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Accueil » Islamic Republic of Iran

Islamic Republic of Iran

Status of the embargoOngoing
EntityState
Organisation(s) imposing embargo(es)EU
Restriction(s)Conventional weapons
Nuclear
Internal repression
Surveillance equipment
ExceptionsYes, no prior notification or approval
Yes, prior notification
Yes, prior approval

The Islamic Republic of Iran is currently under EU arms embargoes. The UN embargo expired on 18 October 2020.

UN

Iran was under a UN embargo between 2006 and 2020 (Resolution 1737 (2006)). The embargo expired on 18 October 2020, as it was not renewed as agreed during the negotiations for the Iran Nuclear Deal.

On January 16th 2016, a new arms embargo was established within the framework of the Joint Comprehensive Plan of Action on Iranian nuclear programme adopted 14th July 2015 (Resolution 2231 (2015), Annex A), which replaced all previous sanctions provided for in Resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008), 1929 (2010), and 2224 (2015).

  1. Conventional weapons

Prohibitions and exceptions

The current sanctions regime, as detailed in Resolution 2231 (2015), established that UN Member States must obtain UN Security Council’s prior approval to authorize :

  • the supply, sale or transfer directly or indirectly (…) to Iran, of any battle tanks, armoured combat vehicles, large calibre artillery systems, combat aircraft, attack helicopters, warships, missiles or missile systems, as defined for the purpose of the United Nations Register of Conventional Arms, or related materiel, including spare parts (Resolution 2231 (2015), Annex B, para.5).
  • the provision of technical training, financial resources or services, advice, other services or assistance related to the supply, sale, transfer, manufacture, maintenance, or use of arms and related materiel (Resolution 2231 (2015), Annex B, para.5).

2. Nuclear

Prohibitions and exceptions related to items, materials and technologies that might contribute to the nuclear programme

The current sanctions regime, as detailed in Resolution 2231 (2015), established that UN Member States must obtain UN Security Council’s prior approval to authorize :

  • the supply, sale or transfer directly or indirectly to, or for the use in or benefit of, Iran, and whether or not originating in their territories, of all items, materials, equipment, goods and technology set out in INFCIRC/254/Rev.12/Part 1 [on the export of nuclear materials, equipment and technology ] and INFCIRC/254/Rev.9/Part 2 [on transfers of nuclear-related dual-use equipment, materials, software and related technologies] (Resolution 2231 (2015), Annex B, para.2, a). This list is not exhaustive and the relevant State concerned may add any further items for which it determines they “could contribute to reprocessing or enrichment-related or heavy water-related activities inconsistent with the JCPOA” (Resolution 2231 (2015), Annex B., para.2).
  • the provision to Iran of any technical assistance or training, financial assistance, investment, brokering or other services, and the transfer of financial resources or services, related to the supply, sale, transfer, manufacture or use of the items, materials, equipment, goods and technology aforementioned (Resolution 2231 (2015), Annex B., para.2, b).

However, approval in advance by the Security Council shall not be required for the supply, sale, or transfer to Iran of equipment covered by B.1 of INFCIRC/254/Rev.12/Part 1 when such equipment is for light water reactors, low-enriched uranium covered by A.1.2 of INFCIRC/254/Rev.12/Part 1 when it is incorporated in assembled nuclear fuel elements for such reactors, as well as items, materials, equipment, goods and technology set out in INFCIRC/254/Rev. 9/Part 2 only when for exclusive use in light water reactors (Resolution 2231 (2015), Annex B., para.2).

Prohibitions and exceptions related to items and technologies that might contribute to ballistic missiles programmes

The current sanctions regime, as detailed in Resolution 2231 (2015), established that UN Member States must obtain UN Security Council’s prior approval to authorize :

  • the supply, sale or transfer directly or indirectly from their territories, or by their nationals or using their flag vessels or aircraft to or from Iran, or for the use in or benefit of Iran, and whether or not originating in their territories, of all items, materials, equipment, goods and technology set out in S/2015/546 and of any items, materials, equipment, goods and technology that the State determines could contribute to the development of nuclear weapon delivery systems (Resolution 2231 (2015), Annex B., para.4, a).
  • the provision to Iran of any technology or technical assistance or training, financial assistance, investment, brokering or other services, and the transfer of financial resources or services, or Iran’s acquisition of an interest in any commercial activity in another State, related to the supply, sale, transfer, manufacture or use of the items, materials, equipment, goods and technology aforementioned (Resolution 2231 (2015), Annex B., para.4, b).

The sanctions regime calls upon to Iran to not undertake any activity related to ballistic missiles designed to be capable of delivering nuclear weapons, including launches using such ballistic missile technology (Resolution 2231 (2015), Annex B., para.3).

3. Transversal prohibitions

The current sanctions regime, as detailed in Resolution 2231 (2015), calls upon to Member States to take the necessary measures to ensure that any activities covered by the sanctions regime and “occur[ring] on their territories, or involving their nationals or individuals subject to their jurisdiction, or involving their flag vessels or aircraft, (…) [be] pursuant to the relevant terms of [these activities as described in the relevant paragraphs], and also to prevent and prohibit any activities inconsistent with these provisions” (Resolution 2231 (2015) Annex B, para.6, a).

4. Other prohibitions

Member States are also requested to take the necessary measures to “prevent, except as decided otherwise by the UN Security Council in advance on a case-by-case basis, the supply, sale, or transfer of arms or related materiel from Iran by their nationals or using their flag vessels or aircraft, and whether or not originating in the territory of Iran” (Resolution 2231 (2015), Annex B, para.6, b).

The sanctions regime also provides for some targeted measures – freezing of financial assets and travelling restrictions – to individuals participating in, directly associated to or supporting the development of proliferation-sensitive nuclear-, arms- and ballistic missile-related activities for Iran but also to individuals and entities, acting for aforementioned individuals or entities controlled or owned by them. The list of targeted persons and entities is set and updated by the UN Sanctions Committee established pursuant Resolution 1337 (2006).

Others

Restrictive measures pertaining to conventional arms transfers are in force until October 2020 (Resolution 2231 (2015), Annex B, para.5). Those pertaining to Iranian nuclear programme apply until October 18th 2025 (Resolution 2231 (2015), Annex B, para.2), while ballistic missiles-related sanctions are in force until October 18th 2023 (Resolution 2231 (2015), Annex B, para.4).

The Islamic Republic of Iran is also subject to an EU arms embargo.

EU

The Islamic Republic of Iran has been under EU arms embargo since February 2007 (Common Position 2007/140/CFSP) Restrictive measures have first been extended and strengthened before being partly eased within the framework of the Joint Comprehensive Plan of Action on Iranian nuclear programme which was adopted 14th July 2015 (UN Resolution 2231 (2015), Annex A).

The current sanctions regime, as detailed in the updated versions of Council Decision 2010/413/CFSP and its related Regulation 267/2012 – completed by Council Decision 2011/235/CFSP and its related Regulation 359/2011 and Decision 2023/1532/CFSP and its related Regulation 2023/1529 –  prohibits, or make subject to prior approval, the supply, transfer or export to Iran of certain items, pertaining to weaponry, internal repression, communications interception and monitoring and military nuclear activities.

  1. Conventional weapons

Prohibitions

The current sanctions regime, as detailed in the updated versions of Council Decision 2010/413/CFSP and its related Regulation 267/2012, completed by the updated versions of Decision 2023/1532/CFSP and its related Regulation 2023/1529, prohibits :

  • The supply, sale and transfer to Iran of arms and related materiel of all types, including weapons and ammunition, military vehicles and equipment, paramilitary equipment and spare parts (Decision 2010/413/CFSP, art.1, para.1, c).
  • The provision of technical assistance training or other assistance as well as financial assistance or financing related to items aforementioned (Decision 2010/413/CFSP, art.1, para.3, a and b).
  • to sell, supply, transfer or export, directly or indirectly, goods and technology which might contribute to Iran’s capability to manufacture Unmanned Aerial Vehicles (UAVs), whether or not originating in the Union, to any natural or legal person, entity or body in Iran or for use in Iran (Decision 2023/1532/CFSP, art.1, para.1 and Regulation 2023/1529, art.2, para.1) as well as the provision of technical assistance training or other assistance as well as financial assistance or financing related to items aforementioned (Decision 2023/1532/CFSP, art.1, para.2, a and b, and Regulation 2023/1529, art.2, para.2, a and b), due to Iran’s military support to Russia’s war of aggression against Ukraine.

Exceptions

Requiring no prior approval or notification from/to the UN Sanctions Committee:

  • the supply, sale or transfer of non-combat vehicles which have been manufactured or fitted with materials to provide ballistic protection, intended solely for protective use of personnel of the EU and its Member States in Iran (Decision 2010/413/CFSP, art.1, para.1, c).

Requiring prior approval from the UN Sanctions Committee:

  • the supply, sale or transfer of the items prohibited (art.1, para.1, c), as well as the provision of technical or financial assistance related, where the Committee determines in advance and on a case-by-case basis that such supply, sale, transfer or provision of such items or assistance would clearly not contribute to the development of Iran’s technologies in support of its proliferation-sensitive nuclear activities and of development of nuclear weapon delivery systems, including where such items or assistance are for food, agricultural, medical or other humanitarian purposes (Decision 2010/413/CFSP, art.3, para.1). However, Decision 2010/413 provides that the supply, sale or export of such goods and technologies are only allowed under two conditions, which are not stated in Regulation 267/2012: sufficient guarantees must be provided on their end-use and Iran must commit itself not to use these articles for the development of nuclear weapons (Decision 2010/413/CFSP, art.3, para.1, a and b).

2. Nuclear

Prohibitions

The current sanctions regime, as detailed in the updated versions of Council Decision 2010/413/CFSP and its related Regulation 267/2012, prohibits :

  • The direct or indirect supply, sale or transfer to Iran of
    items, materials, equipment, goods and technology contained in the Nuclear Suppliers Group and Missile Technology Control Regime lists (Decision 2010/413/CFSP, art.1, para.1, a). The items prohibited are listed in Annex I of Regulation 267/2012.
  • The direct or indirect supply, sale or transfer to Iran of any additional items, materials, equipment, goods and technology, determined by the Security Council or the Committee, which could contribute to enrichment-related, reprocessing or heavy water-related activities, or to the development of nuclear weapon delivery systems (Decision 2010/413/CFSP, art.1, para.1, b). The items prohibited are listed in Annex II of Regulation 267/2012.
  • The direct or indirect supply, sale or transfer to Iran of certain other items, materials, equipment, goods and technology that could contribute to enrichment-related, reprocessing or heavy water-related activities, to the development of nuclear weapon delivery systems or to the pursuit of activities related to other topics about which the IAEA has expressed concerns or identified as outstanding (Decision 2010/413/CFSP, art.1, para.1, d), as well as other dual-use goods and technology listed in Annex I to Council Regulation (EC) No 428/2009 of 5 May 2009 (Decision 2010/413/CFSP, art.1, para.1, e). The items prohibited are listed in Annex II of Regulation 267/2012.
  • The direct or indirect supply, sale or transfer to, or for use in, or the benefit of Iran of items, materials, equipment, goods and technology, including software, not covered by Article 1, that could contribute to enrichment-related, reprocessing or heavy water-related activities, to the development of nuclear weapon delivery systems or to the pursuit of activities related to other topics about which the IAEA has expressed concerns or identified as outstanding (Decision 2010/413/CFSP, art.2, para 1 and 3).
  • The provision of technical assistance training or other assistance as well as financial assistance or financing related to items aforementioned (Decision 2010/413/CFSP, art.1, para.3, a and b, and art.2, para.2).
  • the procurement by nationals of Member States of the items, materials, equipment, goods and technology aforementioned from Iran (Decision 2010/413/CFSP, art.1, para.4).

Exceptions

Requiring no prior approval or notification from/to the UN Sanctions Committee:

  • the direct or indirect transfer to, or for use in, or the benefit of Iran, through the territories of Member States of items referred to in paragraph 2(c), subparagraph 1 of Annex B to UNSCR 2231 (2015) for light water reactors. (Decision 2010/413/CFSP, art.1, para.2, and Regulation 267/2012, art.2b, para.1 and art.3c, para.1).
  • The direct or indirect supply, sale or transfer to Iran of dual-use goods and technology listed in Annex I to Council Regulation (EC) No 428/2009 of 5 May 2009, as well as the provision of technical or financial assistance related, where  the competent authority in the relevant Member State determines in advance and on a case-by-case basis that such supply, sale, transfer or provision of such items or assistance would clearly not contribute to the development of Iran’s technologies in support of its proliferation-sensitive nuclear activities and of development of nuclear weapon delivery systems, including where such items or assistance are for medical or other humanitarian purposes (Decision 2010/413/CFSP, art.3, para.2). However, Decision 2010/413 provides that the supply, sale or export of such goods and technologies are only allowed under two conditions, which are not stated in Regulation 267/2012: sufficient guarantees must be provided on their end-use and Iran must commit itself not to use these articles for the development of nuclear weapons (Decision 2010/413/CFSP, art.3, para.2, a and b).

Requiring prior approval from the UN Sanctions Committee:

  • The direct or indirect supply, sale or transfer to Iran of the items listed in Annex II of Regulation 267/2012, as well as the provision of technical or financial assistance related, where the Committee determines in advance and on a case-by-case basis that such supply, sale, transfer or provision of such items or assistance would clearly not contribute to the development of Iran’s technologies in support of its proliferation-sensitive nuclear activities and of development of nuclear weapon delivery systems, including where such items or assistance are for food, agricultural, medical or other humanitarian purposes (Decision 2010/413/CFSP, art.3, para.1). However, Decision 2010/413 provides that the supply, sale or export of such goods and technologies are only allowed under two conditions, which are not stated in Regulation 267/2012: sufficient guarantees must be provided on their end-use and Iran must commit itself not to use these articles for the development of nuclear weapons (Decision 2010/413/CFSP, art.3, para.1, a and b).

3. Equipment which might be used for internal repression

Prohibitions

The current sanctions regime, as detailed in the updated versions of Council Decision 2011/235/CFSP and its related Regulation 359/2011, prohibits :

  • The sale, supply, transfer or export of equipment which might be used for internal repression to Iran by nationals of Member States or from the territories of Member States or using their flag vessels or aircraft, shall be prohibited, whether or not originating in their territories (Decision 2011/235/CFSP, art.2b, para.1 and Regulation 359/2011, art.1a, para.1, a). These equipment are listed in Annex III of Regulation 264/2012 updating Regulation 359/2011.
  • The provision of technical assistance training or other assistance as well as financial assistance or financing related to items aforementioned (Decision 2011/235/CFSP, art.2b, para.2, a and b, and Regulation 359/2011, art.1a, para.1, b and c).

Exceptions

Requiring no prior approval or notification from/to the UN Sanctions Committee:

  • the sale, supply, transfer or export of equipment aforementioned which is intended solely for the protective use of the personnel of the Union and its Member States in Iran, or the provision of technical assistance, brokering services and other services or of financing and financial assistance related to such equipment (Decision 2011/235/CFSP, art.2b, para.3, and Regulation 359/2011, art.1a, para.2).

4. Surveillance equipment

Prohibitions

The current sanctions regime, as detailed in the updated versions of Council Decision 2011/235/CFSP and its related Regulation 359/2011, prohibits :

  • The sale, supply, transfer or export of equipment or software intended primarily for use in the monitoring or interception by the Iranian regime, or on its behalf, of the Internet and of telephone communications on mobile or fixed networks in Iran (Decision 2011/235/CFSP, art.2a and Regulation 359/2011, art.1b, para.1 and 3). These equipments are listed in Annex IV of Regulation 359/2011.
  • the provision of assistance to install, operate or update such equipment or software, as well as the provision of technical assistance training or other assistance, financial assistance or financing related to equipment aforementioned (Decision 2011/235/CFSP, art.2a and Regulation 359/2011, art.1c, para.1, a,b and c).

Exceptions

Requiring prior notification to other Member States and to the Commission :

  • The sale, supply, transfer or export of equipment or software aforementioned if the competent authorities of the Member States have reasonable grounds to  determine that the equipment, technology or software in question would not be used for monitoring or interception, by Iran’s government, public bodies, corporations and agencies or any person or entity acting on their behalf or at their direction, of internet or telephone communications in Iran (Regulation 359/2011, art.1b, para.2).

Others

The sanctions regime also provides for targeted sanctions such as assets freeze and travel restrictions against individuals or entities involved directly or indirectly in the development of nuclear weapons or nuclear delivery systems on behalf of Iran. They are listed in Annexes I and II of Decision 2010/413/CFSP and Annexes VIII and IX of Regulation 267/2012.

To the exclusion of sanctions provided for in Decision 2011/235/CFSP which are in force until 13th April 2025, the EU arms embargo against Iran is indefinite.

The Islamic Republic of Iran is also subject to an UN arms embargo.

Restrictions diagram :

Conventional weapons

Nuclear

Surveillance equipment

Internal repression