
Iran

1. Does Iran have a sanctions regime in place?
No. Iran does not publicize sanctions imposed against other nations or parties, but it may impose certain sanctions on an ad hoc basis.
2. Does Iran implement UN sanctions?
Iran has been an original member of the UN since October 1945, and it has in the past implemented UN sanctions. Today, Iran may implement certain UN sanctions, depending on the nature, but it has been a rare occurrence since the country became the Islamic Republic of Iran.
3. Does Iran implement an autonomous sanctions regime?
Yes. Iran may impose autonomous general sanctions against countries. For example, Iran has implemented strict sanctions against Israel and Israeli nationals, where travelling to the country is strictly prohibited by Iran, conducting business with Israel and Israelis, or any nations who has a presence in Israel is strictly prohibited, and Iranian nationals are generally prohibited to travel to Israel.
In March 2017 Iran implemented a new sanctions regime against 15 American companies, alleging these companies support terrorism, repression and Israel’s occupation of Palestinian land.
On 13 August 2017, Iran passed a Law on Countering the Violation of Human Rights and Adventurous and Terrorist Activities of the United States in the Region pursuant to which the Ministry of Foreign Affairs is required to identify US individuals and entities to be sanctioned. The Ministry recently released statements announcing sanctions on a number of US authorities:
4. What is the nature of the sanctions regime in Iran?
The nature of the sanctions are usually economic and political.
5. Does Iran maintain a list of sanctioned individuals and entities?
Aside from the general sanctions against countries (for example Israel), there is a list of sanctioned individuals and entities which will not be publicized by the Iranian Ministry of Foreign Affairs. The list remains with the Government of Iran only.
The Ministry of Foreign Affairs has nonetheless recently released statements announcing sanctions against US individuals and entities pursuant to the 2017 Law on Countering the Violation of Human Rights and Adventurous and Terrorist Activities of the United States in the Region.
6. Are there any other lists related to sanctions?
The list is not available to the public.
7. Does Iran have a licensing or authorization system in place?
Yes. Usually most licences and authorizations are granted by the Islamic Republic of Iran’s Ministry of Industry, Mine and Trade.
8. What are the consequences for a breach of sanctions in Iran?
The penalties are not release to the public. Breach of sanctions usually leads to criminal prosecutions.
9. Who are the relevant regulators in Iran and what are their contact details?
The Ministry of Foreign Affairs in Iran is usually responsible for governing most sanctions. However the information is usually not released to public. Islamic Republic of Iran Ministry of Foreign Affairs Imam Khomeini Sq Tehran, Iran T: (+9821) 61151 F: (+9821) 61154275 E: info@mfa.gov.ir W: en.mfa.ir
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Léonor d’Albiousse
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Wesley Pydiamah
Partner
Eversheds Sutherland (France) 8 Place D'Iéna Paris 75116 France
T: +33 1 55 73 40 29 LeonorDAlbiousse@eversheds-sutherland.com
T:+33 1 55 73 41 22
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