Source: Legal 500 (Steptoe LLP), October 22nd, 20261
Day counts are worked out from today's date when the page opens.
The EU has listed more Russian companies in one round than ever before, and it has no central agency to chase the ones that evade. On October 12th, 2026 the Council froze the assets of 826 Russian companies and 743 of their chief executives, 1,569 listings in all2,3. Enforcement is pursued at the national level4.
The US office that did much of that work for Europe is pointing elsewhere. Between October 9th and October 16th the US authorized Russian diesel imports and waived the Graham Act's mandatory Russia sanctions5,1. Carnegie's authors say OFAC now does much less of what Europeans need4.
For compliance teams, the exposure is who polices a transaction. A listing binds every EU operator3, but enforcement is national and capacity differs4,6. The US has not left: OFAC still sanctioned Iran-linked vessels on October 8th1.
On October 12th, 2026 the Council adopted asset freezes on 826 Russian companies and 743 of their chief executives, 1,569 listings in all2,3. The Council says the set brings listings under the Ukraine regime to close to 4,6002,3.
The listed companies employ more than 250,000 people and turn over at least €20 billion a year, the Council says2,3. It names electronics, radars, aviation and missile systems, explosives and optics among the components they supply2. Kaja Kallas, the EU's High Representative for foreign affairs, said over half of the listings address the production chain for Russia's ballistic missiles2.
The Council picked the 826 companies from a list the Russian government itself set up to name military-industrial enterprises eligible for state subsidies3,7. A trade-law briefing on the package notes that this lets Russia's own industrial policy inform EU designations, including for manufacturers not widely seen as defense contractors3.
This is not the time to ease pressure on Moscow but to increase it.
Council of the EU2
The EU does not have a central agency to enforce its sanctions, and compliance is pursued at the national level, write Nicu Popescu and Tiago Antunes of the Carnegie Endowment4. National authorities often lack the human and technical means to enforce on a major scale4. A Bush Institute paper reaches the same point: the EU relies overwhelmingly on its member states' enforcement capacity, which makes the whole system only as strong as its weakest link8.
Directive (EU) 2024/1226 required member states to criminalize sanctions breaches consistently. More than a year after its transposition deadline, several are still adapting their laws, writes Gonzalo Saiz Erausquin of the Royal United Services Institute (RUSI)6. The EU also has a special envoy for the implementation of sanctions, appointed in December 2022, who presses third countries to stop listed tankers sailing under their flags9.
UK figures, for scale. The sources reviewed give no comparable EU national total
Source: Royal United Services Institute6
OFSI is the UK's Office of Financial Sanctions Implementation. HMRC is the UK tax and customs authority. The Sabre penalty was just over £1 million.
RUSI calls the £7.44 million settlement with Illumina Cambridge Limited, published in September, the largest sanctions-related settlement published to date6. It and the £569,157 Petrofac Facilities Management settlement both came from voluntary self-disclosures6. RUSI judges the UK's direction in 2026 encouraging, particularly when compared with the EU6.
The law firm Wikborg Rein reads the waiver, a week after GL 135, as indicating a further softening in the U.S. sanctions position vis-à-vis Russia5. A bipartisan group of six senators asked the President to cancel the diesel deal, arguing it would violate the Ending Importation of Russian Oil Act1.
Popescu and Antunes argue that OFAC, a team of up to 250 officials, now does much less of what Europeans need than it used to, and may act against European interests4. They point to US sanctions on a former European commissioner and on the ICC4. The UK, Canada, Denmark, Germany, France, Italy, Japan and the Netherlands said they regret and strongly disagree with the ICC sanctions1.
EUAnnounced the largest round of EU sanctions listings since 2022 and said it is not the time to ease pressure on Moscow2.
USSigned the October 16th order waiving the Graham Act's mandatory Russia sanctions5. Said after a discussion with Vladimir Putin that Russia agreed to supply diesel to US and global markets1.
USBy August 2026 Ukrainians had identified 5,816 foreign-made components in 202 Russian weapons systems that were shot down or landed unexploded4. The parts come from Germany, Japan, the Netherlands, South Korea, Switzerland, the UK and the US, and some were made in 2025 or 2026, according to Ukrainian officials4.
Eve of the invasion against the end of 2023, the latest date available
Source: George W. Bush Institute, December 9th, 20258
The count falls, but the Bush Institute paper says companies tied to Moscow now hide those links.
Two cases show how the goods move. The Bosnian subsidiary of the German firm Mann + Hummel supplied auto parts to Turkish intermediaries who re-exported them to Russia, and its factory exported products worth €753,331 to Russia in 20238. Between October 2022 and July 2023 the Serbian company Soha Info exported $18 million in goods to Russia, including $4.3 million in tightly controlled Intel components8.
On the enforcement side, the cases are small. On October 9th, 2026 OFAC announced a $175,015 settlement with the US forwarder Pegasus Worldwide Logistics under counter-narcotics sanctions. The firm screened only a sanctioned supplier's new name, not its unchanged address and phone number1. Renamed entities are a risk for any sanctions screening that checks names only.
OFAC is still active. On October 8th it sanctioned 17 vessels and 17 companies tied to Iran, and on October 5th it warned foreign banks dealing with Iran that they could be targeted without notice1. It also settled with Pegasus on October 9th1. The Graham Act waiver used a power the Act itself grants: Wikborg Rein noted earlier that the President may waive most of its provisions if it is in the national interest5.
Carnegie's own authors accept that member states are unlikely to cede executive powers to Brussels, so their fallback is a non-executive clearing house that helps national authorities decide where to strike4. They add that chasing evaders is worth doing even if it is whack-a-mole, because evaders must spend effort on avoidance4. And RUSI's UK record shows national agencies can improve, though both HMRC settlements rested on companies reporting themselves6.
The reply: none of this shows OFAC pursuing Russian military supply chains at the pace Europe needs. The October actions the sources record include Russia-related relief and Iran-related sanctions1,5. The gap in the EU is national capacity, and it stays whatever Washington does4,8.
Confidence on the mechanism is high: three sources describe national-level enforcement as the EU's weak point4,8,6. Confidence on the horizon is low: none of the sources reviewed shows a formal EU proposal for a central enforcement body.
The Bush Institute paper (December 9th, 2025) supports only the historical figures from 2022 and 2023. The Carnegie piece is opinion by two former officials and is cited as argument.
| Reader | What to do |
|---|---|
| PE and VC firms | Ask portfolio companies with electronics, aerospace or industrial-equipment supply chains to re-screen suppliers and distributors against the October 12th listings, including executives3. |
| Family offices | Check holdings with exposure to listed companies. An asset freeze can reach non-listed entities that a listed person owns or controls3. |
| Corporates | Review third-country distribution channels. Re-exports through intermediaries are the documented route8. GL 135 expires on April 7th, 20275. |
| Law firms | Advise on which member state's authority would act, since enforcement is national4. Check addresses and phone numbers as well as names, as the Pegasus case shows1. |