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Airlines in Iran and the effect of EU and US Sanctions (Post-Implementation Day)

Airlines in Iran and the effect of EU and US Sanctions (Post-Implementation Day)

Published

Jun 08 2016

Written By

Brian Mulier

Partner
Netherlands

Paul Briggs

Consultant
UK

Summary

Airlines
Aban Air Aria Air ATA Airlines Atrak Air Caspian Airlines Chabahar Airlines Eram Air Iran Air	Iran Airtour Airline Iran Aseman Airlines Iran Naft Airlines Yas Air Kish Mahan Airl Meraj Air Payam Air Qeshm Airlines	Saha Airlines Safiran Airlines Sepahan Airlines Taban Airlines Yas Air Zagros 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
Chabahar Airlines ^{(Note: related to the Iran Air group of companies, and regarded as a defunct airline).}	Tehran (THR)	18

Airline

Main Base

Current Active Fleet

Chabahar Airlines

^{(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
Eram Air ^{(Ceased operations in 2013)}	Tabriz (TBZ)	3

Airline

Main Base

Current Active Fleet

Eram Air

^{(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
Iran Airtour Airline ^{(also known as Iranair Tours and Iran Air Tours)}	Mashhad (MHD)	10

Airline

Main Base

Current Active Fleet

Iran Airtour Airline

^{(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
Saha Airlines ^{(Ceased operations in 2013) Note – Saha Airlines is a wholly owned subsidiary of the Air branch of the IRGC.}	Tehran (THR)	11

Airline

Main Base

Current Active Fleet

Saha Airlines

^{(Ceased operations in 2013)

Note – Saha Airlines is a wholly owned subsidiary of the Air branch of the IRGC.}

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
Safiran Airlines ^{(Ceased operations in 2013)}	Tehran (THR)	4

Airline

Main Base

Current Active Fleet

Safiran Airlines

^{(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
Yas Air ^{Note - Owned by PARS Aviation Company who supply aviation repair services to the IRGC and others.}	Tehran (THR)	2

Airline

Main Base

Current Active Fleet

Yas Air

^{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.

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Airlines in Iran and the effect of EU and US Sanctions (Post-Implementation Day)

Published

Written By

Summary

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

Relevant EU Sanctions

Relevant US Sanctions

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