Iran sanctions – designated persons list updated

What are your AML obligations?

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On 14 October 2024, HM Treasury published a notice regarding the Iran sanctions regime, which includes an updated list of designated persons. This notice outlines the current individuals and entities subject to sanctions under this regime. For more details, you can refer to the official HM Treasury website to access the full list and any related information.

The sanctions regime targeting Iran is designed to promote compliance with international human rights law and to discourage hostile activities against the UK and other nations. The Regulations impose asset freezes on individuals and entities designated under the Sanctions Act who are deemed responsible for serious human rights violations or involved in hostile actions by the Iranian government.

This approach aims to hold accountable those contributing to human rights abuses and destabilising activities.

As part of the firm-wide risk assessment and client due diligence procedures, practitioners need to bear in mind the risk from geographical factors, which includes cross-checking for any clients from countries that are subject to sanctions and/or proliferation financing.

The CCAB’s AML Guidance for Accountants (AMLGAS) states the following in relation to sanctions:

2.2.6 It should be noted that, because terrorism and funding terrorism are illegal, terrorist property will also be criminal property. The fact that the property involved may be both criminal property and terrorist property does not create a dual reporting obligation. For example, the following are criminal acts that will normally also be terrorist offences if they relate to persons or organisations engaged in terrorism:

  • Failure to comply with a prohibition imposed by a freezing order or enabling any other person to contravene the freezing order; and
  • Dealing with, or making available, funds or economic resources which are owned, controlled by or benefit a designated person (under the Office of Financial Sanctions Implementation (OFSI) list).

2.7.2 The UK has a robust, bespoke regulatory framework in place to combat the threat posed by PF and adherence to this regulatory framework will assist firms in mitigating their PF risk. A key focus is the implementation of UK and UN sanctions regimes on the Democratic People’s Republic of Korea (North Korea/DPRK), Iran and chemical weapons activity. These sanctions measures apply to anyone in the UK’s jurisdiction, action taken by a UK national outside of the UK and to companies incorporated in the UK. Obligations under the measures imposed by the UN are set out in UN Security Council Resolution (UNSCR) 1540 and relevant counter-PF (CPF) measures set out in UK legislation, such as CPF sanctions regimes implemented under Sanctions and Anti-Money Laundering Act 2018 (SAMLA). In addition to UNSCR 1540, a number of other UNSCRs can have some relevance, including UNSCR 1673(2006); and 1810(2008) on non-proliferation in general; and resolutions related to specific countries of proliferation concern, such as UNSCRs 1695(2006); 1718(2006); and 1874(2009) on North Korea; and UNSCRs 1737(2006); 1747(2007); and 1803(2008) on Iran.

Further resources

ACCA AML hub

The UK Sanctions List - GOV.UK