Following the issue of the news release of 18 January regarding the lifting of some of the sanctions measures in force in respect of Iran, the Treasury wishes to make the following additional advice available.
The implementation of the amendments made by the European Union (Iran Sanctions) (Proliferation) (Amendment) (No. 3) Order 2015 means that as certain financial sanctions measures have been removed –
- 34 individuals and 298 entities are no longer subject to an asset freeze or a prohibition on making economic resources available to them;
- the restrictions on financial transfers to and from non-listed Iranian entities have been removed, and there is therefore no requirement to submit prior notification, or obtain prior authorisation, for such transfers. As a consequence, the Supplement to Sanctions Notice 24 has been withdrawn;
- banking activities (such as the establishment of new correspondent banking relationships with Iranian banks, and the opening of branches, subsidiaries or representative offices of Iranian banks) are permitted;
- the provision of insurance and reinsurance services to non-listed Iranian entities is permitted;
- the supply of specialised financial messaging services (such as SWIFT) is permitted for non-listed Iranian financial institutions;
- transactions in public or public-guaranteed bonds with Iranian non-listed entities are permitted.
In addition, certain non-financial sanctions measures have been lifted allowing –
- the import, purchase, swap and transport of crude oil and petroleum products from Iran;
- the export by Island persons of oil, gas and petrochemical equipment or technology, and the provision of related technical assistance (including training to any Iranian person) inside or outside Iran, or for use in Iran;
- investment in Iranian oil, gas and petrochemicals sectors;
- the sale, supply, transfer or export of naval equipment and technology for shipbuilding, maintenance or refit to Iran or any Iranian person engaged in the sector;
- design construction, or participation in the design and construction, of sea cargo vessels and oil tankers for Iran or Iranian persons;
- the provision of sea vessels, designed or used for the transport or storage of oil or petrochemical products, to Iranian persons, entities or bodies;
- the provision of flagging and classification services for sea vessels;
- cargo flights operated by Iranian operators or originating in Iran access to EU airports;
- cargo to and from Iran of previously prohibited items being no longer subject to inspection, seizure and disposal by customs authorities in the EU;
- the sale, supply, purchase, transfer or export of gold, other precious metals and diamonds to or from or for the Government of Iran, its public bodies, corporations and agencies, or the Central Bank of Iran;
- the provision of brokering, finance and security services;
- the delivery of newly-printed or minted banknotes and coinage for the Central Bank of Iran.
As notified in the news release of 18 January, certain goods, whilst no longer prohibited from sale, supply, transfer or export to Iran or any Iranian entity or body, or for use in Iran, remain subject to the requirement for an export licence. These include –
- certain nuclear-related goods and technology listed in Annex I to Council Regulation (EU) No 267/2012;
- nuclear-related goods and technology listed in Annex II of that Regulation;
- certain graphite and raw and semi-finished metals;
- Enterprise Resource Planning software, including updates;
- the provision of technical assistance, brokering services or financial assistance related to any of the above.
These specific controls are in addition to the normal export and trade control licensing requirements – see Notice 279 MAN and Notice 279T MAN. In particular, goods and technology that could contribute to the development of nuclear weapon delivery systems or other WMD, or items on the EU Common Military List, remain subject to tight controls.
More information may be found in an information note on EU sanctions to be lifted under the Joint Comprehensive Plan of Action (JCOA) which has been published by the European Commission.
There has been no change to those sanctions imposed in respect of Iran on human rights grounds, and therefore these remain in force. These include the listing of certain individuals and entities, as well as restrictions on the supply of certain equipment and technology that could be used for internal repression or the monitoring or interceptions of telecommunications.
Whilst US secondary legislation imposing nuclear-related sanctions has also been suspended, some US-imposed sanctions remain in force, with additional measures put in place and affecting 11 individuals and entities connected to Iran’s ballistic missile programme with effect from 17 January. Guidance on the effect of the lifting of US sanctions under the JCPOA may be found on the website of the Office of Foreign Assets Control. You should note that, as a general rule, US persons and companies remain prohibited from engaging in transactions with Iran or the Iranian government and Iranian financial institutions.
You should check the amended Consolidated List of Iranian individuals and entities for those that remain subject to financial sanctions.
Sanctions Notice 24 has been amended to reflect the changes detailed above.
For more information contact Customs and Excise
