Statutory guidance

Iran sanctions: statutory guidance

Updated 25 March 2026

Introduction

This guidance is about the financial, director disqualification, trade and immigration sanctions imposed by The Iran (Sanctions) Regulations 2023 (‘the Regulations’).

About the Regulations

The Regulations impose sanctions for the purposes of encouraging the Government of Iran^{[footnote 1]} to comply with international human rights law, respect human rights and deter the Government of Iran or an armed group backed by the Government of Iran ^{[footnote 2]} from conducting hostile activity against the United Kingdom or any other country. 

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. For past amendments that have been made to the Regulations see:

• the Iran (Sanctions) (Amendment) Regulations 2024

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 11 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 immigration sanctions if they are, or have been, involved in a specified activity (as defined in regulation 8). The Secretary of State may also designate persons for shipping and director disqualification sanctions (as set out in regulation 5).  

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 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 4 of the Regulations.

Persons designated under regulation 5 for the purpose of director disqualification sanctions under regulation 21 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 6 of the Regulations.

The Regulations impose trade prohibitions relating to:

• goods and technology which might be used for internal repression (as specified in Schedule 2 to the Regulations)
• goods and technology which might be used for the monitoring and interception of telecommunications (as specified in Schedule 3 to the Regulations) 
• the provision of interception and monitoring services (as defined at regulation 26) to or for the benefit of the Government of Iran  *goods and technology of strategic concern, including those used in Iran’s Unmanned Aerial Vehicle and missile programmes (as specified in Schedule 4 to the Regulations).

Technical guidance on interception and monitoring is available. 

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. 

Goods of strategic concern or technology of strategic concern are identified by reference to commodity codes in the Goods Classification Table. The UK Tariff sets out a system for the classification of goods for importers to ascertain the applicable rate of import duty for their goods. It is this system of classification that is used in the Regulations in order to determine whether these goods are within scope of the prohibitions. 

This means that where commodity codes are used in the Regulations, the relevant goods are those which would be classified under the relevant commodity code (applying the rules in the UK Tariff) if the goods were being imported to the UK. 

Some of the listings of commodity codes in the Regulations have an ‘ex’ before the code. Where this ‘ex’ appears before a commodity code this means the prohibitions in the Regulations do not apply to all of the items under that commodity code. The prohibitions will only apply to those items that (1) would be classified under the commodity code and (2) match the description given next to the relevant ‘ex’ code entry in the Regulations. 

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 exports 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 goods from a third country to a place in Iran. Regulations 29(4) and 38(4) specify that for the purposes of this regulation a third country is a country that is not the UK, Isle of Man or Iran. 

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 27(4) 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). 

Transfer of technology 

Prohibitions in the Regulations on the transfer of restricted technology include transfer to a place in Iran or to 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 restricted technology is contained within a good, it would be classified as a restricted good under the accompanying goods-related provisions. This includes information contained on USB memory devices, laptops, tablets and the like. 

Technical assistance 

The term ‘technical assistance’ in relation to goods or technology is defined in regulation 27, 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 providing technical assistance you should check whether the goods or technology may be used in Iran and apply for a licence or contact ECJU if so. 

The following Regulations prohibit the direct or indirect provision of technical assistance to specific arrangements:  

• Regulation 32 (relating to restricted goods and restricted technology) 
• Regulation 41 - (relating to goods of strategic concern  and technology of strategic concern)

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 the Regulations. This captures arrangements where the object or effect falls into one of the prohibitions, for example the export of restricted goods or direct or indirect supply or delivery of restricted goods. 

The following regulations prohibit the direct or indirect provision of financial services to specific arrangements:  

• Regulation 33 (relating to restricted goods and restricted technology) 
• Regulation 42 (relating to goods of strategic concern and technology of strategic concern)

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 set out in: 

• Regulation 34 (relating to restricted goods and restricted technology) 
• Regulation 43 (relating to goods of strategic concern and technology of strategic concern)

Other service provisions 

Provisions on interception and monitoring services are set out in regulation 35 and relate to the provision of such services to or for the benefit of the Government of Iran. The definition of ‘interception and monitoring services’ is set out in regulation 26. 

Trade sanctions enquiries

For general guidance on export controls and trade sanctions, contact the Export Control Joint Unit on: exportcontrol.help@businessandtrade.gov.uk

Helpline: +44 (0)20 7215 4594

For queries about interception and monitoring services sanctions, contact the Office of Trade Sanctions Implementation (OTSI). 

1.5 Transport sanctions 

Transport sanctions provisions are contained in Part 7 of the Regulations.

The Regulations prevent ships specified by the Secretary of State or ships owned, controlled, chartered or operated by designated persons, from entering ports in the United Kingdom. The Regulations also confer powers on the Secretary of State and harbour authorities to issue port barring directions to the master or pilot of a specified ship. The Regulations provide the Secretary of State with a power to control the movement of specified ships or ships owned, controlled, chartered or operated by designated persons by requiring them to leave or enter specified ports, proceed to a specified place or remain where they are.

The Regulations also confer powers on the Secretary of State and harbour authorities to detain specified ships or ships owned, controlled, chartered or operated by designated persons at ports or anchorages in the UK.

The Regulations prohibit the registration of ships owned, controlled, chartered or operated by designated persons on the UK Ship Register and confer powers on the Secretary of State to direct the UK Ship Registrar to terminate the registration of specified ships or ships owned, controlled, chartered or operated by designated persons. 

For guidance on mandatory reporting to DfT, see Information and record keeping.

1.6 Immigration sanctions 

Immigration sanctions provisions are contained in Part 5 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. 

Designated individuals 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, 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.

1.7 Information and record keeping 

Information and record-keeping provisions, including financial sanctions reporting obligations, are contained in Part 9 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 and transport sanctions reporting obligations and information requests

Trade and transport 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
• relevant persons (a pilot, airport operator, ship’s master or harbour authority, for example) in relation to suspected breaches of aircraft and shipping sanctions

For details see:

• Trade sanctions: reporting obligations
• Transport sanctions: reporting obligations

The Regulations establish powers to request information in relation to the trade and transport 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
• in response to a transport 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 Trade, Aircraft and Shipping Sanctions (Civil Enforcement) Regulations 2024 (TASSCER).

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.

The Office of Trade Sanctions Implementation (OTSI), part of DBT, is responsible for the civil enforcement of certain trade sanctions including services and the movement of goods involving UK companies or persons that do not cross the UK border. For information about how OTSI assesses breaches and the possible enforcement outcomes, see OTSI’s enforcement guidance.

2.4 Transport sanctions enforcement

A breach of the following transport sanctions relating to ships 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. This includes failing to comply with: 

• prohibitions on port entry 
• a port barring direction 
• a port entry or movement direction 

A breach of the transport sanctions licensing conditions is also triable either way and carries a maximum sentence on conviction on indictment of 2 years’ imprisonment or a fine, or both. 

The offence of failing to comply with a detention direction in relation to a ship is triable either way and carries a sentence or a fine.

Disclosure of confidential information is an offence which carries a maximum sentence of 6 months’ imprisonment on summary conviction or a fine, or both.  

A failure to comply with the reporting obligations is a criminal offence and carries a maximum sentence of 6 months’ imprisonment on summary conviction or a fine, or both. See Transport sanctions: reporting obligations. 

DfT as the enforcement authority is supported by the Maritime and Coastguard Agency (MCA), harbour authorities, the Civil Aviation Authority (CAA), National Air Traffic Services (NATS) and airport operators. 

DfT also has the power to impose civil monetary penalties for breaches of transport sanctions and to refer cases to law enforcement agencies for investigation and potential prosecution. 

If you become aware that a breach of the transport sanctions detailed in the Regulations has taken or will take place, you can report it by emailing transportsanctions@dft.gov.uk

For more information about how DfT assesses breaches of transport sanctions and the possible enforcement outcomes, see DfT’s enforcement guidance.

3. Exceptions and licences

Exceptions and licensing provisions are contained in Part 8 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 58)

This exception relates to prohibitions in regulations 15 to 19 and chapters 2, 3 or 4 of Part 6 (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 59)

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 55)

These exceptions relate to the prohibitions in regulations 15 to 17 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 55)

This exception relates to the prohibitions in regulations 15 and 17 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.

Trade and transport sanctions exceptions

Exception for emergencies in certain cases (regulation 56)

This exception relates to the prohibitions in regulations 28 to 34 and 37 to 43 about the export, supply, deliver, making available and transfer of restricted goods and goods of strategic concern, and related services, to Iran, to a person connected with Iran, for use in Iran, or to a place in Iran.

The exception applies if:

• the act is assisting with the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, infrastructure or the environment

This exception should only be relied on where there is genuinely insufficient time to apply for a licence to cover the activity of assisting in prevention or mitigation of the event.

There is a notification requirement that satisfactory justification is received within 5 working days of the day on which the act was done.

Exceptions for personal effects, personal use and diplomatic missions (regulation 56A)

These exceptions related to the prohibitions in regulations 37 to 43 about the export, supply, delivery, transfer, and related services, of goods and technology of strategic concern to Iran, to a person connected with Iran, for use in Iran, or to a place in Iran.

The exceptions apply if the goods are:

• the personal effects of a person travelling to Iran,
• of a non-commercial nature for the personal use of a person travelling to Iran and contained in that person’s luggage, or
• necessary for the official purposes of a diplomatic mission or consular post in Iran, or of an international organisation enjoying immunities in accordance with international law

Exceptions for certain ships to enter UK ports (regulation 57)

These exceptions relate to prohibitions in regulation 46 about the granting of, or causing or permitting, access to a UK port.

The exceptions apply if:

• the access is needed by a ship in the case of an emergency, or
• required in accordance with a movement direction under regulation 47 or 48

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.

You should not assume that a licence will be granted or engage in any activities prohibited by financial sanctions until your licence has been granted.

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 5 to the Regulations. In summary these are:

• 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 
• humanitarian assistance activities etc 
• diplomatic missions 
• extraordinary situation
• prior obligations 
• medical goods or services 
• production or distribution of food for the benefit of the civilian population of a country
• insolvency 

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. 

DBT has 3 licensing bodies responsible for administering licences on behalf of the Secretary of State. Which body you need to apply through is dependent on the activity you want to carry out.  

If you are carrying out activity that falls under the remit of more than one licensing body, you will need to submit separate licence applications for each one.  

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.

DBT’s Import Controls team is responsible for licensing the import of (otherwise sanctioned) goods, software and technology. See guidance on how to apply for an import licence. The Import Controls team will, to the extent possible, aim to inform the trader of the application outcome within 30 days. However, in some circumstances, for operational or legal reasons, DBT may need to take longer than the 30 day period. They will inform the applicant if this is the case. 

The Office of Trade Sanctions Implementation (OTSI) can issue licences for (otherwise sanctioned) interception and monitoring services.

DBT has produced guidance where you can check which trade licence you need. This will guide you to the application page for each type.

In making decisions on whether to grant a licence to permit something which would otherwise be prohibited under Part 6 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. 

Licences granted will not permit activity in respect of Northern Ireland that is not consistent with EU sanctions regulations as they apply via the Northern Ireland Protocol.   

For some prohibitions there are some specific activities which DBT considers are likely to be consistent with the aims of the sanctions. 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. 

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 28 to 31	Considerations for the export, making available, transfer, supply and delivery of goods or technology which might be used for internal repression

A licence may be granted if the goods or technology are intended solely for the protective use of UK government personnel in Iran.

A licence may be granted if the goods or technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.

A licence may be granted if the goods or technology are necessary for the delivery of humanitarian assistance activity.

A licence may be granted if the goods or technology are provided for medical and pharmaceutical purposes for the benefit of the civilian population.

Prohibitions	Type of consideration
Regulations 32 to 34	Considerations for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology which might be used for internal repression

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology which are intended solely for the protective use of UK government personnel in Iran.

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology which are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology are necessary for the delivery of humanitarian assistance activity.

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology which are provided for medical and pharmaceutical purposes for the benefit of the civilian population.

Prohibitions	Type of consideration
Regulations 28 to 31	Considerations for the export, making available, transfer, supply and delivery of goods or technology which might be used for the monitoring and interception of telecommunications

A licence will not be granted if the Secretary of State has reasonable grounds to determine that the goods or technology would be used for the monitoring or interception of internet or telephone communications in Iran by the Government of Iran.[footnote 3]

A licence may be granted if the goods or technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.

A licence may be granted if the goods or technology are necessary for the delivery of humanitarian assistance activity.

A licence may be granted if the goods or technology are provided for medical and pharmaceutical purposes for the benefit of the civilian population.

Prohibitions	Type of consideration
Regulations 32 and 34	Considerations for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology which might be used for the monitoring and interception of telecommunication

A licence will not be granted if the technical assistance, brokering services, or financial services or funds relate to goods or technology that the Secretary of State has reasonable grounds to determine would be used for the monitoring or interception of internet or telephone communications in Iran by the Government of Iran.

A licence may be granted if the technical assistance, brokering services, or financial services or funds relate to goods or technology which are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology are necessary for the delivery of humanitarian assistance activity.

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology which are provided for medical and pharmaceutical purposes for the benefit of the civilian population.

Prohibitions	Type of consideration
Regulation 35	Provision of interception and monitoring services

A licence will not be granted if the Secretary of State has reasonable grounds to determine that the services would be used to monitor and intercept internet or telephone communications in Iran by the Government of Iran.

A licence may be granted if the services are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.

Prohibitions	Type of consideration
Regulation 37 to 40	Considerations for the export, making available, transfer, supply and delivery of goods or technology of strategic concern

A licence may be granted if the goods or technology are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.

A licence may be granted if the goods or technology are necessary for the delivery of humanitarian assistance activity.

A licence may be granted if the goods or technology are provided for medical and pharmaceutical purposes for the benefit of the civilian population.

Prohibitions	Type of consideration
Regulation 41 to 43	Considerations for the provision of technical assistance, brokering services, financial services or funds relating to goods or technology of strategic concern

A licence may be granted if the technical assistance, brokering services, or financial services or funds relate to goods or technology which are necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health and safety, including the safety of existing infrastructure, or the environment.

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology are necessary for the delivery of humanitarian assistance activity.

A licence may be granted if the technical assistance, brokering services, financial services or funds relate to goods or technology which are provided for medical and pharmaceutical purposes for the benefit of the civilian population.

When you export goods, you may need to submit an electronic export declaration: guidance is available on how to make an export declaration. 

Overlap with strategic export licensing 

Military goods and military technology

Please note 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 of and trade in dual-use goods and technology are also 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. A licence under the Regulations is unlikely to be granted if an authorisation is refused for the same activity under the Dual-Use Regulation. 

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 

If you export goods or services, you need to consider if financial sanctions apply to you. You may need a licence from OFSI as well as from the Export Control Joint Unit. 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 Overlap with Iran (nuclear) sanctions regime 

Please note the export of and trade in goods, technology and services is also restricted under the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019.  The licensing grounds above are only applicable to the Iran (Sanctions) Regulations 2023.   This means that all licence applications relating to restricted goods, technology and services will also need to be considered against the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 licensing grounds.  A licence under the Regulations is unlikely to be granted if a licence is refused for the same activity under the Iran (Sanctions) (Nuclear) (EU Exit)Regulations 2019. 

The way this will work in practice is that we will consider such applications under both Regulations. 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 Regulations. 

3.6 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.

1. ‘The Government of Iran’ is defined in the Regulations as including its public bodies, corporations or agencies, or any person acting on its behalf or at its direction.   ↩

2. ‘An armed group backed by the Government of Iran’ is defined in the Regulations as including any armed group which— a) is being or has been armed, trained or funded by the Government of Iran, b) is taking or has taken direction from the Government of Iran, or c) is acting or has acted for the benefit of the Government of Iran. ↩

3. All references in this table to ‘The Government of Iran’ include its public bodies, corporations or agencies, or any person acting on its behalf or at its direction.  ↩