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Merry Olde Iranian Sanctions updated

Two releases today from across the pond:

On the heels of last week’s updates to EU regulations based on UN updates to the Iranian program, the first notice from Her Majesty’s Treasury has updated their list of sanctioned entities. One individual and 18 entities were added, 2 were removed and 3 were amended.

Wouldn’t it be nice if all the regulators could coordinate this stuff, so regulated firms could update their lists once?

The second notice from Her Majesty’s Treasury delineates the changes to what is permitted and prohibited due to the changes in the EU Iran sanctions program. These are:

  • Funds transfers with any branch (regardless of location) of financial or credit institutions, or bureaux de change, or their subsidiaries or branches, if domiciled in Iran or controlled by people or entities domiciled in Iran, are prohibited
    • Transfers that are part of a larger end-to-end transaction that would be prohibited if it were a single transfer, are prohinited
    • An aggregated set of transfers which, individually, fall under the amount threshold set out elsewhere in the regulations, but are above that threshold when aggregated, are prohibited
  • Under specific circumstances (e.g. depending on amount, written authorization may be required), the following transfers above 10,000 EUR may be permitted
    • Transfers of foodstuffs, healthcare or medical equipment, or for agricultural or humanitarian purposes
    • Personal remittances
    • Certain transfers in fulfillment of trade contracts
    • Transfers for diplomatic or consular posts, or for international organizations with immunity
    • Transfers to settle claims by or against Iranian persons or entities
    • Transfers necessary for obligations under certain contracts
  • Transfers of up to 10,000 EUR do not require prior authorization
  • Frozen assets of the Central Bank of Iran may be released for trade finance purposes, and to settle claims by Iranian people or entities

Note: for brevity, these changes are heavily edited and, as such, may be misleading in the form above. Before proceeding to authorize or block any transaction, please see the source documents issued by the regulator.


Her Majesty’s Treasury Press release – changes in names under Iranian (nuclear proliferation) sanctions
European Union Council Implementing Regulation
European Union Council Iran regulations
Her Majesty’s Treasury Iran (nuclear proliferation) sanctions page

Her Majesty’s Treasury Press release – functional changes to Iran (nuclear proliferation) program
Corresponding EU Regulation 1263/2012 – from HMT website

Categories: EU Updates OFSI Updates UN Updates


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