Welcome to This Month in EU Sanctions — briefings and podcast episodes at the crossroads of EU law, foreign policy, and corporate compliance. Stay ahead in a fast-evolving EU sanctions and export control landscape by subscribing to the newsletter and podcast. For March 2026, here are the main updates.
New EU Sanctions
Iran
On 16 March 2026, the Council of the European Union (the “Council”) imposed new sanctions an additional 16 persons and three entities over serious human rights violations in Iran for their involvement in serious human rights violations. The new sanctions focus on key figures and organizations responsible for the violent suppression of street protests in January 2026, which resulted in thousands of civilian casualties. The new listings include:
Iran’s Deputy Minister of the Interior for Security and Law Enforcement Affairs;
Commanders from local branches of the Islamic Revolutionary Guard Corps (”IRGC”), including the Mohammad Rasulullah Corps in Tehran and the Imam Reza IRGC in Khorasan Razavi Province;
Members of the judiciary who have participated in the prosecution of peaceful protesters, civil activists, women’s rights advocates, journalists, and political dissidents;
Naji Research and Development Company (NRDC), an IT firm behind the Nazer mobile app used by Iranian authorities for citizen surveillance, and the Head of Tehran’s Cyber Police, who plays a central role in internet censorship and the prosecution of citizens over digital content.
With these latest additions, the EU’s sanctions for human rights abuses in Iran now cover 263 individuals and 53 entities (See Council Implementing Decision (CFSP) 2026/645 and Council Implementing Regulation (EU) 2026/648). On 30 March 2026, the Council extended the Iran human rights sanctions regime until April 2027. The same day, it also updated the nuclear-related sanctions on Iran to reflect changes to the EU dual-use regulation.
Cyber Attacks
On 16 March 2026, the Council sanctioned three entities and two individuals for their involvement in cyber-attacks targeting EU member states and partners. The new listings include:
Integrity Technology Group (China) for providing products used to compromise and access over 65,000 devices across six EU member states between 2022 and 2023.
Anxun Information Technology (China) for offering hacking services targeting critical infrastructure in EU member states and third countries. Two of its co-founders were also sanctioned for their direct involvement in these cyber-attacks.
Emennet Pasargad (Iran) for unlawfully accessing a French subscriber database, advertised stolen data on the dark web, compromised advertising billboards to spread disinformation during the 2024 Paris Olympic Games, and disrupted a Swedish SMS service affecting numerous EU citizens.
The EU’s horizontal cyber sanctions regime now applies to 19 individuals and seven entities (See Council Decision (CFSP) 2026/588 and Council Implementing Regulation (EU) 2026/589).
Russia Hybrid Threats
On 16 March 2026, the Council sanctioned four individuals for their involvement in Russia’s hybrid activities, specifically Foreign Information Manipulation and Interference (FIMI) targeting the EU, its member states, and partners. The new listings include:
Sergey Klyuchenkov (Russia) for spreading disinformation to justify Russia’s war against Ukraine, advocates for violence in Ukraine (including against civilians), and promotes the occupation of Baltic states and retaliatory strikes against Ukraine’s supporters (including the US, Türkiye, Germany, France, UK).
Ernest Mackevičius (Lithuanian-born, Russia), hosting a Russian state TV evening news programme, regularly disseminating false narratives about Russia’s war in Ukraine and the Ukrainian armed forces.
Graham Phillips (UK) for justifying Russia’s war through disinformation, films propaganda content in Russian-occupied Ukrainian territories, and writes articles supporting Russia’s occupation.
Adrien Bocquet (France) for amplifying Kremlin propaganda in Europe and Russia through appearances at conflict sites, interviews on Russian TV, and contributions to Kremlin-funded outlets.
The EU’s restrictive measures for Russia’s destabilising activities now apply to 69 individuals and 17 entities (See Council Decision (CFSP) 2026/646 and Council Implementing Regulation (EU) 2026/647. Relatedly, the Council adopted conclusions on advancing the EU’s capacity to counter hybrid threats.
Russian aggression against Ukraine
On 14 March 2026, the Council extended individual listings over Ukraine’s territorial integrity for a further six months. On 16 March 2026, the Council sanctioned nine individuals for their major role in the Bucha massacre (February–March 2022). EU’s sanctions under this regime now apply to around 2,600 individuals and entities (See Council Decision (CFSP) 2026/614 and Council Implementing Regulation (EU) 2026/615).
Policy Developments
Ukraine
On 19 March 2026, the European Council noted in its conclusions on Ukraine that:
The European Union remains determined to further increase pressure on Russia and continue weakening Russia’s war economy so that it stops its brutal war of aggression and engages in meaningful negotiations towards peace. The European Council looks forward to the swift adoption of the 20th sanctions package. It reiterates the importance of further reducing Russia’s energy revenues and further constraining Russia’s banking system, and took stock of efforts to curb Russia’s shadow fleet operations. Undermining the Russian shadow fleet’s business model requires a ‘whole of route’ approach, including by addressing through a common approach the significant environmental, security and maritime safety risks posed by such vessels. In this respect, the European Council calls for further efforts and coordinated action by Member States. It also stresses the importance of continued coordination with G7 and other like-minded partners on sanctions, of strengthening the enforcement of existing measures and closing loopholes, and of further reinforcing the anti-circumvention measures.
In a 31 March 2026 statement, Kaja Kallas noted, among other things:
The way to end this war is to confront Moscow, not reward it. Not to loosen sanctions, but to harden them. The 20th package is ready to go, and we will tighten the net even further, especially around Russia’s shadow fleet.
Middle East
In a 1 March 2026 statement on behalf of the European Union on developments in the Middle East, HR VP Kaja Kallas noted, in relevant parts:
The European Union has adopted extensive sanctions in response to the actions of Iranian authorities, whether their brutal repression and human rights violations against the Iranian people or threats to the region and to European and international security, through Iran’s ballistic missile and nuclear programmes, and its support for armed groups in the Middle East. We will continue to protect EU security and interests, including through additional sanctions. The European Union has consistently urged Iran to end Iran’s nuclear programme, curb its ballistic missile programme, refrain from destabilizing activities in the region and in Europe, and to cease the appalling violence and repression against its own people.
In a 9 March 2026 statement, President Costa and President von der Leyen noted, after the video conference with Leaders from Middle East countries on the war in Iran that “[...] The European Union has been consistent in its position on Iran’s activities and has repeatedly called on their leadership to end its nuclear program and curb its ballistic missile program. The European Union has also condemned the unacceptable repression and violence perpetrated by the Iranian regime against its own citizens.”
A New Doctrine?
In a 9 March 2026 speech at the EU Ambassadors Conference, Ursula von der Leyen noted, among other things, that:
Europe can no longer be a custodian for the old-world order, for a world that has gone and will not return. We will always defend and uphold the rules-based system that we helped to build with our allies, but we can no longer rely on it as the only way to defend our interests or assume its rules will shelter us from the complex threats that we face. So we need to build our own European path and find new ways of cooperating with partners.
The second is that we need a clear-eyed and hard look at our foreign policy in today’s world, both in how it is designed and how it is deployed. We urgently need to reflect on whether our doctrine, our institutions and our decision making – all designed in a postwar world of stability and multilateralism – have kept pace with the speed of change around us. Whether the system that we built – with all of its well-intentioned attempts at consensus and compromise – is more a help or a hindrance to our credibility as a geopolitical actor. I know this is a stark message and a difficult conversation to have.
A New EU Sanctions Program to Tackle Transnational Crime?
On March 9 2026, the European Parliamentary Research Service (EPRS) published a briefing titled “A new horizontal sanctions regime: Migrant smuggling, trafficking in human beings and other forms of organised crime.”
EU Courts Developments
Highlights of 2025 Annual Report
In March 2025, the Court of Justice of the European Union published its annual 2025 year in review report. The report highlighted a notable continuing increase of the Court’s docket regarding EU sanctions.
Whereas, as of 31 December 2024, 91 out of 1,705 pending cases related to restrictive measures, by 31 December 2025 that number had increased to 125 out of 1,167 pending cases, representing an increase of 34 cases (approximately 37%), alongside a significant rise in their proportion of total pending cases from about 5.3% to 10.7%.
The 2025 report highlighted two cases:
Judgment of 10 September 2025, Positive Group v Council (T-573/23) (interpreting the new criterion to freeze the funds and economic resources of entities operating in the Russian IT sector with a license issued by the Centre for Licensing, Certification and Protection of State Secrets of the Russian Federal Security Service (FSB) or a ‘weapons and military equipment’ licence administered by the Russian Ministry of Industry and Trade).
Judgment of 15 January 2025, MegaFon v Council (T-193/23 (finding that the Council had provided a sufficiently precise explanation of the reasons for those sanctions and had been under no obligation to hear the undertaking beforehand, in order to preserve the element of surprise needed for the sanctions to be effective. It also held that the measures remain proportionate to and necessary for the public interest objective of restricting Russian military capacity in the context of the war in Ukraine, even though those measures affect MegaFon’s activities and reputation.)
Select Judgements Rendered in March 2025
In March 2025, several key judgements and opinions were delivered, including:
On 30 March 2026, the Court rendered its judgement in joined cases Cases C-696/23 P Pumpyanskiy v Council, C-704/23 P Khudaverdyan v Council, C-711/23 P Rashnikov v Council, C-35/24 P Mazepin v Council and C-111/24 P Khan v Council, interpreting the notion of “leading businesspersons involved in economic sectors that generate significant revenue for the Russian government” and dismissing all actions.
On 12 March 2026, the Court of Justice rendered its judgment in Case C‑84/24 EM System v AB SEB Bank, a request for a preliminary ruling from the Lithuanian Supreme Court on the interpretation of the notions “ownership and control” and the relevant thresholds.
On 12 March 2026, the Court of Justice rendered its judgment in Case C‑465/24 SBK Art v Fortenova Group STAK, a request for a preliminary ruling from the Dutch Supreme Court on the meaning of “freezing of funds” in the context of voting rights.
On 26 March 2026, the Court of Justice dismissed an appeal against the General Court’s refusal to annul a 2022 listing under the DRC sanctions regime in case Case C-455/24 UC v. Council.
On 18 March 2026, the General Court rejected an application to annul the listings of Samer Al Dibs’ under the Syria sanctions regime in Case T-405/24 Al Dibs v Council.
On 26 March 2026, the General Court dismissed an application to annul the listing of Xavier Moreau under the Russia hybrid threats sanctions regime in Case T-170/26 Moreau v. Council.
On 19 March 2026, Advocate General Szpunar delivered his Opinion in Case C‑842/24, DNO Yemen AS v Petrolin Trading Ltd, a preliminary reference from the French Supreme Court (Cour de cassation).
On 12 March 2026, Advocate General Campos Sánchez-Bordona delivered his Opinion in Case C-482/24 P, Global 8 Airlines v European Commission.
Compliance Guidance
Throughout the month of March 2026, the European Commission (the “Commission”) and several national competent authorities continued to publish compliance guidance, including:
On 13 March 2026, the Commission published new FAQs concerning article 5(b)(2) of Council Regulation 833/2014 (Frequently asked questions on the provision of payments services concerning sanctions adopted following Russia’s military aggression against Ukraine).
On 16 March 2026, the French Direction générale du Trésor and the Autorité de contrôle prudentiel et de résolution (ACPR) published new guidelines on asset freeze obligations (Lignes directrices conjointes de la Direction Générale du Trésor et de l’Autorité de contrôle prudentiel et de résolution sur la mise en œuvre des mesures de gel des avoirs).
On March 23, 2026, the Italian @UAMA issued a notice to economic operators in applying for exemptions under Article 5n (10)(h) of Council Regulation 833/2014 (COMUNICATO TECNICO PER LA PRESENTAZIONE DI ISTANZE IN DEROGA EX ART. 5 QUINDECIES PAR. 10 LETT. H DEL REG. (UE) N. 833/2014).
EU Sanctions Directive
On 3 March 2026, a proposal for legislation transposing Directive (EU) 2024/1226 of 24 April 2024 on the definition of criminal offences and penalties for the violation of Union restrictive measures and amending Directive (EU) 2018/1673” was introduced in the French National Assembly, kicking off the legislative process.
The Podcast
Catch up with the latest three episodes of the podcast (available wherever you get your podcasts).
Tune in soon for the next episode. The podcast is available on all platforms.
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🎧YouTube: https://lnkd.in/eH6WRNBA
Looking Ahead
21 April 2026 - Foreign Affairs Council
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