Exporting to Iran

Question posted by Malcolm Blogg, on behalf of Mariner Systems (UK) Ltd in RG41

My company has been requested to supply a TFT monitor to a marine engineering company in Iran. Are there any export controls in force? We have not previously been requested to supply goods to Iran. Our products are approved for use in the commercial maritime industry. Thanks in advance for any help you can provide.

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I am sure there are. Have a look at this link as a starter:

http://www.bis.gov.uk/exportcontrol

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Gary Wilcox, on behalf of JAG UFS Intl Ltd in TW13.

Dear Malcolm,
There are restriction on some items going into Iran but a TFT Montior is not listed as restricted. However, the goods may need an import license from the Ministry of Commerce and for some goods other ministries may be required to issue a permit. This is the responsibility of the importer.
In order to export to Iran you will need to have an "EC Certificate of Origin" prepared stamped by the chambers of commerce. If the shipment is valued at over $20,000.00 then a pre-shipment inspection will be required by an authorised agency.
I hope this answer is of some use, if you need any further information, please do not hesitate to contact me.
Many thanks
Gary

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Mike Barnes, on behalf of Despatch Point Limited in RG22.

Hi Malcolm
There are many controls on trade between UK and Iran but you also need to check situation with your Bank as some have restrictions and sanctions on trade with certain countries. For example we bank with Lloyds TSB and we have been told we cannot trade with any Iranian company or receive money from Iran, or our accounts would be closed. We used to do a lot of shipping by air and sea to Iran for one client but they also are Lloyds customers and have had to cease. There are certainly services to Iran but we can’t assist on this one, good luck.
Mike Barnes

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Malcolm
I work for the Export Control Organisation, part of the Department for Business, Innovation and Skills (BIS). ECO is the UK's export licensing authority for military and dual-use goods.

Guidance about export controls is now published on https://www.gov.uk.
This includes the latest position concerning sanctions imposed by the international community on Iran - see the guidance published at: https://www.gov.uk/sanctions-on-iran and you should read this carefully as the prohibitions on Iran are very extensive.

If the items you are exporting (ie TFT monitors) are commercial, off-the-shelf products and have not been specially designed or modified for military use then these items will not be listed on either the UK Strategic Export Control Lists or in specific sanctions lists and hence controlled for export purposes.
If however the items are modified in some way (eg plug is changed to military specification) then the item will be listed and hence controlled and require a licence.

If the items are not listed on the Control Lists you do also need to be aware of end-use controls - see https://www.gov.uk/weapons-of-mass-destruction-wmd-end-use-control and
https://www.gov.uk/iran-list-wmd-end-use-control

The ECO operates an "End-User Advice Service" where you can seek advice on the end-user company you are intending to export to. This advice needs to be requested online via the ECO's SPIRE export licensing database - https://www.spire.bis.gov.uk

Mike Barnes, who responded earlier, is also totally correct in saying that even if the goods are not controlled (either because they are listed or on the grounds of end-use), that you need to check the position about exporting to Iran with your bank. Their are financial restrictions for banks, credit and other financial institutions which prohibits all financial transactions and business relationships between UK financial and credit institutions and banks incorporated in Iran.

Edwina

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Malcolm

Two last points.

The ECO has an email update service called 'Notices to Exporters' which includes announcements about arms embargoes, changes to export control legislation and procedures.
See: http://www.bis.gov.uk/policies/export-control-organisation/eco-notices-exporters
You can subscribe to receive these alerts either via email, RSS feed or via Twitter.

HM Treasury's Asset Freezing Unit also operates a separate notification service - see: http://www.hm-treasury.gov.uk/fin_sanctions_index.htm

Edwina

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Malcolm Blogg, on behalf of Mariner Systems (UK) Ltd in RG41.

Many thanks to everyone who has taken the time to respond to my question - it is greaty appreciated.

Malcolm

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Peter Curnow-Ford, on behalf of Viatec Associates Ltd in WC1N.

Malcolm,

Another point re payments etc, a colleague inadverntanly took a Paypal payment from an organisation that bought equipment that ultimately ended up in Iran.

He only became aware when the US Government contacted him with regard to the sale and delivey into Iran and the payments, because PayPal had reported the transacton to the US Federal authorities.

He has now cleared it up and will not be listed as a barred organisation by US Govt. A close call.

Peter

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