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UK (and EU) restrictions on Iranian nuclear program

The EU's Council Decision 2012/635/CFSP (codified into law by Council Regulation (EU) No 267/2012) adopted sanctions against Iran's weapons programs (nuclear and ballistic) and any revenue they get fron these. These include:

    • prohibition on the sale, supply or transfer to Iran of graphite, raw or semi-finished metals (such as aluminium or steel) and software for integrating industrial processes. The prohibition includes technical or financial assistance.
    • prohibtion on sale or supply of key naval equipment and technology for ship-building, maintence or refit..

Annexes I and II of the Regulation list items which regulated EU persons and enitities (EU citizenship or location within the EU) cannot be involved with the:

  1. sale, supply, transfer or export to Iran or to an Iranian entity or body outside Iran of listed dual-use goods and technology
  2. provision of brokering services, and the provision of technical and financial assistance, related to the listed goods and technology
  3. purchase, import or transport from Iran of listed items
  4. investment in and financing of any Iranian person, entity or body engaged in the manufacture of listed items

Annex I is the EU's Dual-Use List, while Annex II are additional dual-use goods which would provide significant assistance to Iran's nuclear and ballistic programs.

Annex III is similar to Annex II, but which are potentially licensable:

  1. A licence is required for the sale, supply, transfer or export to Iran or to an Iranian entity or body outside Iran of goods and technology listed in Annex IV
  2. A licence is required for the provison of brokering services, of technical or financial assistance related to those items, or for investment in Iranian entities engaged in manufacturing those items

Licenses are only issuable in exceptional circumstances – such as on humanitarian grounds – when there is no risk of the goods ending up in Iran's nuclear program.

Notice to Exporters 2010/40 discusses changes to the licensing policy for Annex III (formerly called Annex IV) items.

Annex IV items are specific to the ban on purchase, import or transport to the EU of Iran's crude oil or petrochemical products.

Annex V contains petrochemical products that cannot be imported to the EU if they are Iran-origin or are exported from Iran.

Annex VI lists equipment key to Iran's production of oil, natural gas and petrochemicals, including exploration and production (e.g. drilling) equioment, and refining (oil) or liquefaction (natural gas) equipment. EU members may not supply or export these to Iran.

Annex VII is a listing of gold, precious metals and diamonds, none of which can be supplied or sold to Iran.

Council Regulation (EU) 267/2012 also prohibits the “sale, supply, transfer or export, directly or indirectly of newly printed or unissued Iranian denominated banknotes and minted coinage, to, or for the benefit of the Central Bank of Iran.”

Additionally, “Goods whose supply is prohibited for human rights reasons (including equipment and technology which may be used for the monitoring or interception of the internet and telecommunications and related services) are listed in Council Regulation (EU) No 359/2011.”


Council Decision 2012/635/CFSP

Council Regulation (EU) No 267/2012

Dual-use goods controls guide

UK Strategic Export Control Lists


Categories: EU Updates Export Control Iranian Sanctions OFSI Updates Sanctions Programs


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