Sanctions have been imposed against Iran by the US since the 1970s, designating the country an international sponsor of terrorism. Since 2011 the EU and US have also imposed programmes targeting individuals involved in political repression in the country and, alongside the UN, its alleged nuclear weapons programme. The UN and EU have relaxed nuclear-related sanctions against Iran under the Joint Collective Plan of Action (“JCPOA”) since 2015. The US, formerly a participant in the JCPOA, has renounced the programme and re-imposed wide-ranging sanctions and trade restrictions against Iran in 2018.
Sanction Name
UN Sanctions for Iran
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Trade Restrictions:
• Ban on testing or launching missiles capable of carrying a nuclear warhead.
Exemptions
1. Trade (including arms) and technical assistance are permitted on a case-by-case basis provided the UN Security Council has decided in advance to permit such an activity.
Links 1
Sanction Name
Restrictive Measures Against Certain Entities In View Of The Situation In Iran
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze:
• Persons complicit in or responsible for directing human rights violations in the repression of peaceful demonstrators and other civil society actors during the widespread anti-government protests in 2011 or responsible for human rights abuses linked to this repression.
• Individuals and organisations complicit in or responsible for directing human rights violations following the death of Mahsa Amini and the violent response by Iranian security forces to consequent protests.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support the attendance of inter-governmental meetings.
Sanction Name
Restrictive Measures Against Iran And Repealing Regulation
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Trade Restrictions:
• Ban on testing or launching missiles capable of carrying a nuclear warhead.
• Persons and entities involved in nuclear or ballistic missile activities and persons and entities providing support to the Iranian Government in this area.
Exemptions
1. An arms embargo is in force related to nuclear activities and missile technology.
2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.
On 15th July 2024, the EU announced it would extend its Iran sanctions measures until 27th July 2025.
Sanction Name
Restrictive measures in view of Iran’s military support of Russia’s war of aggression against Ukraine
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Travel Ban:
• Persons and entities responsible for, or involved in, Iran’s UAV programme. EU persons and entities are also forbidden from making funds available to those listed.
Trade Restrictions:
• Ban on the export of components used in the manufacturing of UAVs.
Exemptions
1. Exemptions can be granted on a case-by-case basis for the delivery of humanitarian aid.
Sanction Name
Regulation on Sanctions Against Iran
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze and Trade Restrictions:
• Entities involved in nuclear or ballistic missile activities. This programme includes extensive restrictions on trade with Iran, including the provision of arms, dual use goods and other commodities such as diamonds, as well as the provision of services to certain strategic sectors, including the oil and gas sector. There are also prohibitions on the provision of goods, technology and software for launch systems and services, defence equipment and goods that could be used for internal repression, and on equipment and technology relating to inspection software and corresponding services.
Arms Embargo:
• A complete arms embargo is in place as well as an authorisation requirement for nuclear goods. There is also an authorisation requirement for the establishment of joint ventures with Iranian entities involved in the nuclear programme.
Exemptions
1. There are arms embargo exemptions relating to armoured vehicles and other equipment necessary to protect Swiss diplomatic and consular staff in Iran. Exemptions can also be granted for non-lethal military equipment for humanitarian and protective purposes as well as for hunting and sporting weapons.
2. Asset freeze exemptions may be granted to prevent cases of rigor; respect existing contracts; respect credits due under existing judicial, administrative or arbitral judgments; for Iranian diplomatic missions or consular posts; for the implementation of the JCPOA; or to protect Swiss interests.
On 18th September 2024, OFAC designated 12 individuals in connection with the Iranian regime’s ongoing repression of the Iranian people, both within Iran’s borders and abroad. These designations target members of the Islamic Revolutionary Guard Corps (IRGC), officials of Iran’s Prisons Organization, and those responsible for lethal operations overseas.
On 11th October 2024, in response to Iran’s attacks on Israel on 1st October, the US Treasury and Department of State expanded its sanctions on the Iranian petroleum and petrochemical sectors, and now may impose sanctions on any individual or entity deemed to operate in them. Accordingly OFAC then designated 10 entities and 17 vessels for their involvement in shipments of Iranian petroleum and petrochemical products.
Sanction Name
OFAC Sanctions Against Iran
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National and Arms Embargo:
• The Government of Iran and Iranian state-controlled entities, including but not limited to the National Iranian Oil Company, the Naftiran Intertrade Company and the Central Bank of Iran, as well as any entity owned or controlled by, or operating on behalf of these entities. The Supreme Leader of Iran and other state officials appointed by the Supreme Leader are also personally subject to sanctions.
• There is also a prohibition on the provision of financial assistance or technological support for the acquisition of US dollar banknotes by the Government of Iran; Iran’s trade in gold or precious metals; the direct or indirect sale, supply or transfer to or from Iran of graphite or raw or semi-finished metals for integrating industrial processes; significant transactions related to the purchase or sale of Iranian Rials, or the maintenance of significant funds or accounts outside of Iran denominated in Rials; the purchase, subscription to, or facilitation of the issuance of Iranian sovereign debt; and Iran’s automotive sector.
• On 27th September 2022 OFAC designated Iran’s Morality Police and seven senior leaders of Iran’s security organisations following the death of Mahsa Amini in custody after she was detained for allegedly wearing a hijab incorrectly. In October OFAC designated three entities and 21 people, including seven senior leaders within Iran’s government and security apparatus for the shutdown of Iran’s internet access and the continued violence against peaceful protestors in the wake of the death of Mahsa Amini.
Trade Restrictions:
• There are extensive trade prohibitions, including a general ban on imports from Iran and on the direct or indirect export of goods, technology and services to the country. There are also sanctions on individuals and entities active in the iron, steel, aluminium and copper sectors along with trade restrictions on these goods. In addition, certain Iranian government organisations or government-controlled organisations remain sanctioned. Certain US state legislatures also retain their own official embargoes or sanctions programmes against certain Iranian entities.
Exemptions
1. General Licences authorise the following: the re-exportation of certain civil aircraft on a temporary sojourn by a non-US person and related transactions; certain education services, certain services in support of sporting activities involving the US and Iran; certain services in support of NGO activities in Iran; certain services; software and hardware involved in personal communications; certain medical devices and the export or re-export of replacement parts for such devices; the export or re-export of food items; transactions related to consular funds transfers and the transportation of human remains; the export of certain services and software over the internet; and transactions involving Iran performed by US citizens employed by six international organisations. There are also exemptions for online educational courses and educational software.
2. There are also certain exemptions for the Iranian oil sector. Authorisations have been granted for the construction of a gas pipeline between Azerbaijan and Turkey; projects which provide Turkey and Europe energy security and independence from Russia and Iran; and production sharing contracts with governments of countries other than Iran agreed before August 2012.
3. On 24th August 2021 OFAC issued General Licence M-1, authorizing the export to Iran of certain graduate level educational services and software.
4. On 23rd September 2022, OFAC issued General License D-2, concerning the authorisation of software and hardware services used for communications. This measure was a response to the Iranian government interrupting internet access to prevent streaming of crackdowns on protests in the wake of the death of Mahsa Amini.
Links 1
Sanction Name
CAATSA Sanctions Against Iran
SANCTIONS
First Imposed
Last updated
Targets
Specially Designated National:
• CAATSA has imposed additional sanctions against officials, agents, or affiliates of Iran’s Islamic Revolutionary Guard Corps, although these designations have been included under the Counter Terrorism sanctions programme.
Exemptions
1. General Licences authorise the following: the re-exportation of certain civil aircraft on a temporary sojourn by a non-US person and related transactions; certain education services, certain services in support of sporting activities involving the US and Iran; certain services in support of NGO activities in Iran; certain services; software and hardware involved in personal communications; certain medical devices and the export or re-export of replacement parts for such devices; the export or re-export of food items; transactions related to consular funds transfers and the transportation of human remains; the export of certain services and software over the internet; and transactions involving Iran performed by US citizens employed by six international organisations.
2. There are also certain exemptions for the Iranian oil sector. Authorisations have been granted for the construction of a gas pipeline between Azerbaijan and Turkey; that which provides Turkey and Europe energy security and independence from Russia and Iran; and production sharing contracts with governments of countries other than Iran agreed before August 2012.
On 14th December 2023 OFSI published the Iran Sanctions Regulations, revoking and replacing the Iran Sanctions (Human Rights) Regulations 2019. Persons previously designated under the Iran (Human Rights) regime are now designated under the Iran regime.
Sanction Name
UK sanctions relating to Iran
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze:
• Persons complicit in or responsible for directing human rights violations in the repression of peaceful demonstrators and other civil society actors during the widespread anti-government protests in 2011 or responsible for human rights abuses linked to this repression.
• Persons or entities involved in the Iranian regime’s activities undermining peace, stability and security in the Middle East and internationally; the use and spread of weapons or weapons technologies from Iran; the Iranian undermining of democracy, respect for the rule of law and good governance; and other hostile activities towards the UK and its allies from the Iranian regime, including threats to its people, property or security.
Exemptions
1. Exemptions can be granted on a case-by-case basis on humanitarian grounds or to support attendance of inter-governmental meetings.
Sanction Name
UK sanctions relating to Iran (nuclear weapons)
SANCTIONS
First Imposed
Last updated
Targets
Asset Freeze, Arms Embargo and Trade Restrictions:
• Ban on testing or launching missiles capable of carrying a nuclear warhead.
• Persons and entities involved in nuclear or ballistic missile activities and persons and entities providing support to the Iranian Government in this area.
Exemptions
1. As UN above, with an arms embargo relating to nuclear activity and missile technology.
2. Asset freeze exemptions are also permitted for basic expenses, the provision of legal and professional services, fees for the holding of frozen funds and for the satisfaction of judicial, administrative or arbitral liens or judgments.
