On October 12, 2026, the Council of the European Union adopted Council Decision (CFSP) 2026/2291, amending Council Decision 2014/145/CFSP, and listed 77 individuals involved in the so-called Russian State Duma elections held from September 18 to September 20, 2026 in Ukrainian territories that Russia occupies. The Council's press release of October 12, 2026 states that those listed are subject to a travel ban and an asset freeze, and that EU citizens and companies are forbidden from making funds, financial assets or economic resources available to them. The names and the amending decision are published in the Official Journal as Council Decision (CFSP) 2026/2291.
EU banks and credit institutions, EU payment institutions and e-money issuers, EU crypto-asset service providers, EU fund and asset managers, and EU companies and citizens holding assets of or transacting with listed persons must immediately screen customer bases, counterparty lists and transaction-monitoring watchlists against the 77 individuals newly listed under Council Decision (CFSP) 2026/2291, freeze any assets held for them without delay, and cease making any funds or economic resources available to them, or they commit a breach of EU restrictive measures exposing the operator to national administrative or criminal penalties, including fines and, in several Member States, liability for circumvention.
Who did the Council list on October 12, 2026?
The 77 listings split into two groups named in the press release. Seventy-four are candidates who stood for various parties in the so-called Donetsk People's Republic, the so-called Luhansk People's Republic, the Zaporizhzhia and Kherson regions, and the so-called Republic of Crimea and the City of Sevastopol. Three are members of the Central Election Commission of the Russian Federation, listed for organising those elections. The Council's ground is that, by standing or by organising the vote, they contributed to legitimising Russia's war of aggression and to sustaining the occupation. The High Representative's statement of September 21, 2026 recorded that the Union does not recognise those elections on Ukrainian territory or their results.
| Listed group | Count | Measures under Decision 2014/145/CFSP |
|---|---|---|
| Candidates in the occupied territories | 74 | Travel ban, asset freeze, prohibition on making funds or economic resources available |
| Members of the Russian Central Election Commission | 3 | Same three measures |
What must EU firms screen and freeze?
The asset freeze and the prohibition on making funds or economic resources available attach on publication. A bank, payment institution, e-money issuer, crypto-asset service provider or fund manager that holds an account, a wallet, a custody position or any other economic resource for one of the 77 must freeze it and must not release it, directly or indirectly, to the listed person or for that person's benefit.
Screening covers customers of record, counterparties, payment beneficiaries, beneficial owners and transaction-monitoring watchlists, checked against the 77 names in Council Decision (CFSP) 2026/2291. A namesake still has to be dispositioned from the identifying particulars in the Official Journal entry. EU companies and citizens outside the financial sector are under the same prohibition: paying a listed person, or providing goods or services that count as economic resources, is a making-available.
What is the penalty if a freeze is missed?
Council Decision 2014/145/CFSP, as amended, requires Member States to apply the restrictive measures. The press release does not set a single EU-wide fine figure for this batch. Enforcement sits in national law: failure to freeze a listed person's assets, or to refrain from making funds available, is a breach of EU restrictive measures and exposes the operator to national administrative or criminal penalties, including fines and, in several Member States, liability for circumvention.
The travel ban is a separate limb. It prohibits the 77 from entering or transiting through EU territory. It does not replace the financial measures, and a firm cannot treat a person who never travels as outside the asset freeze. Continuous, per-jurisdiction monitoring is how a screening team sees a Council listing of this kind at the moment the Official Journal publishes it.
How does this batch relate to the September 2026 listings?
This decision amends Decision 2014/145/CFSP. It is not the September 28, 2026 batch, in which the Council listed ten individuals for supporting repression of the democratic opposition in Russia, tied to the barring of Yabloko from the State Duma elections. Those ten stay listed. The 77, adopted on October 12, 2026, are an additional set of candidates and election organisers in the occupied Ukrainian territories. Nothing in the October 12, 2026 acts postpones or repeals them. Firms that screened only the ten still have to load the 77.
Next, load Council Decision (CFSP) 2026/2291 into the screening file, re-run customers, counterparties and beneficial owners against the 77 names, freeze any confirmed match and block further payments, and brief sanctions, payments and legal teams that the prohibition on making funds available applies to every EU person, not only supervised institutions. Obsidian tracks restrictive-measure amendments of this kind jurisdiction by jurisdiction so the next listing is in the same workflow.
