Airlines in Iran and the effect of EU and US Sanctions (Post-Implementation Day)
Written By
Partner
Netherlands
As co-head of our International Trade & Customs Group I have in-depth, long-standing experience in the full range of customs and trade related matters, sanctions regimes and the application of EU export controls. Whilst working across Europe I am based in The Hague.
Consultant
UK
I offer our clients over 35 years' experience in aviation & aerospace, covering almost every aspect of the sector.
Summary
| Airlines | ||
|---|---|---|
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Aban Air | Tehran (THR) | 2 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs (note that Aban Air was delisted from the SDN List on Implementation Day), and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Aria Air | Tehran (THR) | 2 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| ATA Airlines | Tabriz (TBZ) | 10 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Atrak Air | Tehran (THR) | 2 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Caspian Airlines | Tehran (THR) |
5 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
SDN LISTED ENTITY
For US Persons: General prohibition on trade involving Iran; licences not available for transactions with SDN entities.
For European persons: Dealings by European persons with SDN entities may risk that the European person could be listed as an SDN.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
|
(Note: related to the Iran Air group of companies, and regarded as a defunct airline). |
Tehran (THR) |
18 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
|
(Ceased operations in 2013) |
Tabriz (TBZ) |
3 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Iran Air | Tehran (THR) |
51 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs (note that Iran Air was delisted from the SDN List on Implementation Day), and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
|
(also known as Iranair Tours and Iran Air Tours) |
Mashhad (MHD) |
10 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs (note that Iran Airtours was delisted from the SDN List on Implementation Day), and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Iran Aseman Airlines | Tehran (THR) |
37 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Iran Naft Airlines | Ahvaz (AWZ) |
11 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Yas Air Kish | Tehran (THR) |
10 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
SDN LISTED ENTITY
For US Persons: General prohibition on trade involving Iran; licences not available for transactions with SDN entities.
For European persons: Dealings by European persons with SDN entities may risk that the European person could be listed as an SDN.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Mahan Airl | Tehran (THR) |
57 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
SDN LISTED ENTITY
For US Persons: General prohibition on trade involving Iran; licences not available for transactions with SDN entities.
For European persons: Dealings by European persons with SDN entities may risk that the European person could be listed as an SDN.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Meraj Air | Tehran (THR) |
13 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
SDN LISTED ENTITY
For US Persons: General prohibition on trade involving Iran; licences not available for transactions with SDN entities.
For European persons: Dealings by European persons with SDN entities may risk that the European person could be listed as an SDN.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Payam Air | Tehran (THR) |
0 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Qeshm Airlines | Qeshm (GSM) |
16 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
|
(Ceased operations in 2013) |
Tehran (THR) |
11 |
Relevant EU Sanctions
Prohibition to make funds or economic resources available, directly or indirectly, to or for the benefit of the listed persons in Annex 9 of Council Regulation (EU) 267/2012. The making available of funds or economic resources to a non-listed legal person (in this case Saha Airlines) which is owned or controlled by a listed person (in this case the Air branch of IRGC and IRGC) will in principle be considered as making them indirectly available to the latter, unless it can be reasonably determined, on a case-by-case basis using a risk-based approach, taking into account all of the relevant circumstances and set criteria regarding "ownership and control", that the funds or economic resources concerned will not be used by or be for the benefit of that listed person (in this case the Air branch of IRGC and IRGC).
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
|
(Ceased operations in 2013) |
Tehran (THR) |
4 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Sepahan Airlines | Isfahan (IFN) |
5 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Taban Airlines | Mashad (MHD) |
10 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
|
Note - Owned by PARS Aviation Company who supply aviation repair services to the IRGC and others. |
Tehran (THR) |
2 |
Relevant EU Sanctions
Prohibition to make funds or economic resources available, directly or indirectly, to or for the benefit of Yas Air being a listed person in Annex 9 of Council Regulation (EU) 267/2012.
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Yas Air is subject to additional sanctions and asset freezes as a result of its listing in Annex IX, Council Regulation (EU) 267/2012 (24 March 2012) relating to nuclear proliferation.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs (note that Yas Air remains listed on the SDN List after Implementation Day), and,
- facilitating transactions involving human rights abuses or terrorism.
| Airline | Main Base | Current Active Fleet |
|---|---|---|
| Zagros Airlines | Abadan (ABD) | 10 |
Relevant EU Sanctions
Prohibition on sale, supply, transfer or export, directly or indirectly, of items listed in Annex 3 of Council Regulation (EU) 267/2012 and items listed in Annexes III and IV of Council Regulation (EU) No 359/2011.
Prior authorisation required on sale, supply, transfer or export, directly or indirectly, of items listed in Annexes 1 and 2 of Council Regulation (EU) 267/2012.
Prior authorisations required for the sale, supply, transfer or export of dual-use items as listed in Council Regulation (EU) 428/2009, especially Categories 5, 7 and 9.
Relevant US Sanctions
For US Persons: General prohibition on trade involving Iran, but licences can be obtained to engage in transactions to ensure the safe operation of Iranian commercial passenger aircraft.
For European persons: No general prohibition on trade involving Iran, but risk that transactions may be blocked if the US banking system is used. US sanctions will still restrict any activities involving European persons and Iran relating to
- transfers of weapons-related technology,
- transactions involving SDNs, and,
- facilitating transactions involving human rights abuses or terrorism.
See also:
US and EU Iran sanctions lifted: how to proceed in the aviation sector?
