Notice to Exporters: 2016/05: EU ends economic and financial nuclear-related sanctions against Iran

January 18, 2016

On 16 January  2016, the International Atomic Energy Agency (IAEA) confirmed to the UN Security Council that Iran has taken all measures  laid out in the Joint Comprehensive Plan of Action (JCPOA), agreed by E3 + 3 (UK, France Germany, US, Russia and China) and Islamic Republic of Iran, to ensure that Iran’s nuclear programme is entirely peaceful in nature. This date is commonly known as Implementation Day. Consequently, all EU economic and financial sanctions made in connection with the Iranian nuclear programme have been lifted.

Read the Foreign Secretary’s statement on the implementation of the nuclear deal.

US nuclear-related financial and economic secondary financial and economic sanctions are also suspended.

This means that the following range of activities and associated services are now permitted as of Implementation Day:

i) Financial, banking and insurance measures

  • Transfers of funds between EU persons, entities or bodies, including EU financial and credit institutions, and non-listed Iranian persons, entities or bodies including Iranian financial and credit institutions.
  • The opening of branches, subsidiaries or representative offices of non-listed Iranian banks in Member States.
  • Provision of export credit, guarantees or insurance and other financial support.

Post Implementation day, UK Export Finance (UKEF) will reintroduce cover for Iran in Pounds Sterling and Euros. Read further details.

ii) Oil, gas and petrochemical sectors

  • Import, purchase, swap and transport of crude oil and petroleum products from Iran.
  • Export (by EU persons) of oil, gas and petrochemical  equipment or technology; provision of related technical assistance including training to any Iranian person, in or outside Iran, or for use in Iran.
  • Investment in Iranian sectors of oil, gas, and petrochemicals.

iii) Shipping, shipbuilding and transport sectors

  • Sale, supply transfer or export of naval equipment and technology for ship building, maintenance or refit to Iran or to any Iranian person engaged in the sector.
  • Design construction – or participation in the design and construction – of cargo vessels and oil tankers for Iran or Iranian persons.
  • Provision of vessels; designed or used for the transport or storage of oil and petrochemical products to Iranian persons entities or bodies.
  • Provision of flagging and classification services.
  • Cargo flights operated by Iranian carriers or originating from Iran have access to EU Members States airport.
  • Cargos to and from Iran of previously prohibited items will no longer be subject to inspection seizure and disposal by EU Member States.

iv) Sale, supply, purchase, transfer, export or transfer of gold, other precious metals and diamonds to/from or for the Government of Iran, its public bodies, corporations and agencies or the Central Bank of Iran.

  • Provision of related brokering, finance and security services.
  • Delivery of newly printed or minted banknotes and coinage for the Central Bank of Iran.

The following items are no longer prohibited from sale, supply, transfer or export to any Iranian person entity or body or for use in Iran, but subject to a UK export licence as of Implementation Day:

  • Nuclear-related goods and technology as specified on the Nuclear Suppliers Group (NSG)Trigger List and NSG Dual-Use List and listed in Annex I of Council Regulation (EU) 267/2012. The UK must seek approval from the UN Security Council through the ‘Procurement Channel’ before granting a licence for these items. The Export Control Organisation will issue guidance on the Procurement Channel in due course.
  • Nuclear-related goods and technology as listed in Annex II of Council Regulation (EU) 267/2012.
  • Metals: certain graphite and raw or semi-finished metals.
  • Enterprise Resource Planning software, including updates.
  • Provision of technical assistance, brokering services, or financial assistance related to any of the above.

As of Implementation Day, certain persons and entities are delisted from UN listings and EU autonomous listings. Consequently, these persons are no longer subject to an asset freeze, or the prohibition to make funds available and visa ban.

Read an EU information note with more detail on permitted activities.

In the event of Iran not meeting the ongoing commitments of the JCPOA, the EU will reintroduce sanctions (‘EU snapback’). However, all parties in the JCPOA process have committed to ensuring that the JCPOA is successfully implemented.

Measures and sanctions which are outside the scope of JCPOA and will remain in place post Implementation Day:

  • The EU Arms embargo and missile technology sanctions and restrictions will remain in place until Transition Day (18 October 2023), as well as continuing restrictive measures on certain individuals.
  • Sanctions imposed by the EU in view of the human rights situation in Iran, support for terrorism and other grounds, will remain in place.
  • Iranian persons listed under EU terrorism and Syria sanctions regimes or any other EU sanctions regime will continue to be subject to restrictive measures under these regimes.
  • 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).

Prior Authorisation by the Export Control Organisation, including the Procurement Channel:

  • As of Implementation Day, proliferation-related restrictions including nuclear transfers and activities and associated services are subject to prior authorisation. The list of goods and technologies subject to prior authorisation are in Annex I and Annex II of Council Regulation 267/2012 (as amended).

UK National Controls on Iran (applying to civil aerospace and marine, for example) also remain in place.