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The United Kingdom has published statutory guidance on Iran sanctions.
The UK Government published statutory guidance on 9 September 2026 on the Iran (Sanctions) Regulations 2023, covering financial, trade, maritime, director-disqualification and immigration measures.
Statutory guidance on the 2023 regime
The UK Government published statutory guidance on 9 September 2026 concerning the Iran (Sanctions) Regulations 2023 . The document covers financial sanctions, director-disqualification measures, trade prohibitions, transport sanctions and immigration measures under those Regulations .
The guidance is issued by the Secretary of State for Foreign, Commonwealth and Development Affairs under section 43 of the Sanctions and Anti-Money Laundering Act 2018 . According to the UK Government, it sets out the regime's prohibitions and obligations, their implementation and enforcement arrangements, and potentially applicable exceptions and licences .
Its territorial scope extends to any person, entity or organisation conducting activities in the United Kingdom, including in territorial waters . It also covers entities incorporated under the law of any part of the United Kingdom when conducting activities outside UK territory, as well as British nationals wherever they are located .
Part 11 of the Regulations extends certain maritime enforcement powers to British ships in international or foreign waters, stateless ships in international waters, and foreign ships in international waters . The Regulations prohibit knowingly participating in an activity whose object or effect is, directly or indirectly, to circumvent a prohibition, facilitate a breach, or enable a breach of the prohibitions they establish .
The source refers readers to the legislation.gov.uk page for the status of amendments and earlier versions of the Regulations .
Asset freezes, OFSI and disqualification
Part 3 of the Iran (Sanctions) Regulations 2023 establishes financial sanctions based on targeted asset freezes for designated persons . The regime covers their funds and economic resources, including non-monetary assets such as real estate and vehicles, as well as funds and economic resources made available, directly or indirectly, to them or for their benefit . The same prohibitions apply to entities owned or controlled by a designated person .
The Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, is responsible for implementing UK financial sanctions, monitoring compliance and assessing suspected breaches . The guidance states that businesses and persons subject to reporting obligations must provide HM Treasury, in practice OFSI, with information on known or suspected designated persons or entities, as well as suspected breaches of the regime's prohibitions or obligations . OFSI may require information and the production of documents, including from a designated person; failure to respond or the provision of false information is an offence .
The principal offences relating to financial prohibitions or licensing provisions are punishable, on conviction on indictment, by a maximum of seven years' imprisonment, a fine, or both . Offences concerning reporting obligations are subject to summary proceedings and carry up to six months' imprisonment or a fine .
Part 4 of the Regulations, read with regulation 21, provides for the disqualification of persons designated for that purpose . They may not act as directors of a UK company, or participate directly or indirectly in its promotion, formation or management . The measure also applies to the management of a foreign company with a sufficient UK connection, including where it conducts business or holds assets in the United Kingdom . The principal disqualification offences carry a maximum penalty of two years' imprisonment, a fine, or both .
Trade prohibitions, ships and licences
Part 6 of the Iran (Sanctions) Regulations 2023 groups together trade prohibitions concerning, in particular, the export, supply, delivery, making available or transfer of goods or technology to Iran, for use in Iran or for the benefit of a person connected with Iran .
Goods and technology of strategic concern are identified through UK Tariff commodity codes. The guidance specifies that the applicable classification is that which would result from importing the goods into the United Kingdom under the rules of that tariff . The prohibitions also cover the direct or indirect provision of financial services, funds, technical assistance and brokering services where these relate to prohibited transactions .
Regulations 43C and 43D concern respectively the provision and acquisition of services relating to specified ships, including brokering, chartering, crewing, financial, operational or technical-assistance services . Transport sanctions prohibit the chartering or operation of a specified ship and the entry into UK ports of specified ships or ships connected with a designated person .
The guidance describes exceptions for certain emergency situations, personal effects, personal use, diplomatic missions, and port access required in an emergency or under a movement direction . The emergency exception in regulation 56 covers, in particular, certain acts falling under regulations 28 to 34, 37 to 43 and 43B to 43D .
The BIST is responsible for issuing trade licences. The OTSI handles certain trade activities, while the ECJU processes applications concerning goods or technology subject to strategic export controls . The DfT is responsible for transport licences and OFSI for licences relating to financial sanctions .
The guidance states that activities also covered by the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 are assessed under both regimes. A licence granted in that context may be valid under both instruments .
Sources cited
- gov.uk - Le Royaume-Uni publie une guidance statutaire sur les sanctions contre l'Iran et le rôle de l'OFSI