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Sanctions regimes

Iran Sanctions regime

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Snapshot: Iran sanctions regime [PDF 200 KB]

Why are sanctions imposed?

Between 2006 and 2010, the UNSC passed five resolutions imposing sanctions in relation to Iran in response to Iran’s refusal to suspend its uranium enrichment program. On 20 July 2015, the UNSC adopted Resolution 2231, which endorsed the Joint Comprehensive Plan of Action (JCPOA). The Resolution took effect on 16 January 2016. Under the Resolution, previous sanctions were terminated but measures that restrict certain activities were imposed. Australia implements United Nations Security Council (UNSC) sanctions by incorporating them into Australian law.

In addition, Australia imposes autonomous sanctions in relation to Iran, which complement the UNSC sanctions.

UNSC resolution 2231 (2015) remains in place despite the decision by the United States to withdraw from the JPCOA on 8 May 2018. As such, Australia’s UN sanctions against Iran remain unchanged.

Australia’s autonomous sanctions are likewise not affected by the United States’ withdrawal from the JCPOA. The Australian Government encourages Australian businesses to examine and take legal advice on implications of re-established domestic sanctions by the United States.

What is prohibited by the Iran sanctions regime?

The Iran sanctions regime imposes the following sanctions measures:

Measure UNSC Autonomous
restrictions on the export or supply of certain goods
restrictions on the import, purchase or transport of certain goods  
restrictions on certain commercial activities  
restrictions on the provision of certain services
restrictions on providing assets to designated persons or entities
restrictions on dealing with the assets of designated persons or entities
travel bans on designated persons

Restrictions on the export or supply of certain goods

It is prohibited to supply, sell or transfer to Iran (directly or indirectly) any of the following goods:

  • arms or related matériel
  • certain goods which the UNSC or Australia’s Minister for Foreign Affairs have determined could contribute to activities inconsistent with the JCPOA, including goods on the control lists issued by the Nuclear Suppliers Group, and the Missile Technology Control Regime.
  • certain kinds of graphite, raw metals, semi-finished metals, and software for integrating industrial processes.

Arms or related matériel includes, but is not limited to, weapons, ammunition, military vehicles and equipment, and spare parts and accessories for any of those things. It also includes paramilitary equipment. While each case will be considered individually, goods on the Defence and Strategic Goods List are likely to be considered arms or related matériel. Depending on the context, end user and end use, other goods may also be considered arms or related matériel. Go to Factsheet: Arms and Related Matériel for information on what to consider when assessing whether a good is an arm or related matériel.

Restrictions on the import, purchase or transport of certain goods

It is prohibited to procure from Iran, or from a person or entity in Iran, arms or related matériel (whether or not they originate in Iran) or to transport these goods.

Restrictions on certain commercial activities

It is prohibited to sell or otherwise make available an interest in a ‘sensitive commercial activity’ to Iran, an Iranian national, an entity incorporated in Iran, an entity controlled by Iran or Iranians, or any person or entity acting on his/her/their behalf. A ‘sensitive commercial activity’ is a commercial activity which involves any of the following:

  • uranium mining or production
  • the use of certain nuclear materials or technology
  • the supply, sale, transfer, manufacture or use of goods sanctioned on the basis of their connection with missile technology or nuclear weapon delivery systems development
  • an activity undertaken by Iran related to ballistic missiles capable of delivering nuclear weapons.

Restrictions on the provision of certain services

To complement the restrictions on the export/import of goods and on some commercial activities, the provision of services which relate to those sanctioned goods or activities is also restricted. It is prohibited to provide:

  • services (including but not limited to technical, brokering, financial and investment services, and the transfer of financial resources on certain technology) which assist with or relate to the supply, sale, transfer, manufacture, maintenance or use of export sanctioned goods by or for Iran (see ‘Restrictions on the export or supply of goods’ above)

Restrictions on providing assets to designated persons or entities

The UNSC and Australia’s Minister for Foreign Affairs have designated persons and entities for Iran. It is prohibited to directly or indirectly make an asset available to (or for the benefit of) a designated person or entity, their agents, or an entity they own or control.

Restrictions on dealing with the assets of designated persons or entities (requirement to freeze assets)

It is prohibited to use or deal with an asset, or allow or facilitate another person to use or deal with an asset owned or controlled by a designated person or entity (the assets are ‘frozen’ and cannot be used or dealt with). The prohibition on ‘dealing’ with assets includes using, selling or moving assets. ‘An 'asset' includes an asset or property of any kind, whether tangible or intangible, movable or immovable.

Go to the Consolidated List to search the names of designated persons and entities.

If you become aware that you are holding an asset of a designated person or entity, you are required to freeze (hold) that asset and notify the AFP as soon as possible. Go to What You Need to Do for more information.

Travel bans

All persons designated for the Iran sanctions regime are prohibited from transiting through or entering Australia.

Sanctions Permits

The Minister for Foreign Affairs may grant a sanctions permit to allow an activity that would otherwise be prohibited under this regime provided the activity meets specific criteria.

The Iran Sanctions Regime: Table of Measures and Permit Criteria PDF provides a general guide to the relevant criteria. You should get your own legal advice if you think your proposed activity is affected by sanctions and may meet the criteria for a permit. Go to Sanctions Permits for information on permits, including how to apply.

The Minister may need to notify or receive the approval of the UNSC before granting a sanctions permit. Where required, the Australian Sanctions Office will notify or seek approval from the UNSC as part of the permit application process.

Measure UNSC / Autonomous Details of activities requiring a permit Sanctions Permit Criteria References

Restrictions on the export or supply of certain goods

UN

Direct or indirect supply, sale or transfer of the following ‘export sanctioned goods’:   Regulations 6, 10 and 11 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016

Regulation 13CQ of Customs (Prohibited Exports) Regulations 1958

  • Goods listed in the Nuclear Suppliers Group Guidelines (preventing nuclear proliferation)
  • The goods meet the definition of ‘permissible goods’ in regulation 5 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016 or the supply has been approved in advance by the UNSC; and
  • the requirements set out in the relevant Nuclear Suppliers Group Guidelines have been met; and
  • Australia has obtained a right to, and can effectively, verify the end-use and end-use location for any goods that are supplied.

(Note, any permit issued under these criteria will contain a condition requiring notification of the supply within a set time period, to allow the Minister or delegate to comply with requirements to notify the UNSC and the International Atomic Energy Agency of the supply.)

Nuclear Suppliers Group Guidelines (INFCIRC/254/Parts 1 and 2)

Regulation 5, 6, 10 and 11 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016

  • Goods on the Missile Technology Control Regime List (preventing proliferation of missile systems capable of delivering WMD)
  • The supply has been approved in advance by the UNSC; and
  • the contract for delivery of the goods includes appropriate end-user guarantees; and
  • the Government of Iran has made a commitment to the Minister not to use the goods for the development of nuclear weapon delivery systems.
Missile Technology Control Regime List (S/2015/546)
  • Goods listed in the Iran Determination (goods that the Minister has determined could contribute to reprocessing or enrichment-related or heavy water-related activities inconsistent with the JCPOA, or the development of nuclear weapon delivery systems)
Where the goods could contribute to reprocessing or enrichment-related or heavy water-related activities inconsistent with the JCPOA:
  • the supply has been approved in advance by the UNSC; and
  • the requirements set out in the Nuclear Suppliers Group Guidelines, as appropriate, have been met; and
  • Australia has obtained a right to, and can effectively, verify the end use and end use location for any goods that are supplied.

(Note, any permit issued under these criteria will contain a condition requiring notification of the supply within a set time period, to allow the Minister or delegate to comply with requirements to notify the UNSC and the International Atomic Energy Agency of the supply.)

OR

Where the goods could contribute to the development of nuclear weapon delivery systems:

  • the supply has been approved in advance by the UNSC; and
  • the contract for delivery of the goods includes appropriate end-user guarantees; and
  • the Government of Iran has made a commitment to the Minister not to use the goods for the development of nuclear weapon delivery systems.

OR

The Minister determines that the supply could not contribute to reprocessing or enrichment-related or heavy-water related activities inconsistent with the JCPOA, or to the development of nuclear weapon delivery systems.

Charter of the United Nations (Sanctions-Iran) (Export Sanctioned Goods) List Determination 2016 (the Iran Determination)
  • 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 Convention Arms or related matériel, including spare parts
The supply is approved in advance by the UNSC.  
Autonomous Direct or indirect supply, sale or transfer to Iran, for use in Iran, or for the benefit of Iran, of the following ‘export sanctioned goods’:
  • arms or related materiel
  • certain types of graphite, raw metals, semi‑finished metals, and software for integrating industrial processes, listed in the Iran Specification.
The Minister is satisfied that it would be in the national interest to grant a permit. Regulations 4, 12 and 18 of the Autonomous Sanctions Regulations 2011

Autonomous Sanctions (Export and Import Sanctioned Goods – Iran) Amendment Specification 2016 (Iran Specification)

Regulation 11 of the Customs (Prohibited Exports) Regulations 1958

Restrictions on the import, procurement, purchase or transport of goods UN Procurement from Iran, or from a person or entity in Iran, of the following ‘import sanctioned goods’:
  • arms or related matériel, whether or not they originate in Iran.
The procurement is approved by the UNSC. Regulations 7, 12 and 13 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016

Restrictions on the provision of services

UN The provision to Iran of the following services related to the supply, sale, transfer, manufacture or use of ‘export sanctioned goods’:
  • technical assistance or training,
  • financial assistance,
  • investment, brokering or other financial services,

AND

The transfer of financial resources or financial services related to the supply, sale, transfer, manufacture or use of export sanctioned goods for the benefit of Iran,

AND

The provision to Iran of any technology related to the supply sale, transfer, manufacture or use of goods on the Missile Technology Control Regime List, or goods listed in the Iran Determination that could contribute to the development of nuclear weapon delivery systems.

The service relates to goods that meet the definition of ‘permissible goods’ in in regulation 5 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016, and the requirements set out in the Nuclear Suppliers Group Guidelines, as appropriate, have been met.

OR

Where the service relates to goods listed in the Iran Determination:

  • the Minister determines the services could not contribute to reprocessing or enrichment-related or heavy-water related activities inconsistent with the JCPOA, or to the development of nuclear weapon delivery systems.

OR

The provision of the service has been approved in advance by the UNSC, and the requirements set out in the relevant Nuclear Suppliers Group Guidelines have been met.

OR

Where the service relates to goods on the Missile Technology Control Regime List, or goods listed in the Iran Determination that could contribute to the development of nuclear weapon delivery systems:

  • the provision of the service has been approved in advance by the UNSC; and
  • the contract for delivery of the service includes appropriate end-user guarantees.
S/2015/546

Regulations 5 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016

Regulations 8, 9, 14 and 15 of the Charter of the United Nations (Sanctions-Iran) (Export Sanctioned Goods) List Determination 2016 (the Iran Determination)

Autonomous The following services if they assist with, or are provided in relation to the supply, sale or transfer, manufacture, maintenance or use of an ‘export sanctioned good’ for Iran; and
  • technical advice, assistance or training
  • financial assistance
  • a financial service
  • another service

AND

The following services if they assist with, or are provided in relation to a sanctioned import:

  • financial assistance
  • a financial service.
The Minister is satisfied that it would be in the national interest to grant a permit.  
Restrictions on commercial activities UN Selling or otherwise making available an interest in a ‘sensitive commercial activity’ to
  • Iran
  • an Iranian national
  • an entity incorporated in Iran or subject to Iranian jurisdiction
  • a person or entity acting on behalf of, or at the discretion of, Iran, an Iranian national, or an entity incorporated in Iran or subject to Iranian jurisdiction
  • an entity owned or controlled by Iran, an Iranian national
  • an entity incorporated in Iran or subject to Iranian jurisdiction.

A ‘sensitive commercial activity’ means a commercial activity:

  • involving uranium mining
  • involving uranium production
  • involving the use of nuclear materials or technology listed in Part 1 of the Nuclear Suppliers Group Guidelines
  • related to the supply, sale, transfer, manufacture or use of export sanctioned goods on the Missile Technology Control Regime List, or listed in the Iran Determination that could contribute to the development of nuclear weapon delivery systems
  • related to any activity undertaken by Iran that is related to ballistic missiles designed to be capable of delivering nuclear weapons, including launches using ballistic missile technology.
The commercial activity is approved by the UNSC. Regulations 19 and 30 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016

INFCIRC/254/Part 1

S/2015/546

Restrictions on providing assets to designated persons or entities

and

Restrictions on dealing with the assets of designated persons or entities

UN
  • the use of or dealing with an asset that is owned or controlled by:
    • a ‘designated person or entity’ for Iran
    • a person or entity acting on behalf or at the direction of a designated person or entity
    • an entity owned or controlled by a designated person or entity, including through illicit means

AND

  • making an asset available, directly or indirectly, to or for the benefit of:
    • a ‘designated person or entity’ for Iran
    • a person or entity acting on behalf or at the direction of a ‘designated person or entity’, including through illicit means; or
    • an entity owned or controlled by a ‘designated person or entity’ for Iran
So far as the availability of, use of, or dealing with the asset is necessary for:
  • civil nuclear cooperation projects described in Annex III of the JCPOA; or
  • activities directly related to the goods specified in paragraph 2 of Annex B to the JCPOA, or to any other activity required for the implementation of the JCPOA.

OR

The activity is a:

  • a basic expense dealing;
  • a legally required dealing;
  • a contractual dealing;
  • a required payment dealing; or
  • an ‘extraordinary expense dealing.
Regulations 16, 17 and 18 of the Charter of the United Nations (Sanctions – Iran) Regulation 2016

Regulation 5 of the Charter of the United Nations (Dealing with Assets) Regulations 2008

Joint Comprehensive Plan of Action (JCPOA)

Autonomous
  • The use of or dealing with an asset that is owned or controlled by a ‘designated person or entity’ for Iran; and
  • making an asset available directly or indirectly to, or for the benefit of, a ‘designated person or entity’ for Iran
The Minister is satisfied it would be in the national interest to grant a permit

and

the activity is a:

  • basic expense dealing;
  • legally required dealing; or
  • contractual dealing.
Regulations 6, 14, 15, 18 and 20 of Autonomous Sanctions Regulations 2011

Autonomous Sanctions (Designated Persons and Entities and Declared Persons – Iran) List 2012

Regulations 11A and 11B of the Customs (Prohibited Exports) Regulations 1958

Charter of the United Nations Act 1945

Iran Sanctions Regime: Case Study 1

An Australian mining equipment manufacturer is approached by an Iranian mining company to provide specialised equipment for use in an Iranian coal mine. The equipment is made from particularly strong and high grade materials, to withstand harsh mining environments and give it greater precision. The Australian company is aware that this means some of their products have dual uses, both in the mining sector, as well as in defence applications. They check the various Iran sanctions lists, and their equipment does not appear. However, similar goods are on the Defence and Strategic Goods List, and they don’t know if this also applies to their goods. They have checked the Consolidated List, and found that the names of everyone they are dealing with in Iran do not appear.

What the Australian company should do: The Australian company should seek an in principle assessment from the Australian Sanctions Office, to determine whether their goods require a sanctions permit. Even though the goods are intended for use in the mining industry, they may also be able to be repurposed for weapons development, or fit within the definition of arms or related materiel. Australian sanctions laws in relation to Iran restrict exports of goods that could assist Iran in developing a nuclear weapons capability, as well as arms and related materiel. The Australian Sanctions Office will consult with relevant technical specialists to identify alternative uses of the goods, as well as the risk that they may be repurposed. The Australian company may also need to engage with Defence Export Controls to seek additional export permits.

Iran Sanctions Regime: Case Study 2

An Australian manufacturing company is approached by an Iranian wholesaler to provide stationery including pens, highlighters, and lined notebooks, for sale in an Iranian school supplies shop. The Australian company has heard about sanctions in relation to Iran and is worried they may not be allowed to ship the goods. They understand there are lists of restricted goods related to nuclear and other weapons development, and some other things, but they don’t know if this includes stationery. They have checked the Consolidated List, and found that the names of everyone they are dealing with in Iran do not appear.

What the Australian company should do: The Australian company should check the Australian Sanctions Office website to identify which goods are restricted for export to Iran. They will notice that restricted exports for Iran relate to nuclear, missile and other weapons development, and arms and related materiel. In this case, stationery is not an export sanctioned good; the Iran regime does not impose blanket restrictions on the supply of goods. However, the Australian company still needs to consider the individuals and organisations it will be dealing with in Iran, as well as who will be using the goods, and how they will be used. They should seek detailed information from the Iranian wholesaler or any intermediaries, and check potential links to designated persons or entities on the Consolidated List. In this case, as there are no matches, there do not appear to be any restrictions on the export. If they are still unsure about whether the export would be allowed, they can submit a request for an in principle assessment to the Australian Sanctions Office.

US and Other Foreign Sanctions Laws

It is important you consider the wider legal and commercial context of your trade and investments, and seek your own legal advice on sanctions of the United States and other jurisdictions that might apply to your specific context. Australian businesses engaging with Iranian entities should monitor US sanctions and seek legal advice on whether your operations are affected. You may also wish to consult with your financial institution to ensure that any payments from Iran can be accepted, as some banks have restricted dealing with Iran due to US sanctions law. The Australian Government is not in a position to provide advice on the implications of US sanctions law.

Relevant legislation

The relevant legislation for the Iran sanctions regime includes the following:

Other Resources

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