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
On 11th December 2023 the EU designated six individuals and five entities allegedly involved in Iran’s development and production of unmanned aerial vehicles (“UAV”) used in the war in Ukraine.
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.
The current sanctions programme is set to expire on 26th July 2024.
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 20th March 2024 OFAC targeted three procurement networks –– based in Iran, Türkiye, Oman, and Germany –– that have supported Iran’s ballistic missile, nuclear, and defense programs. These networks have procured carbon fiber, epoxy resins, and other missile-applicable goods for Iran’s Islamic Revolutionary Guard Corps Aerospace Force Self Sufficiency Jihad Organization (IRGC ASF SSJO), Ministry of Defense and Armed Forces Logistics (MODAFL), other U.S.-designated entities in Iran’s defense industrial base, and Iran Centrifuge Technology Company (TESA), which is linked to the Atomic Energy Organization of Iran (AEOI).
On 4th April 2024, OFAC took additional action against Iranian military revenue generation, targeting Oceanlink Maritime DMCC for facilitating the shipment of Iranian commodities on behalf of Iran’s Armed Forces General Staff (AFGS) and Ministry of Defense and Armed Forces Logistics (MODAFL). OFAC also identified 13 vessels managed by Oceanlink Maritime DMCC as blocked property. The Oceanlink Maritime DMCC-managed vessel HECATE recently loaded Iranian commodities valued at over $100 million dollars via a ship-to-ship (STS) transfer from another sanctioned tanker, the DOVER, on behalf of Iran’s Sepehr Energy Jahan Nama Pars (Sepehr Energy), which OFAC sanctioned in November 2023 for its role selling Iranian commodities for the AFGS and MODAFL. OFAC also updated the Specially Designated Nationals and Blocked Persons List (SDN List) to reflect that the name of OFAC-sanctioned vessel YOUNG YONG (IMO: 9194127) has been changed to the SAINT LIGHT, possibly to obfuscate its identity.
On 18th April 2024, OFAC responded to Iran’s unprecedented attack on Israel on April 13, targeting 16 individuals and two entities enabling Iran’s UAV production, including engine types that power Iran’s Shahed variant UAVs, which were used in the April 13 attack. These actors work on behalf of Iran’s Islamic Revolutionary Guard Corps-Qods Force (IRGC-QF), its UAV production arm, Kimia Part Sivan Company (KIPAS), and other Iranian manufacturers of UAVs and UAV engines. OFAC is also designating five companies in multiple jurisdictions providing component materials for steel production to Iran’s Khuzestan Steel Company (KSC), one of Iran’s largest steel producers, or purchasing KSC’s finished steel products. Iran’s metals sector generates the equivalent of several billion dollars in revenue annually, with the majority coming from steel exports. OFAC also sanctioned three subsidiaries of Iranian automaker Bahman Group, which have continued to materially support the IRGC and other entities designated pursuant to counterterrorism authorities, including Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL). Bahman Group itself is being concurrently designated for owning these entities.
On 25th April 2024, OFAC sanctioned over one dozen entities, individuals, and vessels that have played a central role in facilitating and financing the clandestine sale of Iranian unmanned aerial vehicles (UAVs) for Iran’s Ministry of Defense and Armed Forces Logistics (MODAFL), which itself is involved in supporting Iran’s Islamic Revolutionary Guard Corps (IRGC) and Russia’s war in Ukraine. Sahara Thunder is the main front company that oversees MODAFL’s commercial activities in support of these efforts. Sahara Thunder also plays a key role in Iran’s design, development, manufacture, and sale of thousands of UAVs, many of them ultimately transferred to Russia for use in its war of aggression against Ukraine. OFAC also sanctioned two companies and a vessel involved in the shipment of Iranian commodities for Sepehr Energy Jahan Nama Pars, which similarly plays a leading role in the commercial activities of Iran’s Armed Forces General Staff (AFGS). Concurrent with this action, the United Kingdom and Canada are imposing sanctions targeting several entities and individuals involved in Iran’s UAV procurement and other military-related activities.
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.
On 14th December 2023 OFAC and the UK took joint action against Iran’s Islamic Revolutioonary Guard Corps – Qods Force (“IRGC-QF”), Hamas, and Palestinian Islamic Jihad (“PIJ”). The UK designated eight individuals, including the head of the IRGC-QF and individuals linked to Iran’s support for Hamas and PIJ, whilst OFAC designated an IRGC-QF official involved in support to Hamas.
On 29th January 2024 OFSI and OFAC took joint action against a network of individuals that targeted Iranian dissidents and opposition activists for assassination at the direction of the Iranian regime. The network is led by Iranian narcotics trafficker Naji Ibrahim Sharifi-Zindashti and operates at the behest of Iran’s Ministry of Intelligence and Security (“MOIS”)
On 27th February 2024 OFSI and OFAC took joint action against the IRGC-QF, Mohammad Reza Falahzadeh, as well as a Houthi group member.
On 18th April 2024, OFSI and OFAC took joint action against seven individuals and six entities enabling Iran’s UAV production.
On 25th April 2024, OFSI and OFAC took joint action against two further individuals and four entities involved in Iran’s UAV procurement and other military-related activities.
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.
