Editor’s Note
This article details the EU’s recent decision to reimpose significant asset-freeze measures on a wide range of Iranian individuals and entities, extending beyond UN sanctions. The targets include key financial, energy, and shipping sectors.
Going beyond UN-based designations, the EU has reinstated asset-freeze measures against more than 50 natural persons (“individuals”) and close to 200 legal persons, entities or bodies (“entities” and, collectively with individuals, “persons”), as listed in Annexes VIII and IX of Regulation 267/2012.
Targeted persons, which are located both inside and outside Iran, notably comprise major financial institutions, companies operating in the energy sector and shipping companies.
While most existing and/or standard exemptions or derogations have been maintained, limited additional exemptions and derogation grounds have been introduced.
Export-related restrictions refer to prohibitions targeting the sale, supply, transfer or export of specific items, as well as—in most cases—ancillary services related to such items (technical assistance, brokering services, financing or financial assistance) to Iranian persons, entities or bodies (“Iranian persons”) or for use in Iran;
Import-related restrictions refer to prohibitions targeting the import, purchase or transport of specific items, as well as—in some cases—ancillary services, if they originate in, have been or are exported from and/or are located in Iran.
Export- and import-related restrictions, which had been relaxed under the JCPOA, have been fully reintroduced as regards:
Dual-use items, as listed in Annex I of the EU’s dual-use Regulation, excluding a subset of items specified in part A of Annex I of Regulation 267/2012 (“Dual-Use Items”).
Goods and technology which could contribute to Iran’s nuclear proliferation-related activities, as listed in Annex II of Regulation 267/2012 (“Proliferation Items”).
Limited exemptions and derogations have been introduced, including a wind-down exemption until January 1, 2026 for contracts concluded before September 30, 2025 as regards Dual-Use Items listed in Part C of Annex I of Regulation 267/2012.
The measures reimposed are without prejudice to export- and import-related restrictions, as well as investment prohibitions in respect of items that could contribute to the development of nuclear weapon delivery systems, as identified in Annex III of Regulation 267/2012, which continue to apply.
Export-related restrictions have also been reimposed as regards:
Equipment and technology for the oil and gas industry (exploration or production of crude oil and natural gas, refining, liquefaction of natural gas) or petrochemical industry, as listed in Annexes VI and VIA of Regulation 267/2012 (“Energy Equipment”).
Naval equipment or technology for shipbuilding, maintenance or refit, including equipment or technology used in the construction of oil tankers, as listed in Annex VIB of Regulation 267/2012 (“Naval Equipment”).
Enterprise Resource Planning software, designed specifically for use in nuclear, military, gas, oil, navy, aviation, financial and construction industries, as listed in Annex VIIA of Regulation 267/2012 (“Industrial Software”).
Graphite and raw or semifinished metals, including aluminum and steel, as listed in Annex VIIB of Regulation 267/2012.
Limited exemptions and derogations have been introduced, including a wind-down exemption until January 1, 2026 for contracts concluded before September 30, 2025 as regards Energy Equipment (provided they relate to an investment made in Iran before September 30, 2025), Naval Equipment and Industrial Software.
Targeted export-related restrictions have been reintroduced as regards:
Gold, precious metals and diamonds, as listed in Annex VII of Regulation 267/2012, but only to the Government of Iran, its public bodies, corporations and agencies and any person acting on their behalf or at their direction, or any entity or body owned or controlled by them.
Newly printed or unissued Iranian denominated banknotes and minted coinage, but only to, or for the benefit of the Central Bank of Iran.
Import-related restrictions have been reintroduced as regards:
Crude oil or petroleum products, as listed in Annex IV of Regulation 267/2012 (“Oil Items”).
Petrochemical products, as listed in Annex V of Regulation 267/2012 (“Petrochemical Items”).
Natural gas, as listed in Annex IVa of Regulation 267/2012 (“Gas Items”).
