EU Sanctions Against Iran 2026: What Exporters and Financial Entities Must Review

Key data

Any Spanish company with commercial, financial or logistics operations linked to Iran has an immediate obligation: to review its contracts, counterparties and compliance programs. Regulation (EU) 2026/1867, published on July 31, 2026 and effective from the previous day, amends Regulation 267/2012—the central framework of European sanctions against Iran—and repeals Regulation 961/2010, thus eliminating a regulation that had coexisted with the updated framework for years.

This is not a development without practical consequences. The consolidation and possible expansion of existing restrictive measures requires updating counterparty screening filters and internal compliance programs before conducting any operation with Iranian links.

What does this regulation establish?

Regulation 2026/1867 operates on three main axes of the sanctions regime against Iran:

The repeal of Regulation 961/2010 eliminates the previous regulation that coexisted with Regulation 267/2012, simplifying the applicable legal framework. From now on, Regulation 267/2012—in its version amended by 2026/1867—is the single reference for European companies.

Economic and operational impact

The impact is not only legal: it has direct consequences on the daily operations of affected companies.

• Compliance costs: Companies must update their counterparty screening systems to incorporate the lists of designated persons and entities under the new framework. This involves software update costs, training and review of existing contracts.
• Blocking of operations: Any transaction with a counterparty included in the sanctions lists is automatically blocked. Financial entities are obligated to reject or freeze such operations.
• Risk of administrative and criminal sanctions: Non-compliance with the sanctions regime can result in serious administrative and criminal sanctions in Member States, including Spain. The severity varies according to the national legislation applicable, but the reputational and economic risk is high.
• Review of existing contracts: Ongoing contracts with Iranian counterparties or with companies operating in Iran must be reviewed to verify that they do not incur any of the prohibitions of the new regulation.

Who does it affect?

• Exporting companies that market dual-use goods, technology, industrial equipment or energy sector products destined for Iran or with Iranian intermediaries.
• Financial entities (banks, insurance companies, asset managers) that carry out transfers, financing, export credit insurance or any financial service with Iranian counterparties.
• Transport and logistics operators that manage routes, freight or storage services linked to goods originating from or destined for Iran.
• Oil and energy sector companies with any type of commercial relationship with the Iranian energy sector.
• Legal advisors, consulting firms and customs agents that provide services to companies with exposure to Iran, as they may incur liability if they facilitate prohibited operations.
• Multinational business groups with subsidiaries in third countries that operate with Iran, given that European sanctions apply to persons and entities under EU jurisdiction regardless of where the operation is executed.

Practical example

A Spanish industrial machinery manufacturer has a contract signed in 2025 to supply equipment to a customer based in Dubai, which in turn re-exports them to Iran. Under Regulation 2026/1867, this operation may be subject to dual-use goods restrictions if the equipment is listed in the applicable export control lists.

Before executing the shipment, the company must: (1) verify whether the goods are classified as dual-use under European regulations; (2) check that neither the customer in Dubai nor the final recipient in Iran appear on the lists of designated persons and entities; and (3) ensure that the financial entity managing the payment does not block the transaction due to application of sanctions. If it omits any of these steps and the operation turns out to be sanctions evasion, the company is exposed to serious administrative and criminal sanctions in Spain.

What should companies do now?

1. Review the inventory of Iranian counterparties: Identify all customers, suppliers, intermediaries and business partners with links to Iran and verify them against updated sanctions lists.
2. Update screening filters: Ensure that compliance systems incorporate the lists of designated persons and entities under Regulation 267/2012 in its version amended by 2026/1867.
3. Review existing contracts: Analyze ongoing contracts to detect possible breaches arising from the regulatory update and, if appropriate, activate force majeure or termination clauses.
4. Update the compliance program: Incorporate the new regulatory framework into internal procedures, with special attention to dual-use goods, financial transactions and logistics operations.
5. Train involved teams: Ensure that export, finance, legal and operations departments understand the new obligations and the risks of non-compliance.
6. Consult with a specialized advisor: If in doubt about whether a specific operation is permitted, obtain legal advice before executing it. Non-compliance can result in serious administrative and criminal sanctions.

Official source

Consult complete regulation in official source

Notice: 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_202601867