EU Sanctions on Iranian Judges 2026: What European Companies Must Verify

Key data

Six Iranian judges from revolutionary courts have their assets frozen in the European Union and cannot enter any Member State as of 24 July 2026. Implementing Decision (CFSP) 2026/1850 expands the list of sanctioned individuals under Decision 2011/235/CFSP, the European framework of restrictive measures against those responsible for human rights violations in Iran.

The measure responds directly to the conclusions of the European Council of June 2026, which demanded that the Iranian regime cease repression. Among those designated is the judge who sentenced Nobel Peace Prize winner Narges Mohammadi. The sanctioned individuals have imposed death sentences, imprisonment and flogging against dissidents, activists, religious minorities and protesters of the "Woman, Life, Freedom" movement.

What does this regulation establish?

Decision 2026/1850 is an implementing decision that expands the annex of designated persons under the Decision 2011/235/CFSP, the European sanctions regime specifically targeting Iran for human rights violations. It does not replace the previous framework: it expands it by adding six new names.

The six new designees are judges from Iranian revolutionary courts. The designation criterion is having imposed sentences —death penalties, imprisonment and flogging— against:

• Political dissidents
• Human rights activists
• Religious minorities
• Protesters of the "Woman, Life, Freedom" movement

The legal consequences of designation are two and apply simultaneously:

• Asset freezing: all funds and economic resources of the designees located in EU territory are blocked. No company or entity can make funds available to them.
• Entry ban: designees cannot enter or transit through any EU Member State.

The detailed summary does not include the individual names of the six designated judges. To consult the complete nominal list with identification data for each person, it is necessary to access the full text of the decision in the EU Official Journal (CELEX:32026D1850).

Economic and operational impact

For most Spanish and European companies, the direct impact of this decision is low: the six designees are Iranian judges with no known commercial activity in Europe. However, the risk of non-compliance exists and can be costly for the following profiles:

• Financial entities with correspondent banking or accounts linked to Iranian individuals: must execute screening of the new list against their customer base and counterparties.
• Companies with operations in Iran or with Iranian business partners: any financial relationship —direct or indirect— with a designee constitutes a breach of the sanctions regime.
• Asset managers and family offices administering assets of Iranian nationals: the freeze applies to assets located in the EU, regardless of who manages them.

Non-compliance with the EU sanctions regime does not have a fixed amount established in this decision: sanctions for breach are determined by the national legislation of each Member State. In Spain, the applicable sanctions regime is the Law 10/2021, of 9 July, on combating tax fraud and capital control regulations, with fines that can reach the total value of the funds involved.

Who does it affect?

• Banks and credit institutions with Iranian customers or counterparties
• Payment service companies and fintech operating with users of Iranian origin
• Fund and asset managers administering assets of Iranian nationals in the EU
• Export or import companies with commercial activity in Iran
• Law firms and advisors providing services to Iranian clients
• Insurance companies with policies linked to Iranian individuals or entities

Practical example

A Spanish bank with correspondent banking in Iran receives, on 25 July 2026, an international transfer from an account linked to one of the six designated judges. Since Implementing Decision 2026/1850 entered into force the previous day, the bank is obliged to block the funds immediately and notify the competent authorities. If the screening system has not incorporated the new list before processing the transaction, the bank may incur liability for breach of the sanctions regime, regardless of whether the error was unintentional.

This scenario illustrates why updating sanctions lists must be executed on the same day of their publication, without waiting for periodic update cycles.

What should companies do now?

1. Access the updated official list: download the full text of Decision 2026/1850 on EUR-Lex to obtain the names, dates of birth and identification data of the six new designees.
2. Update screening systems: incorporate the six new names into compliance tools (AML/KYC) before processing any transactions with Iranian counterparties.
3. Review the customer base and counterparties: cross-reference the new list against active customers, beneficial owners and counterparties in pending transactions.
4. Block and notify if there is a match: if any link with a designee is detected, freeze the assets immediately and notify the competent authority according to applicable national regulations.
5. Document the process: keep written record of the date and result of the review, as evidence of due diligence in the event of an inspection.

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=CELEX:32026D1850