Tabla de contenidos
European Union
Russia
As part of its sanctions regime against Russia, the European Union continues to reinforce its economic pressure strategy, while the 20th package of restrictive measures remains pending approval, currently blocked in the Council due to Hungary’s position.
Notably, on 2 February 2026, the Regulation (EU) 2026/261 of the European Parliament and of the Council of 26 January 2026 on the phasing out of Russian natural gas imports and the preparation for the phasing out of Russian oil imports, improving the monitoring of potential energy dependencies and amending Regulation (EU) 2017/1938 was published in the Official Journal of the European Union (OJEU), which entered into force on 3 February as part of the European REPowerEU plan.
The regulation introduces a gradual ban on imports of natural gas, both by pipeline and in the form of LNG, originating directly or indirectly from the Russian Federation, with different deadlines depending on the type of existing contract (short or long term) and with limited temporary exemptions for contracts signed before 17 June 2025. In this regard, Article 7.1 of the Regulation establishes that the competent authority for granting prior authorisation for such exemptions shall, as a general rule, be the customs authority, unless the Member State expressly designates another authority. In the case of Spain, this power has been assigned to the Customs and Excise Duties Department of the Spanish Tax Agency, to which information relating to natural gas supply contracts and their country of production must be submitted. In addition, Article 8 of the Regulation requires Member States to establish effective, proportionate and dissuasive penalties for non-compliance, setting thresholds of 3.5% of global annual turnover, EUR 40 million or up to 300% of the estimated value of the transaction concerned for legal persons and a minimum of EUR 2.5 million for natural persons.
In this regard, although Spain has made progress in diversifying its energy supply and now relies largely on partners such as Algeria and the United States, it continues to maintain imports and contracts linked to the supply of natural gas from Russia, which introduces an element of complexity in adapting to this new regulatory framework.
Regulation 2026/261 also introduces the obligation for Member States to draw up national diversification plans with the aim of completely eliminating Russian oil supplies by the end of 2027. These plans must detail the current volume of imports, the measures planned to replace them (including alternative sources and routes), as well as the milestones and timetable for phasing them out. They must also incorporate mechanisms to ensure the traceability of the origin of crude oil and prevent its relabelling, assess possible national bans and analyse technical, contractual or regulatory obstacles that may hinder the transition. Member States must submit these plans to the Commission by 1 March 2026, which may issue recommendations if it identifies risks of non-compliance. The process will also be supported by technical assistance and coordination at European level in order to minimise impacts on national and regional energy systems.
Furthermore, on 23 February, the Council adopted Council Decision (CFSP) 2026/432 amending Decision (CFSP) 2024/1484 concerning restrictive measures in view of the situation in Russia and Council Implementing Regulation (EU) 2026/431 implementing Regulation (EU) 2024/1485 concerning restrictive measures in view of the situation in Russia, which amend respectively the sanctions regime established by Decision (CFSP) 2024/1484 and Regulation (EU) 2024/1485 in response to developments in the internal situation in Russia, particularly in the field of human rights. Following Russia’s withdrawal from the European Convention for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (1987) on 30 September 2025, the European Union decided to strengthen existing restrictive measures by adding eight new individuals to the list of sanctioned persons.
Finally, on the fourth anniversary of the conflict in Ukraine, Decision (CFSP) 2026/438 of 23 February 2026 was adopted, amending Decision (CFSP) 2022/266 concerning restrictive measures in response to the recognition, the illegal occupation or annexation by the Russian Federation of certain areas of Ukraine not controlled by the Government, extending until 24 February 2027 the restrictions applicable to the Donbas region (i.e. the provinces of Donetsk and Luhansk) not controlled by the Ukrainian Government. These measures maintain the ban on imports of goods originating in those territories, unless certified by the Ukrainian Government, and reinforce restrictions on trade in goods, technology and services in key sectors such as transport, telecommunications, energy and the exploitation of natural resources.
Zimbabwe
On 18 February 2026, Council Decision (CFSP) 2026/383 of 17 February 2026 amending Decision 2011/101/CFSP concerning restrictive measures in view of the situation in Zimbabwe and Council Regulation (EU) 2026/384 of 17 February 2026 amending Regulation (EC) No 314/2004 concerning restrictive measures in view of the situation in Zimbabwe.
As a result of its annual review of the sanctions regime, the Council has decided to extend the arms embargo until 20 February 2027, while lifting the individual measures previously in force, consisting of travel bans and the freezing of assets.
Sanctions against terrorism
On 19 February 2026, the European Union formalised the political agreement reached at the end of January to include Iran’s Islamic Revolutionary Guard Corps on the list of terrorists through Council Decision (CFSP) 2026/421 amending Decision (CFSP) 2025/1577 updating the list of persons, groups and entities to which Common Position 2001/931/CFSP on the application of specific measures to combat terrorism applies, as well as the corresponding Council Implementing Regulation (EU) 2026/420, implementing Article 2(3) of Regulation (EC) No 2580/2001 on specific restrictive measures directed against certain persons and entities with a view to combating terrorism.
In response, Iran has decided to designate the naval and air forces of all European Union Member States as terrorist organisations.
However, on 26 February 2026, the Council adopted Council Decision (CFSP) 2026/455 on restrictive measures to combat terrorism, with the aim of consolidating into a single instrument the restrictive measures and related exemptions that had until then been dispersed across Common Position 2001/931/CFSP and its subsequent updating decisions. This Decision expressly repeals Articles 2, 3 and 3a of Common Position 2001/931/CFSP, as well as Decisions (CFSP) 2025/1577 and 2026/421, incorporating their substantive content into a more coherent and unified legal framework.
From a legal standpoint, the new instrument preserves the core elements of the regime, centred on the freezing of funds and the prohibition on making economic resources available to designated persons, while broadening its scope to explicitly include senior members, governing structures and associated individuals involved in financing, planning, facilitating, training or recruitment linked to terrorist activities. It also introduces, in a structured manner, the possibility of imposing entry bans or transit restrictions within the territory of the Union.
Compared with the previous framework, the principal development lies in the consolidation of the legal regime and the expansion of the personal scope of the measures, which now extend beyond direct perpetrators to encompass supporting networks and affiliated structures. The Decision further provides more precise definitions of terrorist acts and structured groups, adapts the regime to evolving threats, including those of a digital nature, and preserves existing procedural safeguards.
United States
Russia
On 24 February 2026, the Treasury Department, through OFAC, imposed sanctions against a Russian citizen and his company Matrix LLC (operating as Operation Zero), as well as five associated individuals and entities, for their alleged involvement in the acquisition and commercialisation of sensitive cyber tools stolen from the United States.
According to the authorities, the network allegedly acted as an intermediary in the purchase and distribution of exploits, including tools developed for the exclusive use of the US Government and its allies, which were subsequently transferred to unauthorised users. The action was taken under Executive Order 13694 and also constitutes the first application of the Protecting American Intellectual Property Act (PAIPA), which allows for the punishment of misappropriation of trade secrets with potential impact on national security.
As a result of the designations, the assets of the sanctioned individuals under US jurisdiction are blocked and transactions with US persons are prohibited, extending also to entities controlled 50% or more by the designated individuals.
Iran
On 2 February 2026, OFAC announced new designations targeting networks involved in the illicit trade of Iranian oil and the use of maritime structures linked to the so-called ghost fleet. In this context, four individuals, 15 entities and 12 vessels were added to the Specially Designated Nationals (SDN) list, all of which are allegedly used to facilitate energy exports outside authorised channels and support Iranian strategic activities.
Subsequently, on 25 February 2026, OFAC adopted a new package of designations related to the proliferation and support of ballistic missile and conventional weapons programmes, as well as networks linked to the illicit transport of Iranian oil through the ‘ghost fleet‘. On this occasion, six individuals, 14 entities and 14 vessels were added to the SDN list ; linked to industrial and logistical supply networks, structures used to facilitate energy exports and the acquisition of sensitive machinery, chemical precursors and technology linked to military programmes.
Sudan
On 19 February 2026, three individuals associated with the Rapid Support Forces (RSF) were added to the SDN list for their alleged involvement in abuses and in undermining the peace process in the conflict affecting Sudan since 2023.
Counterterrorism designations
On 10 February 2026, OFAC adopted new designations under its counterterrorism regime targeting financial operatives linked to Hezbollah. In total, two individuals, four entities, and two vessels were added to the SDN list. The measures focus on networks allegedly used to facilitate financial and logistical support to the organisation, including commercial and maritime structures.
Venezuela
In February 2026, OFAC issued several general licences introducing limited flexibilities within the Venezuela sanctions regime.
On 3 February, General Licence No. 47 authorised the export and supply of US-origin diluents to Venezuela, including associated logistical and financial operations, provided that the contracts are governed by US law and subject to US jurisdiction. The authorisation excludes certain payment methods, transactions with specifically restricted countries, and any transactions involving previously blocked assets.
On 10 February 2026, OFAC also issued General Licence No. 46A, which authorises certain activities related to the lifting, export, marketing and transport of Venezuelan-origin petroleum by US entities established before 29 January 2025. The licence allows, under specific conditions, operations involving PDVSA or entities under its control, including logistics, refining and reasonable commercial payments, provided that the contracts are governed by US law and payments to blocked parties are channelled to accounts designated by the Treasury. However, the authorisation maintains significant limitations, excluding transactions with certain countries such as Russia, Iran, North Korea or Cuba, with entities linked to China in certain cases, as well as operations involving blocked assets or sanctioned vessels. It also establishes a requirement for periodic reporting on the operations carried out. This licence replaces General Licence No. 46 and constitutes a technical adjustment to the current regime that allows certain energy operations without lifting the structural restrictions on Venezuela.
Subsequently, on 13 February, General Licence No. 49 allowed the negotiation and signing of conditional contracts for new investments in the Venezuelan oil and gas sector. These activities may include preliminary agreements, technical evaluations or the creation of new business structures, although the effective implementation of such projects requires additional authorisation from OFAC.
These measures were complemented on 18 February by the publication of new frequently asked questions (FAQs) aimed at clarifying the operational scope of the licences, reflecting a technical adjustment to the regime without lifting existing structural restrictions.
Cuba
On 25 February 2026, OFAC published FAQ 1238, clarifying that it will apply a favourable policy for granting specific licences to authorise the resale of Venezuelan oil to Cuba, provided that the transactions substantially comply with the terms of General Licence 46A and are intended to directly support the Cuban people, including the private sector or humanitarian purposes. This guidance does not extend to transactions that benefit the Cuban state apparatus, in particular the armed forces, intelligence services or entities included in the Cuba Restricted List. The clarification is part of the executive order adopted on 29 January 2026, which intensified economic pressure on third countries supplying oil to the island, and reflects an approach that combines the maintenance of structural restrictions with the possibility of authorising operations that have a direct impact on the civilian population.
Nicaragua
On 26 February 2026, OFAC sanctioned five senior Nicaraguan officials who head key institutions in the financial, labour, telecommunications, and military intelligence sectors for their role in sustaining the Murillo-Ortega regime. These measures were adopted in the context of constitutional reforms aimed at consolidating executive power, restricting civil liberties, and strengthening state control mechanisms.
Designations against drug trafficking
On 19 February 2026, OFAC added new designations linked to the Jalisco New Generation Cartel (CJNG), including 5 individuals and 18 entities related to a timeshare fraud network allegedly used to channel illicit funds.
Afghanistan
OFAC has issued General Licence No. 20, which authorises certain transactions involving Afghanistan or its government institutions under US counter-terrorism sanctions regimes. The measure allows transactions that would otherwise be prohibited under Executive Order 13224 and regulations related to global terrorism and foreign terrorist organisations.
However, the authorisation maintains key restrictions, including a prohibition on financial transfers to the Taliban, the Haqqani network, or entities under their control, except for limited payments necessary for administrative obligations such as fees, permits, or utilities. Furthermore, the licence does not permit transactions with other blocked persons or access to frozen assets.
United Kingdom
Russia
On 24 February 2026, coinciding with the fourth anniversary of the conflict, the United Kingdom announced a new package of sanctions against Russia, one of the most comprehensive to date. The measures include nearly 300 new designations targeting key sectors of the Russian economy, with a particular focus on energy revenues and supply chains that sustain the war effort.
Among the targets are the state-owned pipeline company Transneft, a network of 175 companies linked to Russian crude oil trading and the ghost fleet, as well as 48 vessels used for oil transportation. The package also includes sanctions against entities and individuals involved in the supply of military components, the LNG sector, the civil nuclear energy sector and nine financial institutions that facilitate cross-border payments.
The aim of these new measures is to strengthen and restrict the Russian Federation’s external sources of financing and limit its access to strategic goods, technology and services, in line with coordinated efforts with other international partners.
Iran
On 2 February 2026, the United Kingdom announced the adoption of new sanctions targeting ten individuals and one organisation in connection with their alleged involvement in the response to protests in Iran. The measures include asset freezes, travel bans and disqualification from holding corporate directorships.
Among those designated are the Islamic Republic of Iran’s Disciplinary Force, responsible for policing the protests, as well as senior institutional officials, police commanders, members of the Islamic Revolutionary Guard Corps and a businessman linked to the financing of its activities.
According to the British authorities, these sanctions are based on the involvement of those designated in actions that allegedly included the use of force, arbitrary arrests and other restrictive measures against demonstrators.
Sudan
On 5 February 2026, the United Kingdom adopted new sanctions against six individuals in connection with their alleged involvement in the conflict in Sudan, including commanders associated with both the Rapid Support Forces (RSF) and the Sudanese Armed Forces (SAF), as well as individuals linked to the financing of the conflict and the recruitment of foreign fighters. The measures include asset freezes and financial restrictions and are part of the UK’s efforts to put pressure on actors contributing to the conflict.
The UK also updated its national sanctions list again on 25 February 2026, introducing changes to four designations affecting senior commanders linked to the Rapid Support Forces (RSF), following their recent inclusion on the UN sanctions list under Resolution 1591 (2005).
United Nations
Afghanistan
The Security Council unanimously adopted Resolution 2816 (2026) on 24 February 2026, extending for twelve months the mandate of the team responsible for monitoring compliance with the sanctions regime against the Taliban and associated entities. This instrument reaffirms the measures established in Resolution 2255 (2015), including the freezing of assets, the travel ban and the arms embargo applicable to individuals, groups, undertakings and entities associated with the Taliban that are included in the list established pursuant to Resolution 1988 (2011) and that constitute a threat to the peace, stability and security of Afghanistan.
The renewal of the mandate of the monitoring team, established under the sanctions regime set out in Resolution 1988 (2011), is intended to continue assessing the degree of compliance with these measures, detect possible non-compliance and make recommendations to the relevant Sanctions Committee.
Sudan
The Security Council Sanctions Committee, established pursuant to Resolution 1591 (2005) concerning Sudan, agreed on 24 February 2026 to add four new individuals to its Sanctions List. The new designations concern senior commanders linked to the Rapid Support Forces (RSF), including operational and commanders in Darfur.
As a result of their inclusion on the list, these individuals are subject to the measures adopted by the Security Council under Chapter VII of the United Nations Charter, including an asset freeze, a travel ban and an arms embargo. This update is part of the ongoing monitoring of the UN sanctions regime in relation to the situation in Sudan and its implications for regional peace and security.
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En Madrid, 28 de febrero de 2026
Departamento de Comercio y Sanciones Internacionales
Lupicinio International Law Firm
