Sanctions against Iran

There are several sanctions regimes in place against Iran that should be noted.

The Danish Maritime Authority cannot provide specific advice to individual companies on how to comply with the sanctions. In this regard, the Danish Maritime Authority recommends that companies seek legal advice.

Overview

There are several sanctions regimes in force against Iran that you should be aware of. Below there is a non-exhaustive list of current prohibitions and restrictions against Iran with maritime relevance. For further information, please refer to the legal acts for the specific wording of the individual prohibitions and applicable exemptions.

Companies are encouraged to seek legal assistance if necessary, for example if they have economic activities that could have direct or indirect links to Iran. 

Please also note that the EU and US sanctions policies differ significantly. Read more about current US sanctions at the U.S. Department of the Treasury.

On September 29, 2025, the EU reintroduced a number of sanctions against Iran with the adoption of EU Council Regulation 2025/1975. The reintroduction is based on Iran's failure to comply with the Iran nuclear agreement (JCPOA) of July 14, 2015, which eased a number of sanctions against Iran.

Force majeure situations

The Danish Maritime Authority's general legal opinion is that it will be permissible to carry out repairs and assist ships in relation to force majeure events in accordance with Denmark's international obligations, including consideration for maritime safety.

This legal opinion may differ from the prevailing opinion in other countries, which is why you should always familiarize yourself with the relevant jurisdiction where an operation may take place in whole or in part.

Trade restrictions

A number of trade restrictions have been imposed, including on the transport of natural gas, oil, and petrochemical products if the goods originate in Iran or are exported from Iran to another country. (EU Council Regulation 267/2012, Articles 11–14 and 14a)

Several of the trade restrictions also prohibit the provision of technical assistance in relation to the supply of the goods covered. In addition, certain trade restrictions prohibit the provision of insurance and reinsurance in relation to the prohibitions.

Insurance and reinsurance services

There is a ban on providing or brokering insurance and reinsurance services to, among others, the Iranian government or Iranian persons and entities, including public bodies and companies. (EU Council Regulation 267/2012, Article 35)

Financing of the petrochemical industry

There are prohibitions in force relating to the financing of Iranian persons, entities, or bodies involved in, among other things, the production of crude oil and natural gas, the refining of fuels, or the liquefaction of natural gas, or involved in the petrochemical industry. (EU Council Regulation 267/2012, Article 17)

Making available of funds and asset freezing

The sanctions prohibiting the making available of funds and obligating asset freezing in relation to designated entities remain in force - both direct and indirect making available of funds to designated persons, entities or bodies. The Danish Business Authority is the competent authority in this regard, but we would like to point out that the prohibitions cover several maritime companies.

The freezing obligations include, among other things, the obligation to freeze funds and resources held by Islamic Republic of Iran Shipping Lines (IRISL) and designated entities owned or controlled by IRISL. It is also prohibited to load or unload cargo onto or from ships owned or chartered by IRISL or such entities in the ports of Member States. (EU Council Regulation 267/2012, Article 23 and EU Council Regulation 2023/1529, Article 3)

Bunkering, ship supply, and other ship-related services

It is prohibited to provide bunkering, ship supply, or other ship-related services to ships that are directly or indirectly owned or controlled by Iranian persons, entities, or bodies, if the service provider has information that gives reasonable grounds to determine that the ships in question are transporting goods covered by the supply, sale, transfer, or export prohibitions in the regulation, with exceptions for services for humanitarian and security purposes. (EU Council Regulation 267/2012, Article 37)

Classification and other services

From January 1, 2026, the provision of a number of services to vessels flying the Iranian flag or owned, chartered, or operated, directly or indirectly, by Iranian persons, entities, or bodies will be prohibited. The services relate in particular to classification services of any kind, as well as design, certification, inspection services and several related services. (EU Council Regulation 267/2012, Article 37a)

It is also prohibited to make ships intended for the transport or storage of oil and petrochemical products available to Iranian persons, entities, or bodies, unless the ship provider has taken appropriate measures to prevent the ship from being used to transport oil or petrochemical products originating in or exported from Iran. (EU Council Regulation 267/2012, Article 37b)

Circumvention of sanctions

It should be noted that it is prohibited to participate, knowingly and intentionally, in activities the object or effect of which is to circumvent the prohibitions in force.

Other authorities

A complete overview of which authorities are responsible for which parts of the sanctions can be found on the website of the Ministry of Foreign Affairs (Responsible authorities).

Contact

Maritime Regulation and Legal Affairs
Sanctions team