Search
In response to Iran’s support of Russia through delivery of drones, ballistic missiles and related technology, EU has expanded its sanctions regulations against Iran. The new measures include export restrictions on components used in development and production of missiles and drones, a transaction ban against certain Iranian ports and locks, and further asset freezes.
The new sanctions regulation was adopted and entered into force on 18 November 2024. The measures are set out in the new regulation accessible here.
The sanctions reaffirm the EU’s willingness to impose sanctions on states and third country entities that support Russia’s ability to wage war against Ukraine. This has previously been demonstrated, most notably with the introduction in the eleventh sanctions package of the EU’s so-called anti-circumvention tool, which allow the EU to impose export restrictions on specified goods and technology to certain third countries, which are at particularly high risk of circumvention.
Below, we have summarised some of the most significant changes to be noted by Danish Companies to ensure continued compliance with EU sanctions.
The EU has expanded its export restrictions towards Iran of components used in the development and production of Unmanned Aeriel Vehicles (UAVs) and missiles.
The list of prohibited items is expanded to include special materials and related equipment, materials processing, additional electronics, telecommunications and information security, sensors and lasers, navigation and avionics, aerospace and propulsion, and technology related hereto. These items can no longer freely be exported to Iran.
The EU has also adopted a transaction ban which prohibits any transaction with certain ports and locks, which currently consist of the Amirabad and Anzali Ports of Iran. The transaction ban prohibits access to facilities at the listed ports and locks, and the provision of any services to vessels operating there.
Certain exceptions are made for necessary and emergency actions related to maritime safety, humanitarian purposes, or the prevention or mitigation of events that could have a serious impact on human health, safety, or the environment.
The new sanctions also impose additional asset freezes. The new designations include individuals and entities that support or are otherwise involved in Iran’s UAV or missile programmes, including transferring such items to Russia.
Asset freezes have been imposed on one additional individual and four entities.
Danish companies should ensure that their sanctions compliance programmes, policies, screening and payment processes are updated to ensure that the newly adopted sanctions against Iran are appropriately addressed. The new sanctions are particularly relevant for shipping companies and companies that export items to Iran and/or its neighbouring countries.
Gorrissen Federspiel closely follows the developments of sanctions against Iran and Russia, and we can assist with interpretation of and compliance with applicable sanctions as well as the implementation of measures to ensure that sanctions are observed. If you have any questions, please feel free to contact a member of our Compliance & Sustainability team.
For more information on the previous EU sanctions packages relating to Russia, please see Gorrissen Federspiel’s newsletters of 10 September 2024, 25 June 2024, 27 February 2024, 19 December 2023, 26 June 2023, 27 February 2023, 19 December 2022, 7 October 2022, 8 June 2022, 11 April 2022, 16 March 2022, 10 March 2022, 2 March 2022, 28 February 2022, and 24 February 2022.