Council Regulation number 961/2010 (the Regulation) on restrictive measures on Iran has come into force. The Regulation replaces and repeals EC Regulation 423/2007; it replicates the asset freezing measures that were contained in Regulation 423/2007 and implements additional restrictive measures against Iran. Key changes have been implemented in the following areas:  

export and import restrictions

  • the list of prohibited goods and technologies includes dual use items or technology (except for goods in category 5 of Annex I)
  • authorisation will not be granted (unless exceptional conditions are satisfied) if the competent authorities have reasonable grounds to determine that the transfer would contribute to (a) Iran's enrichment-related, repossessing or heavy-water related activities (b) the development of nuclear weapon delivery systems by Iran or (c) the pursuit by Iran of activities related to or other topics about which the IAEA has expressed concerns or has identified as outstanding
  • it is prohibited to sell, supply, transfer, export or provide financial or technical assistance in relation to "key equipment or technology", which includes equipment and technology for key sectors of the oil and gas industry in Iran

financing of certain enterprises

  • it is prohibited to grant any financial loan or credit to any Iranian person, entity or body engaged in certain activities, or investing in those activities, including the exploration or production of crude oil and natural gas or nuclear related activities (unless specific conditions are satisfied)

freezing of funds and economic resources

  • the lists of designated entities and persons and the provision requiring funds and economic resources to be frozen has been amended to refer expressly to natural and legal persons, entities and bodies who have been identified as "being a senior member of the Islamic Revolutionary Guard Corps or a legal person, entity or body owned or controlled by the Islamic Revolutionary Guard Corps or by one of more of its senior members"

restrictions on transfers of funds and financial services

  • requirement to seek authorisation (from the Treasury in the case of the UK) for all transfers of funds to and from Iranian persons or entities (wherever they are based) that exceed €40,000 (smaller transfers are subject to notification requirements) (exceptions for humanitarian payments, but in certain cases these still require notification to Treasury)
  • new restrictions are also imposed on financial services institutions