Implementing Regulation (EU) 2026/2165 and Its Implications for Businesses

On September 24, 2026, the Implementing Regulation (EU) 2026/2165 was published, amending the previous Regulation (EU) 2024/2642. The primary aim of this regulation is to enhance and expand restrictive measures against Russia due to its destabilizing activities in the European Union. With these new changes, an individual has been added to the sanctions list. This decision carries significant implications for business operators who need to be informed of all changes and updates.

What changes

The new Implementing Regulation (EU) 2026/2165 adds the individual Xenia Fedorova to the list of those subject to restrictive measures under Regulation (EU) 2024/2642. Fedorova is sanctioned for spreading misinformation and pro-Russian propaganda, further undermining stability and security within the European Union.

Who is affected

The regulation primarily targets individuals and entities already on the EU's sanctioned listings. In this case, it directly affects Xenia Fedorova but also impacts all businesses potentially associated with her or other sanctioned entities under the regulation. Business operators should conduct thorough checks of their associates to avoid violating sanctions.

Dates and deadlines

The regulation enters into force and applies directly on the day of its publication in the Official Journal of the European Union, that is, on September 24, 2026. There are no additional specific deadlines or grace periods related to the application of this regulation.

Practical next steps

Business operators need to review their list of partners and clients to ensure they are not engaging in business with newly sanctioned individuals. Additionally, they should regularly monitor updates to the EU's sanctions lists and establish mechanisms for rapid response to future changes. It may also be necessary to seek legal advice to ensure full compliance with the new adjustments.

What to check for your situation

The document does not introduce new legal duties for all businesses but rather extends existing sanction measures. Therefore, compliance with these sanctions is specific to sectors and businesses that have direct or indirect relationships with sanctioned individuals and organizations.