On 18 November 2024, the UK Government imposed an asset freeze on the state-owned national airline of Iran, Iran Air, and the state-owned national shipping carrier of Iran, the Islamic Republic of Iran Shipping Lines (IRISL).1
The sanctions follow the UK Government's announcement on 10 September 2024 that it would implement new and significant measures against Iran and Russia in response to Iran's transfer of ballistic missiles to Russia, in coordination with other nations such as Germany and France.2 The UK, France and Germany – together, the "E3" – also issued a joint statement condemning Iran's export and Russia's procurement of Iranian ballistic missiles and citing such activity as a "direct threat to European security".3
Since Russia's invasion of Ukraine in 2022, the UK Government has sanctioned both Russian and non-Russian actors for their role in aiding Russia's war effort. The sanctions against Iran Air and IRISL demonstrate that the UK Government, like the United States and European Union, is increasingly targeting persons outside of Russia – in particular in China and Iran – who are undermining the effectiveness of the Russia sanctions regime.
The sanctions against Iran Air and IRISL, together with other recent actions also point to the trajectory of broader sanctions being imposed on Iran. Under the terms of the 2015 Iran nuclear agreement, formally known as the Joint Comprehensive Plan of Action (JCPOA), Iran agreed to limit its nuclear activities in exchange for sanctions relief. Sanctions against Iran were due to be lifted on 18 October 2023 under the JCPOA, which would have allowed Iran to import and export certain ballistic missiles, but the E3 refused to do so on account of Iran's alleged non-compliance with the JCPOA.
Footnotes
1. UK sanctions Iran for aiding Russia's illegal war in Ukraine, as Foreign Secretary chairs UN Security Council press release 18 November 2024, available at: https://www.gov.uk/government/news/uk-sanctions-iran-for-aiding-russias-illegal-war-in-ukraine-as-foreign-secretary-chairs-un-security-council
2. UK and partners respond to Iran's transfer of ballistic missiles to Russia press release, 10 September 2024, available at: https://www.gov.uk/government/news/uk-and-partners-respond-to-irans-transfer-of-ballistic-missiles-to-russia
3. Iranian transfers of Ballistic Missiles to Russia: UK, France and Germany joint statement, 10 September 2024, available at: https://www.gov.uk/government/news/iranian-transfers-of-ballistic-missiles-to-russia-uk-france-and-germany-joint-statement
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