EU sanctions apply to EU nationals wherever located, to any legal entity incorporated under the law of an EU Member State, to any person located in the territory of an EU Member State and to any business activities carried out in whole or part in an EU Member State. The primary measures of applicable EU sanctions against Iran after Implementation Day are asset freezes, particularly prohibitions on dealing with such frozen assets and on making funds or economic resources available to persons listed on the Consolidated List of Persons, Groups and Entities Subject to EU Financial Sanctions, and sector-specific limitations, for example restrictions on nuclear- or arms-related activities.
Prior to Implementation Day, the EU imposed broad economic and financial sanctions related to Iran’s nuclear program, with prohibitions in connection with many sectors of the Iranian economy, including the financial, banking, insurance, energy (oil, gas and petrochemical), shipping, shipbuilding and transport sectors, as well as restrictions on software, metals, gold, other precious metals, banknotes and coinage. Payments between EU and Iranian persons were also subject to requirements for prior notification (for payments between EUR 10,000 and EUR 400,000) or prior authorisation (for payments exceeding EUR 400,000) from relevant EU Member State authorities.
On Implementation Day, the EU lifted most of its economic and financial sanctions related to Iran’s nuclear program. All general restrictions on transfers of funds between EU individuals or entities and Iranian individuals or entities were terminated, and a significant number of individuals and entities were delisted. These persons are no longer subject to asset freezes, prohibitions on making funds available to such persons, or travel bans.
EU sanctions that relate to the human rights situation in Iran and support for terrorism remain in place. Certain individuals and entities designated under UN and EU sanctions continue to remain subject to an asset freeze and visa ban. Also remaining are EU bans on the export to Iran of arms and related materiel, missile technology, certain nuclear-related transfers and activities, certain metals and software, and equipment which could be used for internal repression or for monitoring telecommunications.
