Iran is currently subject to financial sanctions. This document contains the current list of designated persons relating to proliferation sensitive nuclear activities.
In 2006, the UN Security Council imposed, amongst other matters, asset freeze restrictions on persons determined by the UN as engaging in, directly associating with, or providing support for, Iran’s proliferation-sensitive nuclear activities or the development of nuclear weapon delivery systems.
Between 2007 and 2012, the European Commission implemented further measures. In summary, the measures now in place involve the freezing of funds and economic resources of designated persons; restrictions on transfers of funds to and from an Iranian person, entity or body; vigilance over activities with Iranian banks; dealing with the Iranian banking sector; restrictions on Iran’s access to the EU’s insurance and reinsurance markets, restrictions on the provision of insurance and restrictions on financing certain Iranian enterprises and prohibitions on EU credit and financial institutions transferring funds to or from Iranian banks.
18 October 2015 – Adoption Day under the Joint Comprehensive Plan of Action (JCPoA) – publication of the amended EU regulations
On 18 October 2015, the Council has adopted the legal acts (EU Regulation 2015/1861 & Council Implementing Regulation (EU) 2015/1862) providing for the lifting of all nuclear-related economic and financial EU sanctions as specified in the JCPoA. These legal acts will take effect only on ‘Implementation Day’, simultaneously with International Atomic Energy Agency (IAEA) verification that Iran has complied with the terms of the nuclear agreement.
The JCPoA comes into effect as of 18 October 2015. It is the day referred to as ‘Adoption Day’, that is 90 days after the United Nations Security Council adopted a resolution endorsing the JCPoA (20 July 2015). As foreseen, the EU adopted the legal acts to prepare for the lifting of all nuclear-related economic and financial EU sanctions on Implementation Day.
These regulations will amend the existing nuclear-related regulations under EU Regulation 267/2012 with effect from Implementation Day. It is important to note that the provisions of EU Regulations 2015/1861 and 2015/1862 will not come into effect until Implementation Day.
Implementation Day is the future date on which the IAEA reports on the agreed measures taken by Iran under the JCPoA and the EU simultaneously terminates (in some cases only suspend) nuclear related financial and economic sanctions.
In practice this means that until Implementation Day sanctions against Iran in EU Regulation 267/2012 (as amended), including the current thresholds for prior authorisation or prior notification of Iran transfers are unchanged. This guidance remains in force.
14 July 2015 – limited sanctions relief remains in place until 14 January 2016
On 14 July 2015, the E3+3 (UK, France, Germany, Russia, China and US) the EU and Iran reached a comprehensive agreement on Iran’s nuclear programme. The successful implementation of the Joint Comprehensive Plan of Action (JCPoA) will ensure the exclusively peaceful nature of the Iranian nuclear programme and provide for the lifting of all nuclear-related sanctions.
On 14 July 2015, the E3+3, supported by the EU, agreed with Iran to extend the implementation of the measures of the Joint Plan of Action to allow for the necessary arrangements and preparations for the implementation of the JCPoA. The suspension of the restrictive measures specified in the Joint Plan of Action is therefore extended until 14 January 2016 under EU Council Decision 2015/1148. Relevant contracts would have to be executed within that date.
In practice this means sanctions against Iran in EU Regulation 267/2012 (as amended), including the current thresholds for prior notification or prior notification of Iran transfers are unchanged. This guidance remains in force.
Current financial sanctions remain in force. Read more about future sanctions policy.
Iran (nuclear proliferation) – Supreme Court judgement in Bank Mellat v. Her Majesty’s Treasury (No. 2)
Judgement was handed down on 19 June 2013 in relation to Bank Mellat’s challenge to the Financial Restrictions (Iran) Order 2009 (SI 2009/2725). The Supreme Court found in favour of Bank Mellat. The Financial Restrictions (Iran) Order 2009 ceased to have effect in October 2010.
The Judgement does not affect the current EU asset freeze which remains in place against Bank Mellat. Banks and other financial institutions must continue to abide by the EU measure, and must apply all the financial restrictions that are imposed under EU Regulation 267/2012 as amended by EU Regulation 1263/2012.
Current EU regulations
26.06.2015 Council Regulation (EU) No 2015/1001, Amending Regulation 267/2012
14.02.2015 Council Regulation (EU) No 2015/230 Relisting one individual and one entity.
20.01.2014 Council Regulation 42/2014 This Regulation implements the Joint Plan of Action, including the raising of the thresholds for notifications and prior authorisations.
22.12.2012 Council Regulation 1263 New EU Prohibition on transfers of funds between EU credit and financial institutions and Iranian banks, and asset freezing measures regarding the Central Bank of Iran.
16.11.2012 Council Regulation 1067/2012 Regulation 1067/2012 inserts a new Article into Regulation 267/2012 concerning an exemption to the prohibitions applying to acts and transactions carried out with regard to entities listed in Annex IX of that Regulation.
03.08.2012 Council Regulation 708/2012 Amends the reference to IRISL in Article 23.2(e) of Regulation (EU) 267/2012.
26.03.2012 Council Regulation (EU) No 267/2012 Revokes and replaces Council Regulation (EU) No 961/2010, and provides for additional measures.
15.03.2012 Council Decision 2012/152/CFSP Provides for a ban on the supply of specialised financial messaging services used to exchange financial data.
23.01.2012 Council Decision 2012/35/CFSP Set out additional restrictions on Iran, including an oil embargo, which would come into force through a Regulation in due course.
Current UK regulations
You are able to download specific forms for licence applications and prior notification and authorisation applications for Iran. Licences authorise certain activities or types of transaction that would otherwise be prohibited by asset freezing legislation.