Despite the easing of sanctions on Iran on 16 January1 under the Joint Comprehensive Programme of Action (JCPOA), some prohibitions and licensing requirements continue to apply to EU businesses. These are summarised below, together with an outline of the work of the ‘Procurement Channel’ established to consider certain proposed transfers.
This does not address the remaining restrictions on non-U.S. persons imposed by the U.S. authorities, which EU businesses must continue to take into account.
What remains prohibited?
- All military goods and technology,2 and related assistance and services (including technical assistance, brokering, financial and insurance services): their sale, supply, transfer, export and import to or from any Iranian person or entity, or for use in Iran, remains embargoed until ‘Transition Day’ (18 October 2023, but possibly earlier).
- All missile-related dual use items,3 and related assistance and services: these are subject to the same embargo as military items.
- All items which might be used for internal repression,4 and related assistance and services: the embargo on their sale, supply, transfer or export remains in place, under the provisions relating to the human rights situation in Iran which are not affected by the JCPOA.
- Investment in Iranian entities manufacturing or using military or missile-related dual use items.
- Making funds or other economic resources available to listed persons and entities that remain subject to an EU asset freeze, or entities owned or controlled by them.
What requires a licence subject to UN authorisation via the Procurement Channel?
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