EU designates Iranian persons over domestic human rights situation and supplies of drones to Russia

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Authored by our Global Sanctions, Export Controls and Customs Teams

In October 2022, the EU extended asset freeze restrictions to various Iranian individuals and entities under its human rights sanctions framework against Iran and its sanctions framework against Russia, in response to Iran's supplies of drones to Russia. 

On 17 October 2022, the EU designated eleven individuals of Iranian nationality and four entities under its existing human rights sanctions framework against Iran.1 The designations are a response to the death of Ms. Mahsa Amini, the 22-year-old Iranian woman, on 16 September 2022. According to the EU, the sanctions target persons who are responsible for the death of Ms. Amini and persons who have played a role in the "widespread and disproportionate use of force by the Iranian security forces against nonviolent protestors" during subsequent demonstrations.2 The individuals targeted by the EU asset freeze are various Iranian government officers and officials. The entities are Iran's Morality Police, the Basij Resistance Force, the Cyber Defence Command of the Islamic Revolutionary Guard Corps ("CDC"), and the Law Enforcement Forces of the Islamic Republic of Iran. 

Separately, on 20 October 2022, the EU designated three individuals of Iranian nationality and one Iran-established company under its sanctions framework against Russia.3 These designations relate to supply of Iranian-made Unmanned Aerial Vehicles ("UAVs") by Iran to Russia, which the EU considers as "military support for Russia's unprovoked and unjustified war of aggression against Ukraine".4 The individuals subject to the asset freeze are various Iranian government officers. The entity is Shahed Aviation Industries, which is the company responsible for the design and development of the specific series of UAVs that are used in Russia's actions in Ukraine.

Under the EU asset freeze, all funds and economic resources in the EU owned, held, or controlled by these sanctioned parties must be frozen. This means that any move, transfer, alteration, use of, access to, or dealing with the funds concerned is prohibited if it would result in any change in their volume, amount, location, ownership, possession, character, destination or any other change that would enable the funds to be used.  It also means that economic resources may not be used to obtain funds, goods or services in any way. 

Furthermore, no funds or economic resources may be made available – directly or indirectly – to or for the benefit of the sanctioned parties. 

Both sanctions regimes provide for certain exemptions (not requiring an authorisation) and/or derogations (requiring a prior authorisation) from the asset freeze restrictions.

1 Annex I of Regulation (EU) No 359/2011, as amended by Council Implementing Decision (CFSP) 2022/1956 and Council Implementing Regulation 2022/1955.
Council Press Release, "Iran: EU sanctions perpetrators of serious human rights violations", 17 October 2022; Recital 2 of the preamble of Council Implementing Decision (CFSP) 2022/1956.
3 Annex I of Regulation 269/2014, as amended by Council Implementing Decision (CFSP) 2022/1986 and Council implementing Regulation 2022/1985.
4 Recital 3 of the preamble of Council Implementing Decision (CFSP) 2022/1986.

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