Sanctions Profile: Iran

At a glance

UN sanctions on Iran were first imposed in 2006, by UN Security Council Resolution 1737, in response to “the proliferation risks presented by the Iranian nuclear programme” and “by Iran’s continuing failure to meet the requirements of the International Atomic Energy Agency Board of Governors”. The sanctions comprised a ban on exports to Iran of nuclear-related materials and technology, as well as a targeted asset freeze and travel monitoring for those linked to the regime’s nuclear programme.

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The EU implemented those UN sanctions in 2007, by Council Common Position 2007/140/CFSP.

At their height, UN and EU sanctions imposed restrictions on numerous areas of Iran’s economy, including its military, energy, financial, shipping, and transport sectors. Many of those restrictions have since been lifted or eased under the Joint Plan of Action (JPOA) and the Joint Comprehensive Plan of Action (JCPOA).

From November 2013, Iran was given some sanctions relief under the JPOA, agreed between Iran and the E3/EU+3, which: eased or suspended US and EU sanctions on Iran’s petrochemical exports, gold, and precious metals; eased US sanctions on Iran’s auto-industry; licenced the supply and installation of certain parts and services to Iran’s aviation industry; prohibited further UN, EU, or US nuclear-related sanctions; established a financial channel to facilitate humanitarian trade with Iran; and increased the monetary threshold for transactions involving Iran before they have to be authorised.

Negotiations taking place under the sanctions relief granted by the JPOA led to the JCPOA, concluded on 14 July 2015 between Iran and the E3/EU+3. The JCPOA detailed that once Iran had complied with certain commitments in relation to its nuclear programme (which it did on ‘Implementation Day’, 16 January 2016), the bulk of the EU’s anti-nuclear proliferation sanctions on Iran would be lifted, including those suspended under the JPOA (see blog here). On 20 July 2015, the UN Security Council unanimously adopted UNSC Resolution 2231, endorsing the JCPOA and committing to terminate all of its sanctions imposed on Iran between 2006 and 2015 and, following 10 years of compliance by Iran, to remove the Iranian nuclear issue from its agenda.

Current post-JCPOA UN sanctions on Iran include a nuclear and ballistic missile programmes-related embargo, an arms embargo, and targeted asset freezes and travel bans.

Current post-JCPOA EU sanctions on Iran are imposed by two separate regimes. The first continues to target nuclear proliferation even after JCPOA Implementation Day (see Regulation & Decision), and the second targets serious human rights violations (see Regulation & Decision). The nuclear proliferation sanctions implement UN measures, as well as some autonomous EU measures, whilst the human rights sanctions are entirely EU autonomous measures. Both regimes impose targeted asset freezes and travel bans, and the nuclear proliferation sanctions also impose an arms embargo and nuclear-related goods and technology embargo.

In 2018, United States President Donald Trump unilaterally withdrew US participation in the JCPOA and re-imposed all nuclear-related sanctions lifted or waived in connection with the accord. In response, the EU updated its Blocking Statute (Commission Delegated Regulation (EU) 2018/1100, amending Council Regulation (EC) No 2271/96) to protect European companies from the extraterritorial effects of re-imposed US sanctions (see blog here).

Summary of Current UN Sanctions:

General

  • Arms embargo
  • Ballistic missile embargo
  • Embargo on nuclear-related goods and technology

Targeted

  • Asset freeze
  • Travel ban

Summary of Current EU Sanctions:

General

  • Arms embargo
  • Ballistic missile embargo
  • Embargo on nuclear-related goods and technology

Targeted

  • Asset freeze
  • Travel ban

Designation Criteria

Nuclear-proliferation

People and entities:

  1. designated by the UN Security Council or related Sanctions Committee;
  2. who are engaged in, directly associated with, or providing support for Iran’s proliferation-sensitive nuclear activities or the development of nuclear weapon delivery systems by Iran;
  3. that provide support to the Government of Iran and people associated with them or entities owned or controlled by them;
  4. that have evaded or violated, or assisted a listed person, entity or body to evade or violate EU and/or UN sanctions measures;
  5. that are linked to the Islamic Revolutionary Guard Corps (IRGC); or
  6. that are linked to the Islamic Republic of Iran Shipping Lines (IRISL).

Human rights

People and entities identified by the EU Council as:

  1. being responsible for serious human rights violations in Iran; or
  2. being associated with those persons.

 

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News

OFAC designates Iranian persons involved in intelligence and cyber attacks

Yesterday (13 February), OFAC designated 10 Iranian nationals and 2 Iran-based entities. See OFAC Notice and US Treasury Press Release. New Horizon Organization was designated, pursuant to terrorism-related Executive Order (EO) 13224 (asset freeze), for assisting / sponsoring / supporting the Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), namely, by organising international conferences that support the […]

IranIran TerrorismTerrorism

OFAC settles with Kollmorgen & designates its Turkish MD for directing the violation

Last week (7 February), OFAC reached a $13,381 settlement with Kollmorgen Corporation to settle potential civil liability on behalf of its Turkish affiliate, Elsim Elektroteknik Sistemler Sanayi ve Ticaret Anonim Sirketi, for 6 apparent violations of the Iranian Transactions and Sanctions Regulations. On 6 occasions between July 2013 and July 2015, Elsim is said to […]

IranIran

EU conclusions on Iran

Yesterday (4 February), the EU Council said in conclusions on Iran press release that the EU is committed to the JCPOA, welcomes Iran’s implementation of its nuclear commitments, regrets the US’s withdrawal from the deal and draws attention to the new EU SPV (see previous blog). However, the EU also expressed concern at Iran’s role […]

IranIran

ECJ dismisses IRISL Iran sanctions appeal

The ECJ has dismissed the appeal – C-225/17 P (31 January 2019) – brought by the Islamic Republic of Iran Shipping Lines and others, against the General Court’s judgment upholding the EU re-listings of IRISL and others after they successfully challenged their initial sanctions listings in September 2013 (see previous blog). The ECJ declined to follow […]

IranIran

UK updates regs criminalising breach of EU Blocking Statute

On 1 February 2019, the Extraterritorial US Legislation (Sanctions against Cuba, Iran and Libya) (Protection of Trading Interests) (Amendment) Order 2018 (SI 2018/1357) came into force. This UK Order ensures that UK criminal offences extend to conduct by UK nationals and entities within the scope of the amended Blocking Statute (on which see previous blog).

IranIran United StatesUnited States

Current Sanctions

EU UK

Consolidated - Blocking Statute

Council Regulation (EC) No 2271/96

Parent - Blocking Statute

Council Regulation (EC) No 2271/96

Amended by:

Parliament and Council Regulation (EU) No 37/2014

Commission Delegated Regulation (EU) 2018/1100

Consolidated - Nuclear Proliferation / WMD

Council Regulation (EU) No 267/2012

Parent Regulation - Nuclear Proliferation / WMD

Council Regulation (EU) No 267/2012

Amended by:

Council Implementing Regulation (EU) No 350/2012

Council Regulation (EU) No 708/2012

Council Implementing Regulation (EU) No 709/2012

Council Implementing Regulation (EU) No 945/2012

Council Implementing Regulation (EU) No 1016/2012

Council Regulation (EU) No 1067/2012

Council Regulation (EU) No 1263/2012

Council Implementing Regulation (EU) No 1264/2012

Council Implementing Regulation (EU) No 522/2013

Council Regulation (EU) No 517/2013

Council Regulation (EU) No 971/2013

Council Regulation (EU) No 1154/2013

Council Regulation (EU) No 1203/2013

Council Regulation (EU) No 1361/2013

Council Regulation (EU) No 42/2014

Council Implementing Regulation (EU) No 397/2014

Council Implementing Regulation (EU) No 1202/2014

Council Regulation (EU) 2015/229

Council Implementing Regulation (EU) 2015/230

Council Implementing Regulation (EU) 2015/549

Council Implementing Regulation (EU) No 2015/1001

Council Regulation (EU) No 2015/1327

Council Regulation (EU) No 2015/1328

Council Regulation (EU) 2015/1861

Council Implementing Regulation (EU) 2015/1862

Council Implementing Regulation (EU) 2015/2204

Council Regulation (EU) 2016/31

Council Implementing Regulation (EU) 2016/74

Council Implementing Regulation (EU) 2016/603

Commission Implementing Regulation (EU) 2016/1375

Council Implementing Regulation (EU) 2017/77

Council Regulation (EU) 2017/964

Council Implementing Regulation (EU) 2017/1124

Council Implementing Regulation (EU) 2018/827

Consolidated - Nuclear Proliferation / WMD

Council Decision 2010/413/CFSP

Parent Decison - Nuclear Proliferation / WMD

Council Decision 2010/413/CFSP

Amended by:

Council Decision 2010/644/CFSP

Council Decision 2011/299/CFSP

Council Decision 2011/783/CFSP

Council Decision 2012/35/CFSP

Council Decision 2012/152/CFSP

Council Decision 2012/169/CFSP

Council Decision 2012/205/CFSP

Council Decision 2012/457/CFSP

Council Decision 2012/635/CFSP

Council Decision 2012/687/CFSP

Council Decision 2012/829/CFSP

Council Decision 2013/270/CFSP

Council Decision 2013/497/CFSP

Council Decision 2013/661/CFSP

Council Decision 2013/685/CFSP

Council Decision 2014/21/CFSP

Council Decision 2014/222/CFSP

Council Decision 2014/480/CFSP

Council Decision 2014/776/CSFP

Council Decision 2014/829/CSFP

Council Decision (CFSP) 2015/236

Council Decision (CFSP) 2015/556

Council Decision (CFSP) 2015/1008

Council Decision (CFSP) 2015/1050

Council Decision (CFSP) 2015/1099

Council Decision (CFSP) 2015/1130

Council Decision (CFSP) 2015/1148

Council Decision (CFSP) 2015/1336

Council Decision (CFSP) 2015/1337

Council Decision (CFSP) 2015/1863

Council Decision (CFSP) 2015/2216

Council Decision (CFSP) 2016/35

Council Decision (CFSP) 2016/36

Council Implementing Decision (CFSP) 2016/78

Council Decision (CFSP) 2016/609

Council Decision (CFSP) 2017/83

Council Decision (CFSP) 2017/974

Council Implementing Decision (CFSP) 2017/1127

Council Decision (CFSP) 2018/833

Consolidated - Human Rights

Council Regulation (EU) No 359/2011

Parent Regulation - Human Rights

Council Regulation (EU) No 359/2011

Amended by:

Council Implementing Regulation (EU) No 1002/2011

Council Regulation (EU) No 264/2012

Council Regulation (EU) No 1245/2012

Council Regulation (EU) No 206/2013

Council Regulation (EU) No 517/2013

Council Implementing Regulation (EU) No 371/2014

Council Implementing Regulation (EU) 2015/548

Council Implementing Regulation (EU) 2016/556

Council Implementing Regulation (EU) 2017/685

Council Implementing Regulation (EU) 2018/565

Consolidated - Human Rights

Council Decision 2011/235/CFSP

Parent Decision - Human Rights

Council Decision 2011/235/CFSP

Amended by:

Council Implementing Decision 2011/670

Council Decision 2012/168/CFSP

Council Decision 2012/810/CFSP

Council Decision 2013/124/CFSP

Council Decision 2014/205/CSFP

Council Decision 2015/555/CSFP

Council Decision (CFSP) 2016/565

Council Decision (CFSP) 2017/689

Council Decision (CFSP) 2018/568

Sanctions and Anti-Money Laundering Act 2018

Sanctions and Anti-Money Laundering Act 2018 (Commencement No 1) Regulations 2018

Sanctions Review Procedure (EU Exit) Regulations 2018

Iran (Sanctions) (Human Rights) (EU Exit) Regulations 2019

Extraterritorial US Legislation (Sanctions against Cuba, Iran and Libya) (Protection of Trading Interests) (Amendment) Order 2018