EU Sanctions Against Iran 2026: What Exporters and Banks Must Do

Key data

Companies with commercial, financial or contractual ties to Iran have an immediate obligation: to check whether their counterparties appear on the lists updated by Council Implementing Regulation (EU) 2026/775, published on 31 March 2026 and in force since the day before. Failing to do so is not an option: non-compliance can result in criminal penalties.

This regulation applies and updates Regulation (EU) No 267/2012, the European regulatory framework for restrictive measures against Iran, amending the lists of persons and entities subject to asset freezes and travel bans.

What does this regulation establish?

Regulation 2026/775 is an implementing regulation, which means it does not create a new regulatory framework but rather updates the lists of sanctioned subjects within Regulation 267/2012. Its specific effects are:

• Amendment of the annexes to Regulation 267/2012 with new Iranian natural and/or legal persons subject to restrictive measures.
• Asset freeze of the entities and persons included in the updated lists: no EU company may make funds or economic resources available to them.
• Travel ban for natural persons included in the lists: they may not enter or transit through EU territory.
• Obligation of enhanced due diligence for any operator that maintains or intends to initiate relations with Iranian counterparties.

The regulation is directly applicable in all Member States, including Spain, without the need for transposition. It entered into force on 30 March 2026, one day before its official publication in the Official Journal of the EU.

Economic and operational impact

The impact is not only legal: it is operational and financial. Companies that do not adapt their verification processes assume direct risks to their business activity:

• Blocking of ongoing operations: if an Iranian counterparty appears on the updated list, any transaction in progress must be stopped immediately, with the contractual termination costs that this entails.
• Asset freeze: funds or economic resources linked to listed entities are blocked, with a direct impact on cash flow and outstanding receivables.
• Administrative and criminal penalties: non-compliance is not a minor infringement. European sanctions regulations provide for serious consequences, including criminal liability for the responsible directors.
• Compliance costs: the export, banking, insurance and transport sectors must strengthen their counterparty screening systems, which requires investment in tools, processes and training.

Reputational risk is also relevant: operating with sanctioned entities, even unknowingly, can damage relationships with financial institutions and international partners.

Who is affected?

Regulation 2026/775 affects any operator established in the EU that maintains ties with Iran. The sectors with the greatest compliance risk exposure are:

• Exporting companies that sell goods or services to Iranian customers or distributors.
• Financial institutions (banks, savings banks, credit cooperatives) that manage transfers, financing or accounts linked to Iran.
• Insurers that cover operations, goods or persons with Iranian ties.
• Transport and logistics operators that manage routes, cargo or contracts originating from or destined for Iran.
• Companies with supply or service contracts with Iranian entities, even if the relationship is indirect.
• Legal advisors, consultants and auditors providing services to companies with exposure to Iran.

Practical example

A Spanish company in the industrial sector has a machinery supply contract with an Iranian company with which it has been operating for three years without incident. Regulation 2026/775 updates the lists of sanctioned entities.

If that Iranian company has been included on the new list, the Spanish company has the immediate obligation to suspend any shipment, payment collection or commercial communication with it. It cannot claim ignorance: the responsibility for verifying the lists lies with the operator.

If the Spanish company does not carry out the due diligence check and continues operating, it is exposed to:

• Blocking of funds pending collection.
• Opening of sanctioning proceedings by the competent authorities.
• Possible criminal liability for the directors who authorised the operation.

The solution is to implement a systematic verification process against EU sanctions lists before any transaction, and to repeat it periodically for ongoing commercial relationships.

What should companies do now?

1. Immediately verify current Iranian counterparties against the updated lists published in Regulation 2026/775 and the annexes to Regulation 267/2012.
2. Preventively suspend any pending transactions with Iranian counterparties until confirming they do not appear on the sanctions lists.
3. Implement or strengthen the due diligence process for all operations with Iranian parties, including prior verification and periodic reviews of ongoing relationships.
4. Train the teams responsible for foreign trade, finance and regulatory compliance on the obligations arising from Regulation 267/2012 and its updates.
5. Document all controls carried out: in the event of an inspection or investigation, the company must be able to demonstrate that it acted with due diligence.
6. Consult with specialised legal counsel if there is any doubt about the status of an Iranian counterparty or the scope of compliance obligations.

Official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, please consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=CELEX:32026R0775