On 8 January 2019, the Council of the European Union (EU) adopted Decision (CFSP) 2019/25 amending and updating the list of persons, groups and entities subject to Articles 2, 3 and 4 of Common Position 2001/931/CFSP, adding two Iranian individuals, Assadollah Asadi and Saeid Hashemi Moghadam, and the Directorate for Internal Security of the Iranian Ministry for Intelligence and Security to the EU terrorist list.

According to the Council's press release, the designations are marked as a "response to recent foiled attacks on the European soil". They follow earlier allegations from Denmark, France, and the Netherlands that Iran has been involved in assassination plots in their respective countries.

By including the Iranian nationals on the EU terrorist list, they are made subject to the freezing of their funds and other financial assets, as well as enhanced measures related to police and judicial cooperation in criminal matters. In addition, it is also prohibited for EU persons to make funds and economic resources available to them, directly or indirectly.

It is worth noting that the EU has decided to include the Iranian persons on the EU terrorist list rather than adopting new sanctions regulations against Iran. This underscores the EU's difficult balancing act in trying to respond firmly to suspected actions by Iran on the one hand, while preserving the Iran nuclear deal (JCPOA), out of which the U.S. withdrew last year, on the other hand.

Our global sanctions team, including dedicated experts located in Brussels, London, Milan, Vienna and Washington DC, advises a wide range of European and other international clients on implementation of - and compliance with - sanctions targeting Russia, Crimea and Sevastopol as well as other sanctions regimes (including e.g. Iran, Syria, Lebanon, Sudan, Libya).