Iran Sanctions: Which Sanctions Will Be Lifted?

SIBOS Banner 2

Sanctions against Iran are to be lifted. Not all of them, but most of them, according to the negotiations so far. At this point in time, nobody knows exactly what changes will take place and won’t do until the sanctions are actually lifted.

Who will decide? The definitive list will come from the regulators, including the big four – the US’s Office of Foreign Assets Control (OFAC), the European Union (EU), the United Nations (UN) and Her Majesty’s Treasury (HMT) – in conjunction with the other agencies involved.

To help financial institutions prepare for the outcome, we have conducted some research and made predictions using our extensive risk data.

Here we take a look at which entities might be lifted (entities refer to  individuals, corporations and vessels).

At the moment, OFAC has 770 entities on its list relating to Iran. We think that 505 of those sanctions will be lifted, with 245 remaining in place. A number of those entities are either aircraft or vessels. We estimate that all 55 of the aircraft will be removed once the deal takes effect and 153 of the 227 vessels listed will be removed, leaving 74 sanctioned entities still in place. That means, we think, that 32% of OFAC sanctions will remain in place with the remaining 68% being lifted.

It is important to note that OFAC will lift sanctions associated with the nuclear proliferation blacklist – NPWMD, the non-proliferation weapons of mass destruction; IFSR, the Iranian Financial Sanctions Regulations and the Iran Sanctions Act of 1996.

Certain sanctions are not covered by the JCPOA and will continue to remain sanctioned by OFAC. Those sanctions are any tied to terrorist financing, human rights abuses and drug trafficking. It is a similar situation for the other major sanction lists, including HMT, UN and EU lists.

So, which of the 656 entities currently on the EU list are likely to be lifted? We think 559 of them will go – those dealing specifically with nuclear proliferation. The remaining 97 that we think will not be lifted, relate to Human Rights sanctions.

Currently, the EU lists 477 corporations and 179 individuals relating to Iranian sanctions. We predict that the combined total of 656 sanctioned entities will be lifted.

On to the UN list, currently holding 336 Iranian entities. All these entities deal specifically with nuclear proliferation, so presumably, all sanctions will be lifted. We also predict that the 336 sanctioned entities – 222 corporations and 114 individuals – will have their sanctions lifted.

The HMT list currently has 657 Iranian entities, 563 of which deal specifically with nuclear proliferation and will presumably be lifted. That leaves 94 sanctions related to Human Rights sanctions which we do not think will be lifted. That means 14% of HMT sanctions will remain in place, with the other 86% being lifted.

That is what Accuity’s data suggests. To make the statistics easier to visualise, we have created an infographic which breaks down our predictions.

Looking back:

Post 1. Why banks still need a comprehensive sanctions programme

Looking ahead:

Post 3. The differences in scope between the regulators

Post 4. The AML policy implications of the deal

Post 5. What happens when Iranian banks reconnect to SWIFT? 



At this stage, nobody knows exactly what changes will take place when Iranian sanctions are lifted. The definitive list will come from the regulators, including the big four (OFAC, EU, UN, HMT) as well as the other agencies which are involved. While the circumstances evolve and the world awaits clarification, Accuity’s infographic aims to break down the sanctions lists and make some predictions based on Accuity’s extensive risk data.