UK businesses dealing with Iran or Iran-linked trade face a broader sanctions regime after new restrictions covering energy, maritime activity, software, metals, financial services and other commercial activity came into force on 29 September.
The Iran (Sanctions) (Amendment) Regulations 2026 expand both the UK’s Iran sanctions and Iran nuclear sanctions regimes, introducing additional financial, trade and transport controls alongside new schedules of restricted goods and technology.
The measures extend beyond conventional exports. Prohibitions can also cover supply and delivery through third countries, transfers of technology, making controlled goods available, technical assistance, brokering and associated financial services.
New schedules include energy-related goods and technology, gold and precious metals, graphite and relevant metals, maritime equipment, natural gas, oil and petroleum products, petrochemicals, other restricted goods, and sectoral software and technology.
Companies with exposure to those areas now need to establish whether goods, software, services or transactions that were previously permitted fall within the expanded controls.
The breadth of the regime creates obligations beyond exporters physically shipping products from Britain. UK businesses can encounter sanctions risk through financing, insurance, brokering, technical support, technology transfers and participation in transactions conducted through third countries.
Customer and counterparty screening is therefore only one element of compliance. Businesses also need to understand product end use, the sectors in which customers operate, ownership and control of counterparties and whether services connected to a transaction are restricted separately.
The government has advised exporters to examine the new schedules, review exposure to sectors including energy, software and maritime activity and determine whether proposed transactions are prohibited or require a licence.
Sanctions compliance has become more operationally demanding as different regimes overlap. International businesses can need to consider UK controls alongside measures imposed by the US, EU and other markets, particularly where supply chains, banks, insurers and intermediaries span several jurisdictions.
Financial institutions and professional-services providers are also exposed because restrictions can extend to financing, brokering and ancillary activity. A goods transaction that appears permissible can still become impractical if a bank, insurer or logistics provider is unable to participate.
The new UK measures include enhanced enforcement powers relating to vessels involved in nuclear-related trade. Maritime businesses, commodity traders, freight operators and specialist equipment suppliers are among those likely to need renewed checks.
Licensing remains available in defined circumstances. Specific arrangements have also been provided in connection with the Shah Deniz gas field, which supplies energy to European markets, through relevant general licences.
Those exceptions do not alter companies’ responsibility to establish whether an activity is permitted before proceeding. Government guidance places responsibility for compliance on exporters and other organisations undertaking controlled activity.
Commercial consequences can extend beyond enforcement. Contracts may become difficult to perform where counterparties are designated, banks decline payments, shipping routes change or licences take time to obtain. Sanctions clauses, escalation procedures and documented decision-making therefore form an increasingly important part of cross-border contracting.
Businesses without direct sales into Iran can still be exposed where distributors, customers or intermediaries operate across affected markets. Additional restrictions on sectoral software and technology are particularly relevant to suppliers whose products can be transferred electronically rather than through a physical export shipment.
The amended regime is now in force. Companies exposed to the affected sectors need to assess transactions against the new rules rather than relying on compliance work completed before 29 September, as products, services and relationships that previously sat outside the restrictions may now require a different treatment.
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