EU: Update on Iran sanctions | KPMG | GLOBAL

EU: Update on Iran sanctions, dual-use list for export controls

EU: Update on Iran sanctions

The next step concerning sanctions relief for Iran and related changes in the EU dual-use list for export controls would be the “implementation date.”


Related content

Background: Iran sanctions relief

A critical date related to sanction relief for Iran is 18 October 2015. That is the date when the E3 / EU+3 (United States, United Kingdom, Germany, France, Russia, and China) and Iran began to make arrangements and preparations for the implementation of a “joint comprehensive plan of action” intended to provide for comprehensive lifting of all worldwide sanctions related to Iran’s nuclear program. 

  • For Iran, 18 October 2015 represents the start of the implementation of its nuclear-related commitments. 
  • The EU fulfill its part of the agreement by adopting a legislative framework for lifting all of its nuclear-related economic and financial sanctions.  
  • The United States has taken a different approach. President Obama issued a memorandum directing the relevant government agencies to prepare to lift U.S. anti-proliferation sanctions; however, all actions depend on Iran’s follow-up. 

The lifting of sanctions by the EU and the United States will depend on the  “implementation day” which will be when the International Atomic Energy Agency (IAEA) verifies that Iran has taken all of the key nuclear-related steps. With “implementation day,” it would be anticipated that there would be a (partly) lifting of the EU / U.S. nuclear-related sanctions against Iran. It is expected this date will be in the range of five months to 10 months. Until “implementation day,” all sanctions remain in place, and nothing changes as regards the legal requirements prohibiting exports to Iran.

Update EU dual-use list for export controls

The European Commission on 12 October 2015 adopted a regulation amending Council Regulation (EC) No 428/2009—the EU dual-use regulation. The updated EU dual-use list for export controls:

  • Takes account of the latest scientific, technological, industrial, and commercial developments
  • Aims to protect the competitiveness of EU export industries
  • Implements over 100 amendments to the controls made by the multilateral regimes in 2014 (e.g., the Wassenaar Arrangement and Missile Technology Control regimes)
  • Reflect changes relating to the control of machine tools, avionics technology and aircraft wind-folding systems, spacecraft equipment and civil UAVs2 (drones) as well as the removal from control of certain encrypted information security products


Read a November 2015 report prepared by the KPMG member firm in the Netherlands: Update Iran Sanctions – EU Dual-Use

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal