This update concerns EU counter-terrorism sanctions and restrictive measures against a designated entity, which falls outside the payments-specific taxonomy and relates to geopolitical sanctions rather than payment system regulation.
While AML frameworks may reference sanctions lists, this update is fundamentally a sanctions designation rather than AML regulation of payment institutions or services.
Specialism
The update explicitly designates the IRGC as a terrorist entity subject to restrictive measures under EU counter-terrorism regulations, triggering asset freezes and transaction restrictions that payment firms must implement.
The amendment is terrorism-focused restrictive measures that require payment firms to screen transactions and freeze assets of the designated entity, which is core counter-terrorism financing compliance.
2026-02-19 16:57:31·adavies@vixio.com
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TITLE: European Union Amends Terrorist Restrictive Measures List to Include Islamic Revolutionary Guard Corps
BODY:
On 19 February 2026, the Council of the European Union adopted Implementing Regulation (EU) 2026/420, which amends the list of persons, groups, and entities subject to specific restrictive measures under Regulation (EC) No 2580/2001 on combating terrorism.
The regulation adds the Islamic Revolutionary Guard Corps (IRGC) to the annex of Council Implementing Regulation (EU) 2025/1578 (adopted 29 July 2025), which establishes the updated list of designated terrorist entities. The amendment follows a determination by competent authorities that the IRGC has adopted decisions involving terrorist acts as defined under Article 1(3) of Council Common Position 2001/931/CFSP. The addition of the IRGC to the restrictive measures list means that Articles 2 and 3 of the Common Position—which establish specific sanctions and restrictions—now apply to the entity across all European Union Member States.
The regulation entered into force on the day following its publication in the Official Journal of the European Union on 19 February 2026. As an implementing regulation, it is binding in its entirety and directly applicable in all Member States without requiring further national legislation. This amendment ensures that all Member States apply consistent restrictive measures against the designated entity in accordance with European Union counter-terrorism policy.
**Reference:**
Council Implementing Regulation (EU) 2026/420 of 19 February 2026, Official Journal of the European Union, L 2026/420, 19.2.2026