Key data
| Regulation | Council Implementing Regulation (EU) 2026/1853, of 24 July 2026 |
|---|---|
| Publication | 27 July 2026 |
| Entry into force | 24 July 2026 |
| Affected parties | Companies and entities with commercial or financial relations with Iran or the Middle East region |
| Category | European Regulation |
| Base Regulation | Regulation (EU) 2023/1529 |
| Year | 2026 |
From 24 July 2026, European companies with activity linked to Iran or the Middle East and Red Sea region must operate with an expanded list of sanctioned entities. The Council Implementing Regulation (EU) 2026/1853 applies new restrictive measures under Regulation (EU) 2023/1529, which regulates sanctions resulting from Iranian military support to Russia's war of aggression against Ukraine and armed groups in the region.
This is not an abstract rule: non-compliance—even if unintentional—can result in administrative and criminal sanctions under the national legislation of each Member State. For a Spanish company, this could mean anything from fines to criminal liability of its directors.
What does this regulation establish?
Council Implementing Regulation (EU) 2026/1853 updates the list of persons and entities subject to restrictive measures under Regulation (EU) 2023/1529. The specific measures it imposes are three:
| Measure | What it consists of | Who it applies to |
|---|---|---|
| Asset freezing | All funds and economic resources of the designated parties are blocked | Persons and entities included in the updated list |
| Prohibition on making funds available | No European company or person can transfer, pay or provide economic resources to the designated parties | All companies and persons under EU jurisdiction |
| Travel restrictions | The designated parties cannot enter or transit through EU territory | Natural persons included in the list |
The reason for the designations is Iran's military support to Russia's war of aggression against Ukraine, as well as support to armed groups and entities in the Middle East and the Red Sea, and actions that undermine freedom of navigation in the region.
The regulation does not publish the specific names of the new designees in its summary: to consult them, it is necessary to access directly the official text in the EU Official Journal or the EU sanctions mapping tool.
Economic and operational impact
The impact is not only reputational: operating with a sanctioned entity—even unknowingly—can paralyze operations, block bank accounts and generate legal liabilities. The most direct operational effects are:
- Blocking of payments and collections: any transfer to or from a designated entity will be retained by financial institutions, which are obligated to report it to the authorities.
- Paralysis of exports: exporters of dual-use technology must verify that the final recipient is not on the list before each transaction.
- Review of existing contracts: ongoing contracts with counterparties in the region must be evaluated to detect if any party involved has been designated.
- Compliance cost: companies with activity in the region will need to strengthen their due diligence and third-party screening processes, which involves internal or external time and resources.
The risk is especially high for the financial sector (banks, insurers, asset managers) and for dual-use technology exporters, which are the sectors expressly identified by the regulation as having the highest exposure.
Who does it affect?
- Financial entities: banks, insurers, fund managers and any intermediary that processes payments or financing with counterparties in Iran or the region.
- Dual-use technology exporters: companies that sell or transfer technology, components or equipment that may have civilian and military use.
- Companies with commercial activity in the Middle East or the Red Sea: importers, exporters, shipping companies, freight forwarders and logistics operators with routes in the area.
- Companies with Iranian partners or suppliers: any company that has entities with headquarters or links in Iran in its supply chain.
- Advisors and consultancies: law firms, foreign trade consultancies and tax advisors that manage operations with the region.
Practical example
A Spanish industrial components company has a distributor in the United Arab Emirates with which it has been operating for three years without incident. Following the entry into force of Regulation 2026/1853, that distributor—or one of its business partners—appears on the updated list of entities designated by the EU.
If the Spanish company makes a pending payment to that distributor without having previously verified the list, it will be in breach of the prohibition on making funds available to designated entities. The Spanish bank that processes the transfer is obligated to block it and notify the competent authorities. The company may face an administrative sanctioning procedure and, depending on Spanish criminal law, its directors could incur personal liability.
The solution is simple but requires process: verify the list of designees before each transaction with counterparties in the region, not just once a year.
What should companies do now?
- Consult the updated list of designees: access the full text of Regulation 2026/1853 in the EU Official Journal and cross-reference it with the internal database of partners, suppliers and clients.
- Review ongoing contracts and transactions: identify any active contractual relationship with counterparties in Iran, the Middle East or the Red Sea and assess whether any party involved has been designated.
- Implement a periodic screening process: a one-time verification is not enough; screening must be integrated into the due diligence processes for new partners and periodic review of existing ones.
- Alert the finance department: instruct the payments and treasury team to block any transfer to counterparties in the region until it is confirmed that they are not designated.
- Consult with specialized legal advice: if there are doubts about the company's exposure, seek advice from an expert in foreign trade and international sanctions before continuing to operate.
- Document all verifications: in case of inspection, the company must be able to prove that it carried out the necessary checks. Documentation is the best defense against a sanctioning procedure.
Frequently asked questions
What specific sanctions does Regulation (EU) 2026/1853 impose?
The regulation establishes three types of measures: asset freezing of the designated parties, prohibition on making funds or economic resources available to them, and travel restrictions to the EU for natural persons included in the list. Sanctions for non-compliance—administrative or criminal—are determined by the national legislation of each Member State.
Where can I consult the updated list of designated persons and entities?
The complete list appears in the official text of Council Implementing Regulation (EU) 2026/1853, published in the EU Official Journal on 27 July 2026. It can also be consulted through the EU's interactive sanctions tool at sanctionsmap.eu, which allows searches by name and updates listings in real time.
What happens if my company operates with a designated entity without knowing it?
Lack of knowledge does not exempt from liability. If a company carries out a transaction with a designated entity, it may face administrative sanctions and, under Spanish criminal law, personal liability of its directors. This is why it is essential to implement a verification process prior to each transaction with counterparties in the region.
When did this regulation come into force?
Council Implementing Regulation (EU) 2026/1853 came into force on 24 July 2026, three days before its publication in the EU Official Journal (27 July 2026). Companies must apply it from that date.
Which sectors have the highest risk of non-compliance?
The regulation expressly identifies three sectors with the highest exposure: financial sector entities (banks, insurers, asset managers), dual-use technology exporters, and companies with commercial activity in the Middle East and the Red Sea. These sectors must urgently strengthen their due diligence and third-party screening processes.
Official source
Consult complete regulation in official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601853