EU sanctions and restrictions are in place for trading with Iran. UK businesses should ensure they are compliant with all sanctions regimes, and should seek independent legal advice as appropriate.

Iran is currently subject to an extensive sanctions regime.

On 14 July 2015, the E3+3 (UK, France, Germany, Russia, China and US) the EU and Iran reached a comprehensive agreement on Iran’s nuclear programme. This concluded over a decade of negotiations between the international community and Iran and when implemented will give confidence in the exclusively peaceful nature of the Iranian civilian nuclear programme. Read the full text of the agreement and annexes.

The UK Foreign Secretary Philip Hammond made an oral statement to Parliament on 15 July on the outcome of the negotiations with Iran. On economic re-engagement with Iran, the Foreign Secretary said:

…This agreement is focused solely on Iran’s nuclear programme, but its conclusion could have wider positive consequences. By providing the means through sanctions relief for Iran’s economic re-engagement with the world, it will allow the Iranian people to feel the tangible benefits of international co-operation. As that economic re-engagement materialises, we will, of course, seek to assist UK businesses to take advantage of the opportunities that will arise. That assistance would, of course, be enhanced through having a functioning British embassy in Tehran. We remain committed to reopening our embassies in each others’ countries and will do so once we have resolved some outstanding issues….

Read the full statement from the Foreign Secretary.

Initially, the nuclear deal will not affect the targeted sanctions relief agreed under the 2013 interim deal Joint Plan of Action (JPoA). Read full details of the JPoA.

Humanitarian goods such as medicine continue to be explicitly exempt from sanctions. Sanctions relief agreed as part of the JCPoA agreed on 14 July 2015 will be phased, and the first phase will only happen once Iran has taken all the agreed actions on its nuclear programme, and the International Atomic Energy Agency (IAEA) has verified that it has done so. This could take several months. But the timetable will be driven by Iran. Once IAEA-verification of Iran’s actions has been completed this will trigger comprehensive economic and financial sanctions relief. Sanctions related to nuclear proliferation will stay in place until the international community has confidence in the peaceful nature of Iran’s nuclear programme (this could take several years or more).

If Iran adheres to its commitments and sanctions are rolled back, then the Government will help the business and financial sector take advantage of the opportunities that arise, and promote trade and investment between our two countries. The commercial decisions of British businesses, including whether or not to trade with Iran, are independent of government. But HMG will work to support those businesses who wish to take advantage of trade opportunities which are not subject to sanctions, as and when they become available. It is important to note that while sanctions remain in place, they will continue to be enforced.

Even as phased sanctions relief begins, Iran will remain a challenging place to do business. Some companies will have concerns about re-engaging in Iran until confidence is rebuilt. But there will be real opportunities too, particularly in some sectors.

We will continue to update this page with additional information as the situation develops.

For more information on doing business with Iran see our FAQs.

Prohibited activities

Sanctions imposed in view of Iran’s nuclear and ballistic missile programmes are set out in full in Council Regulation (EU) 267/2012.

In summary the following activities are prohibited:

  • the sale, supply, transfer or export of the following goods, software and technology:
    • military goods of all kinds
    • dual-use items as listed in Annexes I and II of the Regulation
    • key equipment and technology for the oil and gas industry as listed in Annexes VI and VIA of the Regulation
    • key naval equipment as listed in Annex VIB of the Regulation
    • software for integrating industrial processes as listed in Annex VIIA
    • graphite and raw and semi-finished metals as listed in Annex VIIB
    • newly minted banknotes and coins
  • the provision of technical assistance, brokering services and financial assistance related to the above
  • the import, purchase or transport from Iran of military goods of all kinds, and of dual-use items listed in Annexes I and II of the Regulation
  • the import or purchase of crude oil or petroleum products which are located in or which originated in Iran; and the provision of related financial assistance including insurance and re-insurance
  • the purchase, transport or import of natural gas which is located in Iran or which has been exported from Iran, and the provision of related financial assistance or brokering services
  • the granting of any loan or financial credit to, the acquisition or extension of a participation in, or the creation of a joint venture with, any Iranian entity or person engaged in:
    • the manufacture of military goods or dual-use items listed in Annex I or II of the Regulation
    • the exploration or production of crude oil and natural gas, the refining of fuels or the liquefaction of natural gas
    • the petrochemical industry
    • uranium mining, uranium enrichment and reprocessing of uranium

Sanctions imposed in view of the human rights situation in Iran are set out in Council Regulation (EU) 264/2012.

The following is prohibited:

  • the 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
  • the provision of technical assistance, brokering services and financial assistance related to the above

Activities that require a licence

Council Regulation (EU) 267/2012 states that the following activities require a licence:

  • the sale, supply, transfer or export of dual-use items as listed in Annex III of the Regulation
  • the provision of technical assistance, brokering services and financial assistance related to items listed in Annex III of the Regulation
  • the making of an investment in an Iranian entity engaged in the manufacture of items listed in Annex III of the Regulation

Note that current UK policy is that we will only grant licences for items listed in Annex III in exceptional circumstances.

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:

  • the 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
  • the provision of technical assistance, brokering services and financial assistance related to items listed in Annex IV of the Regulation
  • the 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 the authorisation and notification requirements. 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.

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.

More information

Frequently asked questions can be found here: FAQs

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