Iran sanctions essentially lifted


January 2016


As you will have all gathered from the weekend’s press reports, the economic sanctions against Iran were extensively lifted after the IAEA had established that Iran had taken the measures required under the JCPOA to reverse the nuclear programme. Through the publication of Council Decision (CFSP) 2015/1863, Council Regulation (EU) 2015/1861 and Council Implementing Regulation (EU) 2015/1862 in the Official Journal of the European Union (No. L 274, p. 1 et seqq.), the European Union had implemented its obligations under the Vienna Convention and Resolution 2231 (2015) to publish legal acts to suspend or lift the economic and financial sanctions listed in detail in the Vienna Convention as well as personal and corporate listings by Adoption Day.


With the establishment of Implementation Day, these provisions to lift the sanctions can now enter into force. Of primary importance for this is “Council Decision (CFSP) dated 16 January 2016 on the beginning of the application of the Council Decision (CFSP) amending Council Decision 2010/413/CFSP concerning restrictive measures against Iran”. A copy of this Council Decision is attached.


The majority of the sanctions have thus now been lifted. However, in its entirety Council Regulation (EU) 2015/1861 is very complex and extensive. There are also numerous exceptions to the provisions lifting the sanctions as well as extensive lists of goods. We therefore urgently recommend that you carefully check the sanction status of your specifically envisaged transaction prior to exporting to Iran.


Furthermore, you should bear in mind that payment transactions with Iran are still suffering from the fact that Iran does not yet participate in SWIFT again. We hear, however, that vehement efforts are being made to change this.


Stephan Müller


Telephone: +49 221 2091 448
Telefax: +49 221 2091 333

Denmark, Finland, Israel, Norway, Sweden