Sanctions against Iran

There are several sanctions regimes in effect against Iran that one should be aware of. Below is a non-exhaustive list of current prohibitions and restrictions against Iran that are relevant to the maritime sector. For further information regarding the specific wording of the individual prohibitions and applicable exemptions, please refer to the relevant legal instruments.

Companies are encouraged to seek legal counsel as needed, for example, if they engage in economic activities that could have direct or indirect ties to Iran.

• Council Regulation (EU) 2023/1529 of 20 July 2023 concerning restrictive measures in view of Iran’s military support to Russia’s war of aggression against Ukraine and to armed groups and entities in the Middle East and the Red Sea region as well as Iran’s actions undermining freedom of navigation in the Middle East
• Council Regulation (EU) No 267/2012 of 23 March 2012 concerning restrictive measures against Iran and repealing Regulation (EU) No 961/2010

Please also note that the EU’s and the U.S.’s approaches to sanctions differ significantly. Read more about current U.S. sanctions at U.S. Department of the Treasury.

On September 29, the EU reimposed a number of sanctions against Iran through the adoption of EU Council Regulation 2025/1975. The reintroduction is in response to Iran’s failure to comply with the Iran nuclear deal (JCPOA) of July 14, 2015, which eased a number of UN sanctions against Iran.

The Danish Maritime Authority takes the general legal view that it is permissible to assist ships in connection with force majeure events, in accordance with Denmark’s international obligations, including considerations of safety at sea and environmental protection. This means taking immediate action to prevent or mitigate an incident that is likely to have a serious and significant impact on human health and safety or the environment.

This legal interpretation may differ from the prevailing interpretation in other countries; therefore, one should always familiarize oneself with the relevant jurisdiction where an operation may take place, in whole or in part.

If applicable sanctions are disregarded in connection with the provision of assistance based on force majeure, the incident must be reported immediately to sanktioner@dma.dk

There is a ban in place on providing or brokering insurance and reinsurance services to, among others, the Iranian government or Iranian individuals and entities, including public bodies and companies. (EU Council Regulation 267/2012, Article 35)

There is a ban in place on providing or brokering insurance and reinsurance services to, among others, the Iranian government or Iranian individuals and entities, including public bodies and companies. (EU Council Regulation 267/2012, Article 35)

There are prohibitions in place regarding the financing of Iranian persons, entities, or bodies involved in, among other things, the production of crude oil and natural gas, the refining of fuels, or the liquefaction of natural gas, or involved in the petrochemical industry. (Council Regulation (EU) No. 267/2012, Article 17)

The sanctions prohibiting the provision of and freezing of financial resources with respect to designated entities remain in effect—including both the direct and indirect provision of financial resources to designated persons, entities, or bodies. The Danish Business Authority is the competent authority in this regard; however, we would like to point out that the prohibitions cover a number of maritime companies.

Specifically, the freezing obligations include, among other things, the obligation to freeze funds and resources held by the Islamic Republic of Iran Shipping Lines (IRISL) and designated entities owned or controlled by IRISL. Furthermore, it is prohibited to load or unload cargo onto or from ships owned or chartered by IRISL or by such entities in the ports of Member States. (Council Regulation (EU) No. 267/2012, Article 23, and Council Regulation (EU) No. 2023/1529, Article 3)

It is prohibited to provide bunkering, ship supplies, or other ship-related services to vessels directly or indirectly owned or controlled by Iranian persons, entities, or bodies, if the service provider has information that provides reasonable grounds to conclude that the vessels in question are transporting goods subject to the prohibitions on supply, sale, transfer, or export set forth in the Regulation, with exceptions for services provided for humanitarian and security purposes. (Council Regulation (EU) No 267/2012, Article 37)

Effective January 1, 2026, there will be a ban on the provision of certain services to ships flying the Iranian flag or that are directly or indirectly owned, chartered, or operated by Iranian persons, entities, or bodies. These services relate in particular to classification services of any kind, as well as design, certification, and inspection services and several related services. (Council Regulation (EU) No. 267/2012, Article 37a)

It is also prohibited to make vessels intended for the transport or storage of oil and petrochemical products available to Iranian persons, entities, or bodies, unless the ship provider has taken appropriate measures to prevent the ship from being used to transport oil or petrochemical products originating in or exported from Iran. (EU Council Regulation 267/2012, Article 37b)

Please note in particular that it is prohibited to knowingly and intentionally participate in activities intended to, or resulting in, the circumvention of the applicable prohibitions.

A comprehensive overview of which authorities are responsible for which aspects of the sanctions can be found at Ministry of Foreign Affairs website (Competent Authorities).