Key data
| Regulation | Commission Implementing Regulation (EU) 2026/1851 of the Council, of 24 July 2026 |
|---|---|
| Legal basis | Regulation (EU) No 359/2011 concerning restrictive measures against Iran |
| Publication | 24 July 2026 (EU Official Journal) |
| Entry into force | 24 July 2026 |
| Direct affected parties | Six Iranian judges added to the EU blacklist |
| Indirect affected parties | European companies and financial entities with commercial or financial links to Iran |
| Category | European Regulation — Sanctions and restrictive measures |
| Year | 2026 |
Any European company or bank with activity linked to Iran has an immediate obligation: to verify that none of the six judges newly added to the EU blacklist appear in their commercial or financial relations. The Commission Implementing Regulation (EU) 2026/1851, published and effective on 24 July 2026, expands the sanctions of Regulation (EU) No 359/2011 and does not allow for an adaptation period: compliance is required from day one.
The expansion responds to the systematic repression by the Iranian regime against dissidents, activists and religious minorities. The six judges added preside over revolutionary courts where serious violations of due process have been documented. Among the most notable cases is that of the judge who sentenced Narges Mohammadi, Nobel Peace Prize laureate.
What does this regulation establish?
Commission Implementing Regulation (EU) 2026/1851 amends the annexes to Regulation (EU) No 359/2011, which is the EU's sanctioning framework against persons responsible for serious human rights violations in Iran. The update consists of adding six judges to the list of natural persons subject to restrictive measures.
The two restrictive measures applied to the sanctioned individuals are:
- Asset freezing: all funds and economic resources of the sanctioned individuals located in EU territory are blocked. No European entity may make funds available to them.
- Prohibition of entry: the six judges are barred from accessing the territory of the European Union.
The common profile of the six sanctioned judges is as follows: all preside or have presided over Iranian revolutionary courts in which political dissidents, activists and members of religious minorities have been tried with serious violations of the right to a fair trial. One of them is the judge responsible for the conviction of Narges Mohammadi, awarded the Nobel Peace Prize.
| Profile of sanctioned individuals | Area of activity | Measures applied |
|---|---|---|
| Six judges of Iranian revolutionary courts | Trials of dissidents, activists and religious minorities | Asset freezing in the EU + prohibition of entry to European territory |
The regulation does not establish a transitional period: compliance obligations are enforceable from 24 July 2026, the date of publication in the EU Official Journal.
Economic and operational impact
For most Spanish and European companies, the direct impact of this list expansion is low if they do not have active links with Iran. However, for those with activity in the country—whether commercial, financial or of any other type—the risk of non-compliance is real and the consequences can be significant.
The main operational risk vectors are:
- Banking and financial relations: any European financial entity that processes payments, maintains accounts or manages assets linked to the six sanctioned judges violates the regulation.
- Commercial contracts: companies with supply contracts, consulting or any other nature in which the sanctioned individuals appear as parties or representatives must suspend the relationship.
- Due diligence in operations with Iran: any new operation with an Iranian counterparty requires verification against the updated list before proceeding.
The main operational cost is that of screening and counterparty verification processes, which must be updated to incorporate the six new names. Financial entities with automated compliance systems must update their databases of sanctioned persons immediately.
Who does it affect?
- European financial entities (banks, insurance companies, fund managers) with any exposure to Iran or to persons of Iranian nationality.
- Export and import companies with commercial activity in Iran or with Iranian counterparties.
- Law firms and consulting firms that provide services to Iranian clients or with interests in Iran.
- Compliance and legal departments of any company with presence or links in Iran, obliged to update their screening lists.
- Directly sanctioned: the six Iranian judges added to the list, who see their assets frozen in the EU and their entry to European territory barred.
Practical example
A Spanish bank with an active export trade financing line with an Iranian company receives a payment request on 25 July 2026. Before processing the operation, its compliance team executes the usual screening of counterparties against the EU sanctions lists. When cross-checking the data, it detects that one of the administrators of the beneficiary Iranian company matches one of the six judges added to Regulation 2026/1851 the previous day.
At that moment, the bank is obliged to block the operation and freeze any funds associated with that person. Processing the payment would constitute a direct violation of Regulation (EU) No 359/2011 in its updated version, with the resulting legal liabilities and administrative sanctions. This scenario illustrates why immediate updating of screening databases is critical: the regulation allows no margin of time.
What should companies do now?
- Update screening lists immediately: incorporate the six new names into counterparty verification systems. The regulation is enforceable from 24 July 2026, with no grace period.
- Review active commercial and financial relations with Iran: identify whether any counterparty, partner, representative or beneficial owner matches the sanctioned individuals. Document the verification process.
- Suspend any pending operations with the sanctioned individuals: if a match is detected, block funds and operations immediately and notify the competent authorities according to the applicable national procedure.
- Review existing contracts: analyze whether any active contract with an Iranian counterparty may be affected by the new designation and assess the need for regulatory compliance clauses.
- Train the compliance team: ensure that those responsible for due diligence are aware of the update and the context of Regulation 359/2011 and its successive expansions.
- Consult specialized legal advice if there is significant exposure to Iran, to assess the specific risk and reporting obligations to national authorities.
Frequently asked questions
How many Iranian judges have been sanctioned by the EU under Regulation 2026/1851?
Commission Implementing Regulation (EU) 2026/1851 adds six Iranian judges to the blacklist of Regulation (EU) No 359/2011. All of them preside or have presided over Iranian revolutionary courts where dissidents, activists and religious minorities have been tried with serious violations of due process.
Since when are the sanctions on the Iranian judges added in July 2026 enforceable?
The restrictive measures are enforceable from 24 July 2026, the date of publication of the regulation in the EU Official Journal and its entry into force. There is no adaptation period: compliance is mandatory from day one.
What specific measures do the EU sanctions on these Iranian judges entail?
The two restrictive measures applied are: freezing of all assets of the sanctioned individuals located in EU territory, and prohibition of entry to European territory. No European company or financial entity may make funds available to the sanctioned individuals or facilitate their access to economic resources.
What should European banks and companies do to comply with Regulation 2026/1851?
They must immediately update their counterparty screening systems with the six new names, review all active commercial and financial relations with Iran, and suspend any operation in which any of the sanctioned individuals appear. Documentation of the verification process is essential to demonstrate compliance to the authorities.
What is the relationship between this regulation and the Narges Mohammadi case?
Among the six sanctioned judges is the one responsible for the conviction of Narges Mohammadi, an Iranian activist awarded the Nobel Peace Prize. Her case is one of the most notable examples of violations of due process documented in Iranian revolutionary courts that justify the expansion of the EU blacklist.
Official source
Consult full regulation at 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=CELEX:32026R1851