Iran nuclear sanctions: statutory guidance
Updated 25 March 2026
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Introduction
This guidance is about the financial, director disqualification, trade and immigration sanctions imposed by The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 (‘the Regulations’).
About the Regulations
The Regulations impose sanctions both for the purpose of giving effect to the United Kingdom’s obligations under United Nations Security Council Resolutions:
- UNSCR 1737
- UNSCR 1747
- UNSCR 1803
- UNSCR 1929
- UNSCR 2231
and for the additional statutory purposes set out in the Regulations.
As a whole this sanctions regime is aimed at encouraging the Iranian Government to comply with relevant UN obligations and abandon nuclear weapons programmes; and at restricting the ability of Iran to develop nuclear weapons delivery systems.
For more details see regulation 4: Purposes.
The legislation.gov.uk webpage tells you if the Regulations are up to date or if there are outstanding amendments. You can also view previous versions using the timeline and a list of the legislation that has affected the regulations, which includes:
About this guidance
As required by section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Secretary of State for Foreign, Commonwealth and Development Affairs has provided this guidance to support compliance with the Regulations.
This guidance is designed to give an overview of the prohibitions and requirements, the enforcement of these, and the circumstances in which exceptions and licences may be used. Where appropriate, it directs you to further detailed guidance to read alongside. See all updates to check this guidance is current.
1. Prohibitions and requirements
Sanctions regulations apply to:
- any individual, business or organisation undertaking activities anywhere in the UK (including the territorial sea)
- any business or organisation incorporated or constituted under the law of any part of the UK undertaking activities anywhere in the world
- any UK national, wherever they are in the world
For full details see section 21 of the Sanctions Act.
The maritime enforcement powers contained in Part 9 of the Regulations apply in relation to British ships in international or foreign waters, ships without nationality in international waters and foreign ships in international waters.
It is prohibited to intentionally participate in any activities if you know that the object or effect of them is directly or indirectly to circumvent the prohibitions imposed by the Regulations or to enable or facilitate a breach of those prohibitions.
If you are unclear about any aspects of the Regulations, in particular about whether action you are considering taking could breach the Regulations, you are advised to seek independent legal advice.
1.1 Designation of persons
Designation of persons provisions are contained in Part 2 of the Regulations.
The Regulations provide that the Secretary of State may designate persons for the purposes of financial and/or director disqualification and/or immigration sanctions if they are, or have been, involved in a relevant nuclear activity (as defined in regulation 6).
The Regulations also provide that each person named by the United Nations Security Council (UNSC) or United Nations Sanctions Committee for the purposes of paragraph 12 of UNSCR 1737, paragraph 4 of UNSCR 1747, paragraph 7 of UNSCR 1803 and paragraphs 11, 12 and 19 of UNSCR 1929 is a designated person for the purposes of the financial sanctions.
Persons subject to a travel ban under UNSCRs 1737, 1747, 1803 and 1929 are dealt with under UK immigration regulations. For further information, see Immigration sanctions.
The UK Sanctions List contains the names of all designated persons (DPs) and the sanctions that have been imposed on them. Checking the UK Sanctions List is an essential part of due diligence for many firms and other organisations.
1.2 Financial sanctions
Financial sanctions provisions are contained in Part 3 of the Regulations.
Asset freeze and making available provisions
The Regulations impose financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly.
These prohibitions also apply in relation to entities owned or controlled by a designated person.
If you find out that a person or organisation you are dealing with is subject to the financial sanctions detailed in the Regulations, you must immediately:
- stop dealing with them
- freeze any assets you are holding for them
- inform OFSI as soon as possible
The Regulations also prohibit the provision of specialised financial messaging services to a designated person.
The Office of Financial Sanctions Implementation (OFSI) is the authority responsible for implementing the UK’s financial sanctions on behalf of HM Treasury. OFSI helps to ensure that financial sanctions are properly understood, implemented and enforced in the UK. See more about how OFSI implements financial sanctions.
1.3 Director disqualification sanctions
Director disqualification provisions are contained in Part 3A of the Regulations.
Persons designated under regulation 5 for the purpose of director disqualification sanctions under regulation 18A are disqualified from:
- being a director of a UK company
- directly or indirectly taking part in or being concerned in the promotion, formation or management of a UK company
- being a director of a foreign company that has sufficient connection to the UK, even if it is not registered, for example, if it carries out business or has assets in the UK
under the provisions of:
- section 11A of the Company Directors Disqualification Act 1986 (CDDA)
- Article 15A of the Company Directors Disqualification (Northern Ireland) Order 2002 (CDD(NI)O)
Companies House and the Department for the Economy (Northern Ireland) are responsible for recording information about director disqualification sanctions in their respective Disqualified Director Registers. Companies House is responsible for annotating the Companies Register and preventing registration of a disqualified director’s appointments.
See more information about director disqualification sanctions.
1.4 Trade sanctions
Trade sanctions provisions are contained in Part 5 of the Regulations.
The Regulations impose trade prohibitions relating to:
-
restricted goods and technology, specifically:
- military goods and military technology (as specified in Schedule 2 to the Export Control Order 2008)
- any thing which falls within Chapter 93 of the Goods Classification Table[footnote 1], other than military goods
- missile-related goods and technology as specified in a UNSC Document S/2012/947l
- nuclear-related goods and technology (meaning anything specified in relevant nuclear list)
- graphite and relevant metals (as defined in regulation 34 of the Regulations)
- relevant enterprise resource planning software (as defined in regulation 34 of the Regulations), and
- other restricted goods and other restricted technology (both as defined in regulation 34 of the Regulations)
- commercial arrangements relating to uranium mining and certain restricted goods and technology
- the provision of certain services in relation to certain ships and aircraft
A number of these goods and services are specified by reference to annexes in EU Regulation 267/2012 of 23 March 2012 concerning restrictive measures against Iran as in force immediately prior to IP completion day.
There are circumstances (set out in the relevant lists of controlled items) in which certain items are not controlled, for example when body armour or a helmet is accompanying a person for that person’s own protection. Please check the relevant lists as applicable.
Further detail on these trade prohibitions, including key terminology used, is explained below. The Regulations contain full definitions of all terms.
Export of goods
The concept of ‘export’ is set out in customs legislation, but is further detailed in Paragraph 32 of Schedule 1 to the Sanctions Act, which clarifies that ‘export’ means export from the UK, but does not capture where goods are removed to the Isle of Man from the UK.
The export prohibition in the Regulations covers export to Iran as well as exports that are for use in Iran. This means that, even if the immediate destination is not Iran, the prohibition may still apply. Exporters should check the ultimate end use of goods and may apply for a licence or contact the Export Control Joint Unit (ECJU) if they know or think the items may be used in Iran.
A sanctions licence is not required for exports of non-military goods covered by the Regulations from Northern Ireland to an EU Member State where the final destination is Iran. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the onward export to Iran. You will also have to comply with any other licensing requirements under UK export control legislation as applicable.
Supply and delivery of goods
Supply and delivery prohibitions in the Regulations prohibit a person from directly or indirectly supplying or delivering restricted goods from a third country to a place in Iran. Regulation 22 specifies that for the purposes of this regulation a third country is a country that is not the UK, Isle of Man or Iran.
The supply and delivery prohibitions also prohibit the direct or indirect supply and delivery of certain goods to a third country from a place in Iran, as set out in regulation 29. Regulation 29 defines ‘third country’ as a country that is not the United Kingdom, the Isle of Man or Iran.
Acquiring or making goods and technology available
Prohibitions in the Regulations on making restricted goods or technology available (e.g. through a sale) include directly or indirectly making them available for use in Iran or to a ‘person connected with Iran’. Regulation 34 sets out when a person is to be regarded as ‘connected with’ Iran (and this applies where the term is used in other trade prohibitions in this Part of the Regulations).
The Regulations prohibit the direct or indirect acquisition of relevant goods and technology which are located in Iran, as set out in regulation 30.
Transfer of technology
Prohibitions in the Regulations on the transfer of restricted technology include transfer to a place in Iran or a person ‘connected with’ Iran.
The term ‘transfer’ is defined in Paragraph 37 of Schedule 1 to the Sanctions Act, which states that it ‘means a transfer by any means (or combination of means), including oral communication and that transfer of goods on which the technology is recorded or from which it can be derived, other than the export of such goods.’
Where military technology is contained within a good, it would be classified as a military good under the accompanying goods-related provisions. This includes information contained on USB memory devices, laptops, tablets and the like.
The transfer of certain technology from a place in Iran to persons outside the United Kingdom or to a place outside the United Kingdom is also prohibited. This provision is set out in regulation 31.
Technical assistance
The term technical assistance in relation to restricted goods or technology is defined in regulation 34, which states that it means:
- technical support relating to the repair, development, production, assembly, testing, use or maintenance of the goods or technology, or
- any other technical service relating to the goods or technology
Prohibitions apply where the technical assistance relates to certain specified goods or technology.
The prohibitions apply to the direct or indirect provision of such technical assistance (1) to persons connected with Iran or (2) for use in Iran.
This means that, even if the person to whom you are providing the relevant technical assistance, is not in or ‘connected with Iran’ the prohibition may still apply if the goods or technology to which the technical assistance relates are for use in Iran. Therefore, if you are intending to provide technical assistance you should check whether the goods or technology may be used in Iran and may apply for a licence or contact ECJU if so.
Financial services and funds related to goods and technology
‘Financial services’ refers to any services of a financial nature in many different forms including insurance and banking. Financial services include payment and money transmission services. The full definition of ‘financial services’ can be found in Section 61 of the Sanctions Act.
‘Funds’ means financial assets and benefits of every kind, including cash, securities and interest. The full definition of ‘funds’ can be found in Section 60 of the Sanctions Act.
Trade sanctions prohibitions on the provision of financial services and funds apply where they relate to certain specified goods or technology.
The prohibitions in the Regulations apply to the direct or indirect provision of financial services, and the direct or indirect making available of funds to persons connected with Iran in pursuance of or in connection with an arrangement set out in Regulation 26(1). This captures arrangements related to the goods or technology controlled by the Regulations, for example an arrangement for the export of goods to or for use in Iran, or direct or indirect supply or delivery of goods.
These prohibitions also prohibit the direct or indirect provision of financial services or funds to anyone, where this is in pursuance of or in connection with specific arrangements as set out in regulation 26(3). This captures arrangements the object or effect of which falls into one of the prohibitions, for example an arrangement for the export of goods to or for use in Iran.
Brokering services
The definition of ‘brokering services’ is set out in regulation 27, which states that it means any service to secure, or otherwise in relation to, an arrangement, including (but not limited to):
- the selection or introduction of persons as parties or potential parties to the arrangement
- the negotiation of the arrangement
- the facilitation of anything that enables the arrangement to be entered into, and
- the provision of any assistance that in any way promotes or facilitates the arrangement
The Regulations prohibit the direct or indirect provision of brokering services where they relate to specific arrangements. Those arrangements are also set out in regulation 27.
Import of goods
The concept of ‘import’ is set out in customs legislation, but is further detailed in Paragraph 33 of Schedule 1 to the Sanctions Act. This clarifies in particular that goods removed to the UK from the Isle of Man are not to be regarded as imported. Paragraph 34 details limited exceptions to this.
The import prohibition in regulation 28 covers imports that are consigned from Iran and goods that originated in Iran. This means that even if the immediate place the goods were shipped from was not Iran, the prohibition may still apply. Therefore, importers should check the original place goods were consigned from and apply for a licence or contact DBT’s Import Controls Team if they think the items may have originated in or have been consigned from Iran.
A sanctions licence is not required for imports of non-military goods covered by the Regulations from an EU Member State which originate in or are consigned from Iran. You will however have to comply with any licensing requirements that apply in the relevant EU Member State for the original import into the customs territory of the EU. You will also have to comply with any other licensing requirements under UK import control legislation as applicable.
Other trade restrictions
Certain other arrangements and services are prohibited in the Regulations. These include arrangements relating to uranium mining and certain restricted goods and technology, and the provision of certain services in relation to certain ships and aircraft.
Provisions on uranium mining and certain restricted goods and technology are set out in regulation 32 and prohibit the entering into of arrangements which have the object or effect of enabling a person connected with Iran (or a person acting on their behalf or at their direction) to participate in or increase their participation in certain specified commercial activities involving uranium mining or certain restricted goods and technology, set out in the Regulation.
Provisions on services in relation to certain ships and aircraft are set out in regulation 33 and prohibit the provision of bunkering or ship supply services to a ship, and engineering or maintenance services to a cargo aircraft, owned or controlled, directly or indirectly, by a person connected with Iran, where the ship or aircraft is carrying relevant restricted items.
Trade sanctions enquiries
The Department for Business and Trade (DBT) leads on trade sanctions. For help with export controls or trade sanctions, contact the Export Control Joint Unit, part of DBT, on: exportcontrol.help@businessandtrade.gov.uk or tradesanctions@businessandtrade.gov.uk
Helpline: +44 (0)20 7215 4594
For further information on import controls and sanctions, contact DBT’s Import Controls and Sanctions team on: importsanctions@businessandtrade.gov.uk
1.5 Immigration sanctions
Immigration sanctions provisions are contained in Part 4 of the Regulations.
The effect of the Regulations is to impose a travel ban on persons who are designated by the Secretary of State for the purposes of being made subject to immigration sanctions under the Sanctions Act. Such persons are excluded persons for the purposes of section 8B of the Immigration Act 1971.
Persons who are subject to existing designations by the UN Security Council or its Sanctions Committee under UNSCRs 1737, 1747, 1803 and 1929 for travel ban purposes are not additionally designated under the Regulations as they are already excluded persons for the purposes of section 8B of the Immigration Act 1971.
Designated individuals under either the Regulations or UNSCRs 1737, 1747, 1803 and 1929 will be refused leave to enter or remain in the UK. Any applications they make for a visa to travel to the UK, including for transit purposes, will be refused. Any foreign national who is subject to a travel ban under the Regulations or UNSCRs 1737, 1848, 1803 or 1929, and who is currently in the UK, will have their permission to stay in the UK cancelled and steps will be taken to remove them from the UK.
If you are the subject of an immigration sanction and try to travel to the UK, carriers are required to deny you boarding.
See more information on how the Home Office deals with those who are subject to a travel ban.
1.6 Information and record-keeping
Information and record-keeping provisions, including financial sanctions reporting obligations, are contained in Part 7 of the Regulations.
Financial sanctions reporting obligations and information requests
For the purpose of the financial sanctions, the Regulations place obligations on relevant firms to report information to HM Treasury (in practice to the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury) about known or suspected designated persons or about persons who may have breached a prohibition or failed to comply with an obligation under specified provisions of the Regulations.
OFSI has powers to request information from, among others, a designated person, including powers to request the production of documents. It is an offence to fail to comply with these requests or provide false information.
If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.
See more guidance about OFSI’s reporting obligations.
Trade sanctions reporting obligations and information requests
The Trade, Aircraft and Shipping Sanctions (Civil Enforcement) (TASSCER) Regulations (2024) place obligations on relevant persons (providers of financial or legal services, or money service businesses, for example) in relation to suspected breaches of certain trade sanctions.
For details see Trade sanctions: reporting obligations.
The Regulations establish powers to request information in relation to the trade sanctions and record-keeping responsibilities for licences. It is an offence to fail to comply with any of these requirements or intentionally obstruct an official in the exercise of these powers.
See more details about information you must provide in response to a trade sanctions information request.
If you are unclear about your obligations or responsibilities, you are advised to seek independent legal advice.
2. Enforcement
Enforcement provisions are contained in Part 8 of the Regulations.
It is a criminal offence to breach sanctions, or to enable or facilitate a breach of, or to circumvent sanctions. The Regulations set out the mode of trial and penalties that apply to such offences.
In some cases, offences are contained in other legislation, such as the Customs and Excise Management Act 1979 (CEMA), or in the regulations made under the Sanctions Act that apply across regimes, such as the TASSCER regulations.
2.1 Financial sanctions enforcement
A breach of the main financial prohibitions or licensing provisions in the Regulations is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 7 years’ imprisonment or a fine, or both.
Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both.
The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, is responsible for monitoring compliance with financial sanctions and for assessing suspected breaches. It also has the power to impose civil monetary penalties and refer cases to law enforcement agencies for criminal investigation and potential prosecution.
OFSI’s approach to compliance and enforcement is outlined in section 7 of OFSI’s general guidance.
For more information about how OFSI assesses suspected breaches and the possible enforcement outcomes, see OFSI’s enforcement guidance.
2.2 Director disqualification sanctions enforcement
A breach of the main prohibitions or licensing provisions is an offence that is triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both.
It is also an offence to provide misleading information to obtain a licence, act outside of permissions given or ignore conditions contained within a licence. A licensing offence carries a maximum sentence on conviction on indictment of 2 years’ imprisonment, or a fine, or both.
The Insolvency Service is responsible for investigating suspected breaches and licensing offences. It has the power to bring prosecutions for breaches and refer cases to other law enforcement agencies for criminal investigation and potential prosecution.
2.3 Trade sanctions enforcement
A breach of the trade sanctions prohibitions is triable either way and carries a maximum sentence on conviction on indictment of 10 years’ imprisonment or a fine, or both.
A breach of the trade sanctions licensing provisions is also triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both.
Offences under the reporting obligations are summary offences and carry a maximum sentence of 6 months’ imprisonment or a fine, or both.
HM Revenue and Customs (HMRC) is responsible for the enforcement of trade sanctions that fall within its remit as the UK’s customs authority and for the enforcement of trade sanctions measures that relate to strategic goods and technology.
If you discover that you have breached any of the trade prohibitions or licensing provisions, you should report the irregularity to HMRC (sometimes known as ‘voluntary disclosure’) as soon as possible. If the irregularity was found on an Export Control Joint Unit compliance audit, the compliance inspector will have informed HMRC and you are strongly advised to do the same. Guidance is available on how to make a voluntary disclosure.
3. Exceptions and licences
Exceptions and licensing provisions are contained in Part 6 of the Regulations.
3.1 Exceptions
An exception gives an automatic exemption to an activity that would otherwise be prohibited under sanctions. It means you can carry out that activity as long as certain defined circumstances, set out in the Regulations, apply to your activity.
An exception applies automatically so you do not require a licence to carry out the proposed activity, but some exceptions have notification obligations.
To check the full legal wording of an exception, go to the regulations listed in Part 6. If you are unsure whether an exception applies in your circumstances, you are advised to seek independent legal advice.
General exceptions
Exception for authorised conduct in a relevant country (regulation 37A)
This exception relates to prohibitions in regulations 12 to 17 and chapters 1 to 3 of Part 5 (Trade).
The exception applies if:
- conduct is authorised by a licence or other authorisation that is issued under the law of the Channel Islands, Isle of Man or any British Overseas Territory for the purpose of disapplying a prohibition in that jurisdiction which corresponds to the relevant prohibition
Exception for acts done for purposes of national security or prevention of serious crime (regulation 38)
This exception can be used in relation to any prohibition or requirement imposed by the Regulations.
The exception applies if:
- a responsible officer has determined the relevant actions to be in the interests of national security, or the prevention or detection of serious crime in the UK or elsewhere
Financial sanctions exceptions
Exceptions for crediting a frozen account (regulation 37)
These exceptions relate to the prohibitions in regulations 12 to 14 about dealing with the funds or economic resources of designated persons and making funds available to them. The exceptions permit, in certain circumstances, frozen accounts to be credited by and transfers made to ’relevant institutions’ – those with permission to carry out regulated activities under the Financial Services and Markets Act 2000 part 4A.
See section 6 of OFSI’s general guidance for details about how to use these exceptions and the related reporting obligations for relevant institutions.
Exception for required payments (regulation 37ZZA)
This exception relates to the prohibitions in regulations 12 and 14 about dealing with the funds or economic resources of designated persons and making funds available for their benefit.
The exception permits certain required payments to be made by, or on behalf of, designated persons to various specified UK public bodies.
See OFSI’s FAQs on required payments for details about how to use these exceptions and the related notification obligations.
United Nations exception for humanitarian assistance (regulation 37ZA)
This exception relates to the prohibitions in regulations 12 to 17 about dealing with the funds or economic resources of designated persons and making funds available to them.
The exception applies if the activity is necessary to:
- ensure the timely delivery of humanitarian assistance, or
- to support other activities that support basic human needs
See section 9 of OFSI’s financial sanctions guidance for charities and non-governmental organisations (NGOs) to check the conditions for this exception and how to use it.
Exception for payment of HM Treasury debt (UN designated persons only) (regulation 37ZZB)
This exception relates to prohibitions in regulations 12 to 14 about dealing with the funds or economic resources of designated persons and making funds available to them or for their benefit.
The exception permits payment in respect of HM Treasury debt to be made to or for the benefit of UN designated persons under certain circumstances.
See section 6.21 of OFSI’s general guidance to check the conditions for this exception and how to use it.
Trade sanctions exceptions
Exception relating to services provided to certain ships and aircraft (regulation 39)
This exception relates to prohibitions in regulation 33 about the provision of bunkering or ship supply services, or engineering or maintenance services in relation to cargo aircraft.
The exception applies if:
- failing to provide the services would endanger the lives of persons on board that ship or aircraft
3.2 Licensing for financial sanctions
A licence is a written permission from OFSI that allows an act that would otherwise be in breach of the financial sanctions prohibitions set out in the regulations.
OFSI has issued general licences that may be used under this regime. For details see OFSI’s general licence page.
In circumstances where there are no applicable exceptions from the prohibitions or general licences, any person (including a designated person) may apply for a licence from OFSI enabling them to deal with the frozen funds or economic resources of the designated person, or to allow these to be made available to or for the benefit of a designated person.
Licensing grounds for financial sanctions
OFSI can only issue individual licences where:
- there is a relevant licensing ground
- the conditions set out in that licensing ground have been met, and
- OFSI considers it appropriate to issue a licence for that purpose
The purposes and activities for which OFSI may grant an individual licence are set out in Schedule 2 to the Regulations. In summary these include:
- basic needs
- reasonable professional fees for or reasonable expenses associated with the provision of legal services
- reasonable fees or service charges arising from the routine holding or maintenance of frozen funds or economic resources
- extraordinary expenses
- judicial decisions etc [footnote 2]
- prior obligations
- activities related to the Joint Comprehensive Plan of Action
- humanitarian assistance activities (non-UN designated persons only)
- diplomatic missions etc (non-UN designated persons only)
- extraordinary situations (non-UN designated persons only)
- insolvency (non-UN designated persons only)
OFSI may need to notify, or in some cases seek approval from the relevant United Nations Sanctions Committee before issuing a licence. These requirements are set out in the relevant UN Security Council Resolutions. These requirements will lengthen the processing time for such licence applications and may in some cases prevent a licence from being issued.
See section 6 of OFSI’s general guidance for more information about exceptions and licensing grounds.
See OFSI’s licensing page for licence application forms and guidance.
3.3 Licensing for director disqualification sanctions
The designated person, or their authorised representative, can make an application for a licence to the Insolvency Service. See more details about how to apply.
The Insolvency Service will assess and grant or refuse licence applications on behalf of the Secretary of State. Companies House is responsible for updating the Companies Register when a licence is granted.
You should not assume that a licence will be granted or act as the director of a company – or directly or indirectly take part in or be concerned in the promotion, formation or management of a company – until your licence has been granted.
3.4 Licensing for trade sanctions
Licences may also be issued for certain trade activities that would otherwise be prohibited by the Regulations. The Department for Business and Trade (DBT) has overall responsibility for trade sanctions licensing. The Secretary of State for Business and Trade is ultimately responsible for decisions to grant or refuse a trade sanctions licence in any individual case.
The Export Control Joint Unit (ECJU), part of DBT, is responsible for licensing the export of sanctioned goods, software and technology. See how to apply for an export licence. Information on the activities you wish to carry out and relevant documentation can be provided in a cover letter and attached to the application.
In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 5 of the Regulations, the Secretary of State will consider each application on a case-by-case basis to determine whether granting a licence would be consistent with the stated purposes of the sanctions regime and any UN or other relevant international law obligations.
For some prohibitions there are some specific activities which DBT considers are likely to be consistent with the aims of the sanctions and relevant international commitments. These are set out in the table below. If you think that your proposed activity falls within one of these specific descriptions, you should make this clear and explain why you believe this to be the case in your application for a licence.
There are some activities which DBT considers likely to be clearly contrary to the aims of the sanctions and these are also set out in the table below.
Some of the licensing grounds set out below also include approval and/or notification requirements relating to the UN Security Council (‘UNSC’), the UN Security Council Sanctions Committee on Iran as established under UNSCR 1737 and the International Atomic Energy Agency (‘IAEA’). The requirements to seek approval or notification are set out in the UNSCRs 1737, 1747, 1803, 1929 and 2231 and DBT will need to ensure that it complies with these requirements when processing licences under the Regulations. This means that:
- where the Secretary of State is required to give the UNSC and the IAEA notice of a licence granted under this sanctions regime, the Secretary of State will first determine whether granting a licence would be consistent with the purposes set out in the Regulations. If the Secretary of State determines that granting a licence would be consistent with those purposes, the UK (via the FCDO) will notify the UNSC and IAEA at least 10 working days before the activity occurs
- where approval from the UNSC is required in order to grant a licence, the Secretary of State will first determine whether granting the licence would be consistent with the purposes set out in the Regulations. If the Secretary of State determines that granting a licence would be consistent with those purposes, the UK (via the FCDO) will submit the necessary information to the UNSC to seek the approval of the Committee. The Secretary of State will only grant a licence when confirmation of the Committee’s approval has been received
You should not assume that a licence will be granted or engage in any activities prohibited by trade sanctions until your licence has been granted.
Considerations for trade sanctions licences
| Prohibitions | Type of consideration |
|---|---|
| Regulations 21 to 24 | Considerations for export supply and delivery, making available and transfer of military goods and technology |
A licence may be granted for the export, supply and delivery, making available or transfer of non-combat vehicles which have been manufactured or fitted with materials to provide ballistic protection intended solely for the protective use of UK personnel in Iran.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 21 to 24 | Considerations for the export, supply and delivery, making available, and transfer of nuclear-list goods or nuclear-list technology |
A licence may be granted where the Committee determines in advance and on a case-by-case basis that such supply, sale, transfer or provision of such items or assistance would clearly not contribute to the development of Iran’s technologies in support of its proliferation of sensitive nuclear activities and development of nuclear weapon delivery systems, including where such items or assistance are for food, agricultural, medical or other humanitarian purposes, provided that:
(a) contracts for delivery of such items or assistance include appropriate end-user guarantees, and
(b) Iran has committed not to use such items in proliferation sensitive nuclear activities or for development of nuclear weapon delivery systems
A licence may be granted for items in Section 1 and Section 2 of the Annex to the relevant revision of INFCIRC/254/Rev.8/Part2, as notified in advance to the Committee, only when for:
i) exclusive use in light water reactors as defined in paragraph 3 of UNSCR 1737
ii) low-enriched uranium covered when it is incorporated in assembled nuclear fuel elements for such reactors as defined in paragraph 3 of UNSCR 1737, and
| iii) where such supply, sale or transfer is necessary for technical cooperation provided to Iran by the IAEA or under its auspices as provided for in paragraph 16 of UNSCR 1737 (2006) |
A licence may be granted for the export, supply and delivery, making available, or transfer of nuclear-list goods or technology without the prior approval of the Committee where the export, supply and delivery, making available, or transfer relates directly to:
(1) the modification of two cascades at the Fordow facility for stable isotope production
(2) the export of Iran’s enriched uranium in excess of 300 kilograms in return for natural uranium, or
(3) the modernisation of the Arak reactor based on the agreed conceptual design and, subsequently, on the agreed final design of such reactor,
and provided that the activities will be undertaken strictly in accordance with paragraph 22 of UNSCR 2231.
If a licence is granted for an activity which directly relates to (1) to (3) above, then the Secretary of State is required to notify the Committee and, when constituted, the Joint Commission 10 days in advance of the activities occurring, which means that no activity can commence until this period has expired. The Secretary of State is also required to notify the IAEA within 10 days of the activities occurring. In all the above instances, all licence applications must demonstrate (and a licence may be refused if you cannot show):
(1) all relevant requirements of the Guidelines as set out in the Nuclear Suppliers Group list have been met, and
(2) the Secretary of State will have a right to verify the end-use and end-use location of any supplied item (in that such rights have been obtained and can be exercised effectively)
| Prohibitions | Type of consideration |
|---|---|
| Regulations 25 to 27 | Considerations for the provision of technical assistance, financial services and funds, and brokering services relating to nuclear-list goods or nuclear-list technology |
A licence may be granted where the Committee determines in advance and on a case-by-case basis that such supply, sale, transfer or provision of such items or assistance would clearly not contribute to the development of Iran’s technologies in support of its proliferation sensitive nuclear activities and of development of nuclear weapon delivery systems, including where such items or assistance are for food, agricultural, medical or other humanitarian purposes, provided that:
(a) contracts for delivery of such items or assistance include appropriate end-user guarantees, and
| (b) Iran has committed not to use such items in proliferation sensitive nuclear activities or for development of nuclear weapon delivery systems |
A licence may be granted for the provision of technical assistance, financial services and funds, or brokering services relating to nuclear-list goods or technology without the prior approval of the Committee where provision of technical assistance, financial services and funds, and brokering services relate directly to:
(1) the modification of two cascades at the Fordow facility for stable isotope production
(2) the export of Iran’s enriched uranium in excess of 300 kilograms in return for natural uranium, or
(3) the modernisation of the Arak reactor based on the agreed conceptual design and, subsequently, on the agreed final design of such reactor, and provided that the activities will be undertaken strictly in accordance with paragraph 22 of UNSCR 2231
If a licence is granted for an activity which directly relates to (1) to (3) above, then the Secretary of State is required to notify the Committee and, when constituted, the Joint Commission 10 days in advance of the activities occurring, which means that no activity can commence until this period has expired. The Secretary of State is also required to notify the IAEA within 10 days of the activities occurring. In all the above instances, all licence applications must demonstrate (and a licence may be refused if you cannot show):
(1) all relevant requirements of the Guidelines as set out in the Nuclear Suppliers Group list have been met, and
(2) the Secretary of State will have a right to verify the end-use and end-use location of any supplied item (in that such rights have been obtained and can be exercised effectively)
| Prohibitions | Type of consideration |
|---|---|
| Regulations 21 to 24 | Considerations for the export, supply and delivery, making available, and transfer of other restricted goods or other restricted technology |
A licence may be granted where the Committee determines in advance and on a case-by-case basis that such supply, sale, transfer or provision of such items or assistance would clearly not contribute to the development of Iran’s technologies in support of its proliferation sensitive nuclear activities and of development of nuclear weapon delivery systems, including where such items or assistance are for food, agricultural, medical or other humanitarian purposes, provided that:
(a) contracts for delivery of such items or assistance include appropriate end-user guarantees, and
| (b) Iran has committed not to use such items in proliferation sensitive nuclear activities or for development of nuclear weapon delivery systems |
A licence may be granted for the export, supply and delivery, making available or transfer of other restricted goods or technology where the export, supply and delivery, making available, and transfer relates directly to:
(1) the necessary modification of two cascades at the Fordow facility for stable isotope production
(2) the export of Iran’s enriched uranium in excess of 300 kilograms in return for natural uranium, or
(3) the modernisation of the Arak reactor based on the agreed conceptual design and, subsequently, on the agreed final design of such reactor, and provided that the activities will be undertaken strictly in accordance with paragraph 22 of UNSCR 2231
If a licence is granted for an activity which directly relates to (1) to (3) above, then the Secretary of State is required to notify the Committee and, when constituted, the Joint Commission 10 days in advance of the activities occurring, which means that no activity can commence until this period has expired. The Secretary of State is also required to notify the IAEA within 10 days of the activities occurring.
In all the above instances, all licence applications must demonstrate (and a licence may be refused if you cannot show):
(1) all relevant requirements of the Guidelines as set out in the Nuclear Suppliers Group list have been met, and
(2) the Secretary of State will have a right to verify the end-use and end-use location of any supplied item (in that such rights have been obtained and can be exercised effectively)
| Prohibitions | Type of consideration |
|---|---|
| Regulations 25 to 27 | Considerations for the provision of technical assistance, financial services and funds, and brokering services relating to other restricted goods or other restricted technology |
A licence may be granted where the Committee determines in advance and on a case-by-case basis that such supply, sale, transfer or provision of such items or assistance would clearly not contribute to the development of Iran’s technologies in support of its proliferation sensitive nuclear activities and of development of nuclear weapon delivery systems, including where such items or assistance are for food, agricultural, medical or other humanitarian purposes, provided that:
(a) contracts for delivery of such items or assistance include appropriate end-user guarantees, and
| (b) Iran has committed not to use such items in proliferation sensitive nuclear activities or for development of nuclear weapon delivery systems |
A licence may be granted for the provision of technical assistance, financial services and funds, or brokering services relating to other restricted goods or technology where provision of technical assistance, financial services and funds, or brokering services relate directly to:
(1) the necessary modification of two cascades at the Fordow facility for stable isotope production
(2) the export of Iran’s enriched uranium in excess of 300 kilograms in return for natural uranium, or
(3) the modernisation of the Arak reactor based on the agreed conceptual design and, subsequently, on the agreed final design of such reactor and provided that the activities will be undertaken strictly in accordance with UNSCR 2231. And provided that the activities will be undertaken strictly in accordance with paragraph 22 of UNSCR 2231.
If a licence is granted for an activity which directly relates to (1) to (3) above, then the Secretary of State is required to notify the Committee and, when constituted, the Joint Commission 10 days in advance of the activities occurring, which means that no activity can commence until this period has expired. The Secretary of State is also required to notify the IAEA within 10 days of the activities occurring.
In all the above instances, all licence applications must demonstrate (and a licence may be refused if you cannot show):
(1) all relevant requirements of the Guidelines as set out in the Nuclear Suppliers Group list have been met, and
(2) the Secretary of State will have a right to verify the end-use and end-use location of any supplied item (in that such rights have been obtained and can be exercised effectively).
| Prohibitions | Type of consideration |
|---|---|
| Regulations 28 to 31 | Considerations for the import, supply and delivery, and acquisition of other restricted goods, and the acquisition or transfer of other restricted technology |
A licence may be granted for the import, supply and delivery and acquisition of other restricted goods, or the acquisition or transfer of ‘other restricted technology’ where such activity relates directly to:
(1) the necessary modification of two cascades at the Fordow facility for stable isotope production
(2) the export of Iran’s enriched uranium in excess of 300 kilograms in return for natural uranium, or
(3) the modernisation of the Arak reactor based on the agreed conceptual design and, subsequently, on the agreed final design of such reactor, and provided that the activities will be undertaken strictly in accordance with UNSCR 2231.
Licence applications must demonstrate (and a licence may be refused if you cannot show) that the Secretary of State will have a right to verify the end-use and end-use location of any supplied item (in that such rights have been obtained and can be exercised effectively). An end use statement will need to be completed with your application.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 23 to 24 | Considerations for the making available and transfer of relevant enterprise resource planning software |
A licence for the making available or transfer of relevant enterprise resource planning software designed will not be granted where the Secretary of State has reasonable grounds to determine that:
(1) the activities concerned are or may be intended for use in connection with:
(a) reprocessing or enrichment-related, heavy water-related, or other nuclear-related activities inconsistent with the Regulations
(b) Iran’s military or ballistic missile programme, or
(2) the activities concerned are or may be intended to directly or indirectly benefit the Iranian Revolutionary Guard Corps.
All licence applications relating to the above activities must demonstrate (and a licence may be refused if you cannot show) that all relevant contracts connected with the making available or transfer of relevant enterprise resource planning software include appropriate end-user guarantees.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 25 to 27 | Considerations for the provision of technical assistance, financial services and funds, and brokering services relating to relevant enterprise resource planning software |
A licence for the provision of technical assistance, financial services and funds, or brokering services relating to relevant enterprise resource planning software, will not be granted where the Secretary of State has reasonable grounds to determine that:
(1) the activities concerned are or may be intended for use in connection with:
(a) reprocessing- or enrichment-related, heavy water-related, or other nuclear-related activities inconsistent with the Regulations
(b) Iran’s military or ballistic missile programme, or
(2) the activities concerned are or may be intended to directly or indirectly benefit the Iranian Revolutionary Guard Corps
All licence applications relating to the above activities must demonstrate (and a licence may be refused if you cannot show) that all relevant contracts connected with the provision of technical assistance, financial services and funds or brokering services relating to relevant enterprise resource planning software include appropriate end-user guarantees.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 21 to 24 | Considerations for the export, supply and delivery, making available, and transfer of ‘graphite and relevant metals’ |
A licence for the export, supply and delivery, making available, or transfer of graphite and relevant metals will not be granted where the Secretary of State has reasonable grounds to determine that:
(1) the activities concerned are or may be intended for use in connection with:
(a) reprocessing- or enrichment-related, heavy water-related, or other nuclear-related activities inconsistent with the Regulations
(b) Iran’s military or ballistic missile programme, or
(2) the activities concerned are or may be intended to directly or indirectly benefit the Iranian Revolutionary Guard Corps.
All licence applications relating to the above activities must demonstrate (and a licence may be refused if you cannot show) that all relevant contracts connected with the export, supply and delivery, making available or transfer of such items include appropriate end-user guarantees.
| Prohibitions | Type of consideration |
|---|---|
| Regulations 25 to 27 | Considerations for the provision of technical assistance, financial services and funds, and brokering services relating to ‘graphite and relevant metals’ |
A licence for the provision of technical assistance, financial services and funds, or brokering services relating to graphite and relevant metals will not be granted where the Secretary of State has reasonable grounds to determine that:
(1) the activities concerned are or may be intended for use in connection with:
(a) reprocessing- or enrichment-related, heavy water-related, or other nuclear-related activities inconsistent with the Regulations
(b) Iran’s military or ballistic missile programme, or
(2) the activities concerned are or may be intended to directly or indirectly benefit the Iranian Revolutionary Guard Corps.
All licence applications relating to the above activities must demonstrate (and a licence may be refused if you cannot show) that all relevant contracts connected with the provision of technical assistance, financial services and funds, or brokering services relating to such items include appropriate end-user guarantees.
| Prohibitions | Type of consideration |
|---|---|
| Regulation 33 | Considerations for the provision of services in relation to certain ships and aircraft |
A licence will not be granted for the provision of bunkering or ship supply services or for engineering or maintenance services in relation to cargo aircraft unless the provision of such services is necessary for humanitarian and safety purposes.
This would be subject to UNSC approval.
When you export or import goods, you may need to submit a declaration: guidance is available on:
Overlap with strategic export licensing
Military goods and military technology
Please note that the export of and trade in military goods and military technology are also controlled under the Export Control Order 2008 and so you may also need a licence which is valid under that legislation. This means that all licence applications relating to military goods and military technology will also need to be considered against the Strategic Export Licensing Criteria. A licence under the Regulations is unlikely to be granted if a licence is refused for the same activity under the Export Control Order 2008.
The way this will work in practice is that we will consider an application for a licence which relates to activities that are licensable under both the Regulations and the Export Control Order 2008 as an application for a licence under both pieces of legislation. This means that only a single licence application is required.
The application will be considered against the relevant licensing criteria. If a licence is granted it will be valid under both the Export Control Order 2008 and the Regulations.
Dual-use goods and technology
Please note that the export and trade in dual-use goods and technology are controlled under the Dual-Use Regulation. Authorisations under that Regulation are granted by the Secretary of State for Business and Trade under licensing powers in the Export Control Order 2008.
This means that all licence applications relating to items which are controlled dual-use goods and technology will also need to be considered against the Strategic Export Licensing Criteria.
As explained above in relation to military goods and technology, only a single licence application will be required in relation to dual-use goods and technology which falls within the scope of both the Regulations and the Dual-Use Regulation. If the application is compatible with both criteria, a licence will be granted which will be valid under the Dual-Use Regulation and the Export Control Order 2008 as well as the Regulations.
Overlap between trade sanctions and financial sanctions
You may need a licence from OFSI as well as from ECJU, OTSI or the Import Controls Team. See the guidance on licensing for more details.
Transit control
Certain goods transiting the UK are still regarded as being exported when they leave the country and are therefore subject to control. Article 17 of the Export Control Order 2008 includes a transit and transhipment exception meaning that in many situations a licence is not required. This exception does not apply to goods destined for Iran, meaning that a licence is required to transit goods through the UK or to tranship them in the UK with a view to re-exportation to Iran.
3.5 Directions in respect of immigration sanctions
If you are subject to immigration sanctions the Home Office may direct, on a case by case basis, that the sanction does not apply in particular circumstances, such as for travel to, or through, the UK for a UN sponsored meeting. You can check how to apply for a UK visa, and find further information about travelling to the UK on GOV.UK.
4. Further information
The UK sanctions hub page is a central point for all sanctions content, including links to introductory guidance, sector-specific guidance, reporting obligations, blogs, and email alert services.
You can report a suspected breach of sanctions if you think you, or someone else, may have breached sanctions, or be attempting to circumvent sanctions.
For specific queries about this sanctions regime, email: fcdo.correspondence@fcdo.gov.uk
For other contact details, see Government departments and agencies responsible for sanctions.
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‘the Goods Classification Table’ means the table so named in Annex I in Part Three of the Tariff of the United Kingdom. ↩
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Paragraph 7A of Schedule 2 sets out how this applies to UN designated persons, and paragraph 10B of Schedule 2 sets out how it applies to non-UN designated persons. ↩