Guidance

General Trade Licence: Services Necessary for the Continued Operation of the Shah Deniz Gas Field

Published 8 September 2026

1. The Secretary of State grants this General Trade Licence under regulation 41 of the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 (‘Iran Regulations’).

2. The prohibitions in Regulation 27J to 27N, insofar as they relate to the making available or transferring of energy-related goods and technology and provision of technical assistance, financial or brokering services for energy-related goods and technology to a person connected with Iran, of the Iran Regulations do not apply to anything that is authorised under this licence.

Conditions

1. 3. The authorisations in paragraph 5 are subject to the following conditions:
   1. a. The activity taking place is in connection with essential operations of the Shah Deniz project, including the Shah Deniz Gas Field, the South Caucasus Pipeline and the Azerbaijan Gas Supply Company.

Interpretation

4. Unless the context otherwise requires, any term used in this licence has the meaning it bears in the Sanctions and Anti-Money Laundering Act 2018 and the Iran Regulations.

Authorisations

1. 5. Under this licence, subject to the conditions in paragraph 3, a person may:

   1. b. make energy-related goods or energy-related technology available, directly or indirectly, to a person connected with Iran

   2. c. transfer energy-related technology, to a person connected with Iran

   3. d. provide technical assistance, directly or indirectly, relating to energy-related goods or energy-related technology to a person connected with Iran

   4. e. provide financial services, directly or indirectly, to a person connected with Iran, in pursuance of or in connection with an arrangement whose object of effect is-

      1. i. the export of energy-related goods,

      2. ii. the direct or indirect supply or delivery of energy-related goods,

      3. iii. directly or indirectly making energy-related goods or energy-related technology available to a person,

      4. iv. the transfer of energy-related technology, or

      5. v. the direct or indirect provision of technical assistance relating to energy-related goods or energy-related technology

   5. f. make available funds, directly or indirectly, to a person connected with Iran, in pursuance of or in connection with an arrangement whose object of effect is described in 5d

   6. g. provide financial services or funds, directly or indirectly, to a person connected with Iran, in pursuance of or in connection with an arrangement whose object or effect is-

      1. i. the export of energy-related goods to, or for use in, Iran

      2. ii. the direct or indirect supply of energy-related goods to a place in Iran,

      3. iii. directly or indirectly making energy-related goods or energy-related technology available to a person connected with Iran, or for use in Iran

      4. iv. the transfer of energy-related technology to a person connected with Iran, or for use in Iran

      5. v. the direct or indirect provision of technical assistance relating to energy-related goods or energy-related technology to a person connected with Iran, or for use in Iran

   7. h. provide brokering services, directly or indirectly, in relation to an arrangement whose object or effect is-

      1. i. the direct or indirect supply or delivery of energy-related goods from a third country to a place in Iran,

      2. ii. directly or indirectly making energy-related goods or energy related technology available in a third country for indirect or direct supply or delivery to a person connected with Iran, or to a place in Iran

      3. iii. the direct or indirect provision, in a non-UK country of technical assistance relating to energy-related goods or technology, to a person connected with Iran, for use in Iran

      4. iv. the transfer of energy-related technology from a place in a third country, to a person connected with Iran, or to a place in Iran

      5. v. the direct or indirect provision, in a non-UK country, of financial services-
         1. 1. to a person connected with Iran, where arrangement A, or any other arrangement in connection with which arrangement A is entered into, is an arrangement mentioned in 5d
         2. 2. where arrangement A, or any other arrangement in connection with which arrangement A is entered into, is an arrangement 5f

      6. vi. directly or indirectly making funds available, in a non-UK country, where arrangement A, or any other arrangement in connection with which arrangement A is entered into, is an arrangement mentioned in 5d

      7. vii. the direct or indirect provision of funds from a non-UK country, where arrangement A, or any other arrangement in connection with which arrangement A is entered into, is an arrangement mentioned in 5f

Exclusions

6. This licence does not authorise any activities not described in this licence that would otherwise be prohibited under the Iran Regulations.

Requirements

7. The provisions of Regulation 52 (General trade licences: records) of the Iran Regulations apply to any act under the authority of this licence.

8. Any person undertaking activity in paragraph 5 must inform the Department for Business, Innovation, Science, and Trade within 30 calendar days of the activity beginning using the contact form for OTSI.

General

9. Any enquiries regarding this licence should be sent to otsi@businessandtrade.gov.uk.

10. Information provided to the Department for Business, Innovation, Science, and Trade in connection with this licence shall be disclosed to third parties only in compliance with the UK General Data Protection Regulation and the Data Protection Act 2018.

11. This licence takes effect on 29 September 2026.

12. The Secretary of State may vary, revoke or suspend this licence at any time.

Signed

Office of Trade Sanctions Implementation

Department for Business, Innovation, Science, and Trade

Issued on 8 September 2026