Sanctions Responsibility for Iran Shipments

Short Answer — Sanctions compliance

When shipping to Iran, responsibility for ensuring that the cargo, the parties including the buyer, and the payment comply with sanctions and export control regimes lies with the shipper and the buyer. UN sanctions on Iran came back into force at the end of September 2025, the EU has reimposed its related measures and the US OFAC programme remains in place. This entry is general information, not legal advice.

What does sanctions compliance mean?

Sanctions compliance means that the parties verify that the product, the buyer, any intermediaries, the end user and the payment channel in an export transaction do not conflict with the applicable sanctions lists and export control rules. The assessment is made separately for each transaction; the same product may be shippable to one buyer and not to another. This entry outlines the subject in general terms and is not a substitute for legal advice.

What are the main regimes affecting Iran?

Regime	Current status	Official source
United Nations	On 19 September 2025, the UN Security Council did not adopt the draft resolution that would have continued sanctions relief (4 in favour, 9 against, 2 abstentions). Following the snapback process initiated by France, Germany and the United Kingdom, the pre-2015 UN sanctions came back into force at the end of September 2025.	UN press release SC/16175
European Union	After the return of the UN sanctions, the Council of the EU reimposed its nuclear-related restrictive measures at the end of September 2025. They cover travel bans, asset freezes and measures in the trade, finance and transport sectors.	EU Sanctions Compliance Helpdesk
United States	The OFAC Iran programme is based on the Iranian Transactions and Sanctions Regulations (ITSR, 31 CFR Part 560) and executive orders. New determinations were made in 2026 as well: on 24 August the aviation, digital assets, gold, maritime and technology sectors, and on 1 October the automotive and railway sectors, were brought under EO 13902.	OFAC Iran page

How is responsibility divided between the parties?

Shipper (exporter): Classification of the product, dual-use checks, verification of buyer and end-user details, sanctions clauses in the contract.
Buyer: Import licences on the Iranian side and declarations about its own status and payment channel.
Payment: The Turkish Ministry of Trade's October 2024 note on Iran draws attention to restrictions on bank transfers and letters of credit. Whether a payment method is acceptable is assessed by the parties together with their banks; the availability of instruments such as a letter of credit should be checked in advance.
Customs broker: Prepares the declaration and documents and supports the exporter in classifying the product; the assessment of the commercial parties remains with the exporter.
Carrier: Performs the contract of carriage. Accepting a load for carriage does not certify that the cargo or the parties comply with sanctions regimes.

Which questions should the shipper answer before shipping?

Is the buyer, an intermediary or the end user on UN, EU or OFAC lists?
Is the product dual-use, or does it fall into a prohibited or licensable sector? See dual-use goods exports.
Is the product covered by Iran's own import bans? See Iran import ban.
Through which channel and which party will payment be made, and does that channel comply with the relevant regimes?
Does the sales contract contain clauses on delivery terms and on changes in sanctions? For delivery terms, see the Incoterms entry.
Are the records of the assessment kept for any questions that may be asked later?

What needs extra attention for cargo loaded in Europe?

An exporter established in the EU is directly subject to EU measures, even if the cargo travels via Turkey. National export control authorities such as BAFA in Germany handle licence applications. The licence position in the loading country should therefore be settled before the truck sets off. The route for cargo from Europe is described on the Europe to Iran road freight lane page.

Which sources should be monitored regularly?

For the current position, follow UN Security Council announcements, the EU Sanctions Compliance Helpdesk, OFAC's Iran page and, in Turkey, publications of the Ministry of Trade. Because the regimes can change at short notice, the assessment made at the contract date is reviewed again on the loading date.

Frequently Asked Questions

Does the carrier check whether the cargo complies with sanctions?

A contract of carriage does not certify that the cargo, the parties or the payment comply with sanctions regimes. The compliance assessment is the responsibility of the shipper and the buyer; where there is doubt, a specialist sanctions lawyer should be consulted.

Are exports from Turkey to Iran completely banned?

No. Trade between Turkey and Iran continues; according to Turkish Ministry of Trade data, Turkey's merchandise exports to Iran were USD 3.229 billion in 2023. Sanctions target specific persons, sectors, products and payment transactions, so each transaction is assessed on its own terms.

Are there separate rules for food and medicine exports?

OFAC has separate guidance on sales of food, agricultural commodities, medicine and medical devices to Iran by non-US persons. This guidance does not automatically authorise every transaction; its scope, the parties and the payment terms must be assessed together.

Sources

Published: 19.10.2026 · Voltim Global