total number of listings under the regime to close to 4,600.

The listings were adopted under the EU’s asset freeze regime (Regulation (EU) No 269/2014). Listed persons are subject to an asset freeze and a prohibition on making funds or economic resources available to them, directly or indirectly; listed individuals are also subject to travel restrictions. Unlike a typical numbered sanctions package, the measures do not introduce new sectoral, trade, energy, or financial restrictions. Work on a further, 22nd package continues (see below).

Key features of the listings include:

  • Focus on mid-level suppliers forming the “core” of Russia’s defence industry. Listed companies supply key components for missiles, UAVs and aircraft, including electronics and semiconductors, radars and communications equipment, explosives and ammunition, and optics and navigation systems.
  • A list-based designation approach: The listings largely rely on the entity having been identified by the Russian Government as part of the military-industrial complex and extend beyond pure defence manufacturers to broader industrial companies, including, for example, AO Severstal Kanaty, a steel wire rope producer.

Given the volume of new names, and the fact that entities owned or controlled by listed persons may also be caught, businesses should promptly update screening tools and review existing Russian counterparties, distributors, and supply chain relationships, including in the industrial and metals sectors.

Other recent EU sanctions developments

Steel quotas reduced. The quota arrangements under Article 3g for Russian semi-finished iron and steel products (CN codes 7207 12 10 and 7224 90) entered a new period on 1 October 2026, with reduced quota volumes now applying until 30 September 2027 and further reductions until 30 September 2028, when the remaining transitional arrangements expire.

As the restrictions also capture third-country products incorporating Russian-origin inputs specified in Annex XVII, companies sourcing steel products from jurisdictions outside Russia cannot rely solely on the country of export or customs origin and should assess whether Russian-origin inputs were used, taking account of the applicable transitional arrangements.

Businesses that previously relied on transitional arrangements for Russian products should review their supply chains carefully to ensure that imports remain permissible under the reduced quotas and applicable restrictions.

Fridman and Usmanov delisted. On 22 September 2026, the EU removed Mikhail Fridman and Alisher Usmanov from its Russia sanctions list. Latvia and Estonia have imposed national sanctions against both individuals, while Lithuania has proposed national measures. The delisting does not affect their position under UK or US sanctions, so counterparty screening should continue to account for national, UK, and US restrictions.

US diesel sanctions easing. Separately, following a reported US-Russia agreement on Russian diesel supplies, OFAC issued General License 135 on 9 October 2026, temporarily authorising certain transactions involving Russian-origin diesel until 7 April 2027. Other US sanctions on Russia remain in place.

Looking ahead: proposed 22nd Russia sanctions package

The EU is continuing work on a further package of Russia-related sanctions, following adoption of the 21st package in July 2026. The 12 October listings are separate from the proposed 22nd package, which has not yet been formally adopted. EU officials have signalled interest in measures concerning Russia’s military-industrial complex, sanctions circumvention, shadow fleet, financial actors, and crypto exchanges. The scope and timing remain under discussion.

Authors

Raminta Dereskeviciute

Partner

London – 22 Bishopsgate

Sabine Naugès

Partner

Paris

Ludovica Rabitti

Senior Associate

London – 22 Bishopsgate

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