Removal of sanctions against Iran

Tuesday 25 August 2015

Authors: Ian Gault and Andy Glenie

​​​​Since 2006, the international community led by the United Nations (UN) Security Council has imposed a range of sanctions against Iran in response to its nuclear development programme.1

On 14 July 2015, the five permanent members of the UN Security Council (the United States, United Kingdom, France, China and Russia) plus Germany and the European Union reached a deal with Iran called the Joint Comprehensive Plan of Action (JCPOA). The JCPOA provides a timeline for the removal of sanctions upon verification by the International Atomic Energy Agency (IAEA) that Iran’s nuclear weapons programme has been dismantled and that all nuclear materials are being used solely for peaceful purposes. The plan also provides that any non-compliance by Iran will result in automatic “snap back” of the sanctions regime. The IAEA’s report is expected to be delivered in early 2016, assuming full cooperation by Iran.

On 20 July 2015, the UN Security Council passed Resolution 2231 endorsing the JCPOA and adopting its provisions for the removal of sanctions.2

The position in New Zealand

New Zealand’s legislative power to impose sanctions is set out in section 2 of the United Nations Act 1946. To date, all sanctions imposed by New Zealand have followed those imposed by the UN Security Council and are implemented by regulations made under the Act. New Zealand’s sanctions against Iran are presently set out in the United Nations Sanctions (Iran) Regulations 2010.

Once the UN sanctions against Iran are lifted by the Security Council, the New Zealand Government will remove its own sanctions to comply with the Security Council’s regime.3

How will this affect your business?

While New Zealand businesses are currently allowed to trade with Iran, the primary effect of the removal of sanctions will be that businesses will no longer need to register with the Ministry of Foreign Affairs and Trade. This is likel​y to facilitate new trade and investment opportunities by reducing the administrative burden of doing business with Iran. Sanctions relating to various types of military equipment (including ballistic missile-related technology) will also be removed. New Zealand’s export controls under the Strategic Goods List for certain military and dual-use goods, requiring the consent of the Secretary of Foreign Affairs and Trade, will continue to apply.4

If you would like to discuss the possible trade and investment implications of New Zealand’s sanctions regime for your business, please contact us.​

1 The sanctions are set out in UN Security Council Resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008), 1929 (2010) and 2224 (2015).

2 UN Security Council Resolution 2231(2015).

3 Articles 25 and 41 of the Charter of the United Nations 1945 respectively provide that member states agree to accept and carry out the decisions of the Security Council and the Security Council may call upon member states to apply any measures to give effect to its decisions, including the use of sanctions.

4 Customs Export Prohibition Order 2014, implementing the Wassenaar Arrangement on Export Controls for Conventional Arms and Dual Use Goods and Technologies.​


This publication is necessarily brief and general in nature. You should seek professional advice before taking any action in relation to the matters dealt with in this publication.

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