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.Show full details
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:
Summary of Current EU Sanctions:
People and entities:
People and entities identified by the EU Council as:
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 […]
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 […]
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 […]
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 […]
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).