Sanction status

As Iran has repeatedly failed to meet its obligations under the JCPOA since 2019, the “snapback” mechanism of the JCPOA was terminated by Germany, France and the UK on August 28, 2025. (https://www.bundesregierung.de/breg-de/aktuelles/sanktionen-iranisches-atomprogramm-238210) In order to maintain the sanctions relief against Iran, the UN Security Council has not agreed to an extension. Approval has not been given until 28.09.2025.

As a result, all provisions of UN- Resolutions 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008), 1929 (2010) apply in the same way as before the adoption of Resolution 2231 (2015). This means that the UN sanctions against Iran, in particular against the Iranian nuclear program and its financing, are back in force.

The MEBs (and thus the MB) are not subject to any restrictions under sanctions law, as neither beneficial owners nor financial services in the agricultural, food, medical, manufacturing and packaging sectors are covered by the UN sanctions regime.

Following the reintroduction of UN sanctions against Iran, the EU implemented the sanctions directly with EU Regulations 2025/1975, 2025/1980 and 2025/1982 on September 29, 2025. Among other things, comprehensive restrictions came into force, particularly with regard to the nuclear program (including associated natural and legal persons), the petrochemical industry and certain financial institutions. These restrictions apply to the use of accounts and assets.

EU Regulations 2011/359 on human rights, EU Regulation 2012/258 on the prohibition of trade in firearms, EU Regulation 2019/125 on the prohibition of trade in instruments of torture, EU Regulation 2021/821 on dual-use goods and EU Regulation 2012/267 on Iran, including all amending regulations, are relevant and must be taken into account.

With regard to traded goods, it is the responsibility of the respective exporter to check and comply with national and EU export control regulations. This is the responsibility of the respective exporter. In the case of licensing requirements, the exporter must obtain the necessary official licenses and inform MB.

As the MB accompanies financial services in the agricultural, food, medical, manufacturing and packaging sectors and these are not covered by the Annexes to EU Regulation 2012/267, transactions of this type are only subject to notification.

For goods that are covered, for example, by the Annexes to EU Regulation 2012/267 (incl. amending regulations) and EU Regulation 2021/821 (incl. amending regulations) on dual-use goods, authorization requirements may need to be obtained.

Further information can be found at: https://www.bafa.de/DE/Aussenwirtschaft/Ausfuhrkontrolle/Embargos/Iran

With Executive Order 13599 of February 5, 2012, the President of the USA ordered that every Iranian financial institution is subject to US sanctions. As a result, on August 29, 2014, the Office of Foreign Asset Control (OFAC) placed MEB, along with four other previously unsanctioned Iranian banks, on the U.S. Department of Treasury’s Specially Designated Nationals and Blocked Persons List (SDN List). As the SDN listing was made without “Subject to Secondary Sanctions”, “non-US persons” can continue to maintain business relationships with MEBs.

With the conclusion of the negotiations on the Joint Comprehensive Plan of Action (JCPOA) on 16.01.2016, secondary sanctions for “non-US persons” no longer applied. As a result, the MEBs were transferred by OFAC from the SDN list to the newly created 13599 list.

Due to the withdrawal of the United States from the JCPOA agreement, the secondary sanctions regime was reinstated. On 11.10.2018, the MEB was moved from list 12599 back onto the SDN list. MEB (and thus MB) has been on the SDN list of the U.S. Department of the Treasury since 5 November 2018 with reference to the “IRAN” sanctions program (categorization as an Iranian financial institution).

As of November 8, 2018, the company was listed without “Subject to Secundary Sanctions”, meaning that “non-US persons” can maintain business relationships with MEBs without being exposed to the risk of sanctions.

The sanctions status remained unchanged until October 20, 2020. On the basis of Executive Order 13902 (Imposing Sanctions With Respect to Additional Sectors of Iran) dated January 10, 2020, the U.S. Treasury Department determined that sanctions should be applied to the entire Iranian financial sector. As a result, the Middle East Bank was designated as part of the Iranian financial system with the addition “Subject to Secondary Sanctions”. https://home.treasury.gov/system/files/126/13902.pdf

Due to the simultaneously published General License L (GL-L) (https://home.treasury.gov/system/files/126/iran_gll.pdf), this changed SDN status has virtually no impact on MB’s operating activities. The GL-L states that the MB can continue its previous transactions with humanitarian goods on the basis of the aforementioned programs. The restriction to humanitarian transactions with agricultural commodities, food, medicines and medical equipment has been an integral part of MB’s business and risk strategy since the start of its operating activities. From a US perspective, this has the following significant consequences:

– So-called “US persons” (primarily US (controlled) companies, US citizens, green card holders) are not permitted to conduct business activities with the MB. However, an exception applies under certain conditions for transactions in the humanitarian sector (see above).

– For all other persons and companies who are not “US persons”, the SDN listing including the addition “Subject to Secondary Sanctions” means that only transactions in humanitarian goods (agricultural commodities, food, medicines and medical devices) can be processed.

Please note that it is the responsibility of the respective company to check and, if necessary, comply with applicable (US) sanctions regulations and exemptions, whereby any conflicting national or EU anti-boycott regulations must be observed independently by the economic operators.

Further information: https://home.treasury.gov/policy-issues/financial-sanctions/sanctions-programs-and-country-information/iran-sanctions

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