Iran sanctions: continued vigilance for the payments industry despite international agreement

Published on 3rd Aug 2015

On 14 July 2015, the E3+3 (UK, France, Germany, Russia, China and US), the EU and Iran reached a comprehensive agreement on Iran’s nuclear programme. The deal is set out in the Joint Comprehensive Plan of Action (plus associated annexures). 

The Plan of Action

The agreement provides that almost all economic and financial sanctions imposed will be lifted, including the block on Iran using the Swift system for international electronic banking, but only after Iran fulfils a list of stringent conditions relating to its nuclear programme. Commentators have estimated that this process could take at least six months 

Importantly, while the deal signifies the intention of the international community to remove the sanctions against Iran, the extensive sanctions regime remains in place for the time being and will continue to be in force. Broadly, the measures now in place involve:

  • the freezing of funds and economic resources of designated persons;
  • restrictions on transfers of funds to and from an Iranian person, entity or body;
  • vigilance over activities with Iranian banks;
  • restrictions on Iran’s access to the EU’s insurance and reinsurance markets as well as restrictions on the provision of insurance;
  • restrictions on financing certain Iranian enterprises; and
  • prohibitions on EU credit and financial institutions transferring funds to or from Iranian banks.


Provided the terms of the Plan are adhered to, the UK government has expressed its intention to help the business and financial sector take advantage of the opportunities that arise, and promote trade and investment between our two countries. Until then, however, firms involved in the payments, banking and financial spheres particularly, should continue to be vigilant with respect to any transaction that could involve an Iranian person, entity or body and carry out sanctions checks as usual.

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* This article is current as of the date of its publication and does not necessarily reflect the present state of the law or relevant regulation.

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