Business and enterprise – guidance

Embargoes and sanctions on Iran

Iran has received extensive economic and financial sanctions relief as a result of meeting its obligations under the nuclear deal agreed on 14 July 2015.

The UK government fully supports expanding our trade relationship with Iran and encourages UK businesses to take advantage of the commercial opportunities that will arise. Department for International Trade (DIT) is in Tehran to support bilateral trade and investment. However, some sanctions remain in place so UK businesses should continue to ensure they are compliant with all sanctions regimes.

On 14 July 2015, the E3+3 (UK, France, Germany, Russia, China and USA) the EU and Iran reached a comprehensive agreement on Iran’s nuclear programme. This concluded over a decade of negotiations between the international community and Iran. Through the successful implementation of this deal, Iran can demonstrate its commitment to an exclusively peaceful nuclear programme. Most financial and economic sanctions against Iran have now been lifted, following the International Atomic Energy Agency’s verification that Iran had completed all necessary steps to reach Implementation Day (16 January 2016). Read the full text of the agreement and annexes.

Marking Implementation Day on 16 January 2016, UK Foreign Secretary Philip Hammond said:

The nuclear deal with Iran, in which Britain played a major role, makes the Middle East and the wider world a safer place. Years of patient and persistent diplomacy, and difficult technical work, have borne fruit as we now implement the deal.

There were many sceptics who said Iran would never deliver on its side of the bargain, but the independent IAEA have said they have. Tonnes of uranium have been shipped out of Iran, thousands of centrifuges have been taken out of use and the core has been removed from the Arak reactor. Iran’s nuclear programme has been substantially rolled back, in return for the lifting of sanctions and the economic benefits that will bring.

The UK has played a central role, and I hope British businesses seize the opportunities available to them through the phased lifting of sanctions on Iran. The future is as important as the landmark we’ve reached today.

The UK government fully supports expanding our trade relationship with Iran. Iran has now received extensive economic and financial sanctions relief and will be able to trade more freely with the rest of the world. We want to help British businesses take advantage of the opportunities that economic re-engagement with Iran will bring.

UK Export Finance (UKEF), the UK’s export credit agency, has reintroduced cover in to support UK companies competing for business in Iran. Cover is now available on a case-by-case basis in Pounds Sterling and Euros. Within this, and in recognition of the UK’s place as a global centre of excellence for financial and professional services, UKEF will make available an initial £50 million facility guaranteeing payments to UK professional advisory service providers advising the Government of Iran. UKEF will also consider applications for direct lending from purchasers of British exports to Iran. Find out more about UKEF’s cover for Iran here.

DIT will be engaging with UK businesses to provide support and assistance to help ensure UK business benefits from opportunities as they arise. UKTI based both in the UK and in the British Embassy in Tehran will play an important role in supporting trade and investment between our 2 countries.

Although most economic and financial sanctions have now been lifted, some sanctions will remain in place and are not affected by the deal. In particular sanctions related to human rights, proliferation and Iran’s support for terrorism remain in place. You will wish to consider in particular, if you are dealing with a designated person or entity, whether a certain trade product or material is restricted, and how and to whom payments will be made. UK companies will also want to consider whether their proposed activity is subject to US sanctions. It is important to ensure appropriate due diligence measures are undertaken before engaging in any activity. Iran will remain a difficult place to do business so if in doubt you should seek legal advice.

More information on doing business with Iran

Prohibited activities

The following activities remain banned under the proliferation-related sanctions:

  • sale, supply, transfer or export to Iran, of all military goods and technology as listed in the UK Military List
  • sale, supply, transfer or export of missile-related goods and technology as listed in Annex III of Council Regulation (EU) 267/2012
  • provision of technical assistance, brokering services and financial assistance related to the above
  • import from Iran of military and missile-related goods and technology
  • investment in Iranian enterprises engaged in manufacture of military goods, and a ban on investment by an Iranian person in a commercial activity related to production or use of missile-related goods

The following is prohibited under the sanctions imposed in view of the human rights situation in Iran as set out in Council Regulation (EU) 264/2012: * sale, supply, transfer or export of equipment which might be used for internal repression as listed in Annex III of Council Regulation (EU) 264/2012 * provision of technical assistance, brokering services and financial assistance related to the above

In addition, restrictive measures remain in place against individuals and entities who remain listed in Council Regulation 267/2012 and in Council Regulation 264/2012, as well as under EU terrorism and other EU sanctions regimes.

UK businesses should ensure they are compliant with all remaining sanctions regimes. It is important to conduct due diligence and ensure compliance with sanctions regimes before signing business contracts, as with any market.

Activities that require a licence

The following activities require a licence under the proliferation-related sanctions:

  • sale, supply, transfer or export of nuclear-related items as listed in Annex I of the Regulation
  • provision of technical assistance, brokering services and financial assistance related to items listed in Annex I of the Regulation
  • investment by an Iranian person, entity or body in a commercial activity related to uranium mining or the manufacture of items listed in Annex I of the Regulation

These nuclear-related activities can only be authorised if they have been approved in advance by the UN Security Council through the newly-established Procurement Channel. UK persons wishing to supply these goods or services to Iran, or to accept an investment by an Iranian person, must seek a licence from the Export Control Organisation (ECO) in the Department of DIT. The ECO will consider the application and where appropriate seek the required authorisation from the UN. The ECO has published detailed guidance on the Procurement Channel.

A licence is also required for:

  • sale, supply, transfer or export of nuclear-related items as listed in Annex II of the Regulation
  • provision of technical assistance, brokering services and financial assistance related to items listed in Annex II of the Regulation
  • investment by an Iranian person, entity or body in a commercial activity related to the items listed in Annex II of the Regulation

These items are not subject to the Procurement Channel process.

Sanctions imposed in view of the human rights situation in Iran are set out in Council Regulation (EU) 264/2012. The following requires a licence:

  • sale, supply, transfer or export of equipment which might be used for the monitoring or interception of internet or telephone communications as listed in Annex IV of the Regulation
  • provision of technical assistance, brokering services and financial assistance related to items listed in Annex IV of the Regulation
  • provision of telecommunication or internet monitoring or interception services of any kind to, or for the direct or indirect benefit of, Iran’s government, public bodies, corporations and agencies or any person or entity acting on their behalf or at their direction

Financial sanctions may still be relevant to your transaction, including interaction with those persons and entities that remain designated. It is your responsibility to ensure you comply with financial sanctions. For more information see the HM Treasury guidance relating to nuclear proliferation and human rights violations and please refer to the Treasury’s consolidated list which includes all Iranian individuals and entities listed under EU and UK sanctions regimes (including those listed for Counter Terrorism purposes or under the Syria regime).

End-use controls

If your items are not listed specifically as a result of specific sanctions regulations, you may still need a licence under so-called ‘end-use controls’. This aspect of export controls covers licensing of items that might potentially be used in a Weapons of Mass Destruction (WMD) programme or military goods.

These controls are outlined in Article 4 of Council Regulation 428/2009 (the EU Dual-Use Regulation) and in the Export Control Order 2008.

For more information on end-use controls, see the guide on WMD End-Use Control and Military End-Use Control.

The Iran List provides a listing of organisations in Iran of potential concern.

If you have any concerns about exporting to an end-user in Iran, you should consider seeking advice from the ECO End-User Advice Service.

Apply for an export licence to Iran

Many of the restrictions against Iran are prohibitions. That means that there is a complete ban on supply to Iran. Licences will not normally be issued where there is a prohibition in place.

Exporters can apply for an export licence for their goods or for other transactions subject to control.

The government will consider all applications on a case-by-case basis in line with the provisions of the Consolidated EU and National Arms Export Licensing Criteria.

Read the guide on Assessment of export licence applications: criteria and policy.

Apply for an export licence using SPIRE.

BIS ECO helpline

For general export control queries please contact the ECO Helpline on 020 7215 4594 or email: eco.help@bis.gsi.gov.uk