On September 28, 2026, the Council of the European Union adopted Regulation (EU) 2026/2184 and Decision (CFSP) 2026/2185, designating 10 individuals and 17 entities responsible for the unlawful deportation and forcible transfer of Ukrainian children to Russia and into temporarily occupied territories. Published in the Official Journal the same day, the package extends the asset-freeze and travel-ban regime of Regulation (EU) No 269/2014 to 27 new persons and entities, including the President of Tatarstan, the Moscow City Tourism Committee, children's camps and the Songdowon International Children's Camp in the Democratic People's Republic of Korea.
EU banks and payment institutions, travel and tourism operators with commercial links to the designated Russian recreation entities, and companies with supply-chain or financial exposure to the 27 designees must update their sanctions screening systems, freeze any assets, and cease making funds or economic resources available to them, as the asset freeze applies from September 28, 2026, or face national criminal penalties for asset-freeze breaches under Member State enforcement laws.
What the September 28, 2026 package changes
The Council's 28 September 2026 designations add 27 entries to the EU consolidated sanctions list under the Ukraine regime. The 10 individuals include the President of the Republic of Tatarstan, Rustam Minnikhanov, accused of facilitating deportations to camps in his region, ministers of education and sports in occupied territories, and heads of children's camps and schools. The 17 entities span Russian tourism and recreation companies, children's camps and sports centres in Russia and occupied Ukraine, and the DPRK-operated Songdowon camp, all tied to forced assimilation, indoctrination and military-patriotic education of deported children. Russia is estimated to have deported or forcibly transferred over 20,500 Ukrainian children since the start of the war.
| Instrument | Amends | Effect |
|---|---|---|
| Council Implementing Regulation (EU) 2026/2184 | Regulation (EU) No 269/2014 | Adds 27 persons and entities to the asset-freeze and travel-ban list |
| Council Decision (CFSP) 2026/2185 | Decision 2014/145/CFSP | CFSP counterpart listing the same 27 under the Ukraine restrictive measures |
All 27 are subject to an asset freeze, and EU citizens and companies are forbidden from making funds, financial assets or economic resources available to them. Natural persons among the designees are additionally barred from entering or transiting EU territory. The legal acts were published in the Official Journal of the European Union on September 28, 2026.
Who must screen against the new designations
The designations create immediate exposure for three categories of EU operator. Banks and payment institutions that screen against the EU consolidated list must add the 27 entries to their filtering systems and review open accounts, pending transfers and correspondent relationships. Travel and tourism operators face a more specific exposure: the package names the Moscow City Tourism Committee and Russian companies running children's recreation, tourism and entertainment services, so any EU operator with commercial relations to designated Russian tourism or recreation entities must sever them. Importers and companies with supply-chain or financial exposure to any of the 27 persons or entities must trace and freeze those links.
What to do, and by when
The asset freeze applies from September 28, 2026, the date of its publication in the Official Journal, so screening systems should reflect the 27 new designees without delay. Concrete steps:
- Update sanctions screening and transaction-monitoring filters against the 27 entries added by Regulation (EU) 2026/2184.
- Identify and freeze any funds, financial assets or economic resources held for the listed persons and entities.
- Block any payment, transfer or commercial flow that would make funds or economic resources available to them.
- Review open contracts, bookings and supplier relationships with the designated tourism, recreation and camp operators, and the listed officials.
- Report frozen assets to the national competent authority under the Member State's sanctions reporting rules.
- Apply the travel ban to the designated natural persons across border and visa checks.
What happens otherwise
Asset-freeze breaches are enforced nationally. Each Member State transposes EU sanctions into its own criminal or administrative law, so a failure to freeze assets or to withhold funds from a listed party exposes the operator to national criminal penalties, regulatory action by the competent financial or trade authority, and reputational damage. The Bulgarian, Croatian, German, Italian, French and Greek frameworks in this regime all carry penalty regimes for breaches. Continuous, per-jurisdiction monitoring surfaces new EU sanctions designations as they publish in the Official Journal, so screening teams can update their lists without waiting for the next review cycle.
Verify that your screening list matches the 27 entries of Regulation (EU) 2026/2184, confirm any frozen positions with your legal team, and brief the compliance, treasury and front-office functions that handle Russia, Belarus and occupied-territory exposure. Keep the evidence of checks on file for the national authority.
