Legal implications for a UK business on providing services to or doing business with Iranian nationals/businesses | LegaMart

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QuestionJun 25, 2021 - 12:45

Legal implications for a UK business on providing services to or doing business with Iranian nationals/businesses

What are the legal implications for a UK business providing services to Iranian nationals/businesses? Examples: 1- providing services to or doing business with developers and freelancers that are Iranian nationals 2- providing services to or doing business with Iranian food manufacturers and exporters 3- providing services to or doing business with Iranian wholesale food suppliers 4- providing services to or doing business with Iranian nationals/businesses through SaaS (software as a service) platforms or websites or mobile applications Are UK businesses subject to provisions of US sanctions against Iran? Do they face any risks or threats from US government?

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Jun 27, 2021 - 9:33

In early 2016, under the Joint Comprehensive Plan of Action (JCPoA) the majority of the EU's economic and trade sanctions against Iran were lifted including the wide ranging EU sanctions relevant to the oil and gas sector. The EU Iranian sanctions that remain in place restrict sales, supplies, transfers or exports directly or indirectly, to any individual, entity or body in Iran or any use of items that included in two EU Council Regulations: Council Regulation (EU) No 267/2012 and Council Regulation (EU) No 359/2011. The restrictions apply regardless of whether or not items originated in the EU, which means that sales and transfers from non-EU countries by EU persons are also prohibited. The provision of certain services connected to sanction list and items that feature on the EU's Common Military List are also subject to restrictions, including the provision of technical assistance, financing, financial assistance or brokering services.Wider restrictions also apply in respect of: the purchase, import or transport from Iran of certain of the above listed items; the provision of i) bunkering of ship supply services to, or any other servicing of, vessels or ii) engineering and maintenance services to cargo aircraft, owned or controlled directly or indirectly, by an Iranian person, entity or body where there are reasonable grounds to determine that the vessels or aircraft carry items included in the EU’s Common Military List or certain of above listed items; entering into arrangements with an Iranian person, entity or body (or persons acting on their behalf of at their direction) that would enable them to participate or increase participation in commercial activities involving uranium mining, the production or use of certain nuclear materials or involving certain of the above listed items or the manufacture of items listed on the EU Common Military list; and the provision of any telecommunication or internet monitoring or interception services of any kind to, or for the direct or indirect benefit of, Iran's government, public bodies, corporations and agencies or any person or entity acting on their behalf or at their direction. Supplies and dealings with entities more than 50% owned or controlled by financial sanctions targets are also prohibited

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