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Sanctions Legislation and Guidance: Iran

Thursday, 14 December 2023

The Treasury advises that the Iran (Sanctions) (Isle of Man) Order 2023 [SI 2023/1376] comes into operation today, which extends the provisions of the following United Kingdom statutory instrument relating to Iran financial and trade sanctions to the Island:

  • The Iran (Sanctions) Regulations 2023 (‘Iran Regulations')

The Iran Regulations establish a sanctions regime in relation to Iran for the purpose of encouraging the Government of Iran to comply with international human rights law and to respect human rights and to deter Iran from conducting hostile activity against the United Kingdom and other countries.

It is the policy of the Isle of Man Government to maintain the implementation of international sanctions measures in the Isle of Man in line with such measures as have effect in the United Kingdom from time to time. The Isle of Man has adopted these measures to ensure that sanctions against Iran in the Island are aligned with the United Kingdom.

The Iran (Sanctions) (Human Rights) (EU Exit) Regulations 2019 no longer have effect.

The effects of the Iran Regulations, as extended to the Island, are:

  • The imposition of asset freezes on funds and economic resources of designated persons (meaning that those assets cannot be dealt with (e.g. transferred, sold or otherwise), and doing so would be an offence)

  • Travel bans on designated persons, refusing entry to the Island or UK

  • Trade restrictions on exporting specified goods and technology (and related services) which may be used to repress the civilian population of Iran or used for interception and monitoring services in Iran

  • The prohibition of ships, owned, controlled, chartered or operated by a designated person, or a specified ship from entering ports in the Isle of Man

  • Prohibiting the registration of such ships on the Isle of Man Ship Register

The Treasury advises that the Iran Sanctions guidance has also been reissued to include these new regulations and is available to read here and on the Sanctions and Export Control page of the Customs and Excise website.  The guidance is produced by the Customs and Excise Division, part of the Treasury, which is the authority for the implementation of financial sanctions in the Isle of Man.

It outlines your obligations under the Iran sanctions as well as Treasury’s approach to licensing and compliance issues. It takes into account relevant case law and guidance at the date of publication.

This guidance does not represent legal advice. If you are unsure about your obligations in a given case, you should consider taking independent legal advice.

Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.

Further details of the sanctions regime related to Iran and links to other financial sanctions regimes may be found on the Customs and Excise pages of the Isle of Man Government website.

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