Doing business with Iran

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United Nations Sanctions (Iran) Regulations 2025

New Zealand has passed regulations to implement United Nations Security Council sanctions on Iran. As a result of Iran’s non-compliance with its nuclear obligations, the sanctions were reinstated in September 2025, following the triggering of the snapback mechanism under the Joint Comprehensive Plan of Action (JCPOA).

The United Nations Sanctions (Iran) Regulations 2025(external link) introduce a range of obligations on New Zealand persons (a person who is in New Zealand or a New Zealand citizen whether or not they’re in New Zealand) doing business with Iran including: 

  • Prohibitions on certain dealings related to designated persons;
  • A duty to exercise vigilance when doing business with entities incorporated in Iran or subject to its jurisdiction;
  • A compulsory business registration scheme (which will enter into force on 1 February 2026);
  • A requirement to keep business records for at least seven years;
  • Import, export and procurement bans relating to nuclear weapon, missile or enrichment-related goods, and to arms;

More detailed guidance on the Regulations is available here [PDF, 321 KB].

New Zealand persons are required to comply fully with the Regulations implementing UNSC sanctions. Given the wide scope of the Regulations, and the penalties for non-compliance, it is recommended that anyone contemplating doing business with Iran obtain independent legal advice before engaging in business with people in Iran, or with entities that are incorporated in Iran or subject to its jurisdiction.

New Zealand’s compulsory registration scheme is designed to ensure that legitimate trade with Iran can continue, and that people engaging in such trade exercise the necessary degree of vigilance. From 1 February, a registration scheme will operate: New Zealand persons and entities intending to do business with Iran will be required to first register with the Ministry of Foreign Affairs and Trade. More details and the registration form will be circulated in advance of the requirement coming into effect.  

Other factors to consider

New Zealand businesses are also advised to consider the potential impact on their business of foreign ‘autonomous’ sanctions regimes. In addition to UNSC sanctions, some countries, such as the United States, United Kingdom, Australia and European Union have imposed additional, unilateral sanctions on Iran. New Zealand businesses trading with Iran are advised to seek independent legal advice to ensure that their business does not contravene other sanctions regimes.

A number of Iranian individuals and entities have been sanctioned under the Russia Sanctions Act in connection with support for Russia’s war in Ukraine. The Act prohibits New Zealand individuals and entities from having dealings with sanctioned persons, assets, services and securities. More information on the Russia Sanctions Act is available here.

Exporters to Iran must also comply with New Zealand’s Export Controls regime, which prohibits the export of military, dual use and catch-all goods that may harm New Zealand’s security or national interests. More information is available here.

The reimposition of UNSC sanctions may add to existing b by New Zealanders seeking to do business in Iran, for example in the area of banking and insurance. New Zealanders are advised to consult their banks and insurers to confirm comfort levels with facilitating Iran-related trade prior to making any commitments.

Background on Iran sanctions

New Zealand and the broader international community hold long-standing concerns about Iranian nuclear proliferation. In 2010, the UNSC adopted Resolution 1929 which expanded previous sanctions. This included sanctions covering the oil industry, financial industry and technology transfer and a new obligation on all UN member states to require their nationals to "exercise vigilance" when doing business with people in Iran, or with people or entities that are subject to Iranian jurisdiction or control, if there are reasonable grounds to believe that such business could contribute to Iran’s proliferation-sensitive nuclear activities, the development of nuclear weapon delivery systems or to violations of certain UNSC Resolutions.

The Joint Comprehensive Plan of Action (JCPOA) was signed in 2015, providing a pathway for the lifting of sanctions in exchange for Iran limiting its nuclear programme. In 2016, the International Atomic Energy Agency (IAEA) reported to the UN Security Council that Iran had taken a series of measures called for by the JCPOA, leading to the termination of UN sanctions. As a result, New Zealand lifted sanctions and removed the requirement for those doing business with Iran to register with the Ministry of Foreign Affairs and Trade.

The JCPOA included a ‘snapback’ provision that allowed the original participants to unilaterally trigger the reimposition of UN sanctions, if Iran was not complying with the deal. Once triggered, the UNSC would have 30 days to pass a resolution to continue sanctions relief, or the previous sanctions would automatically ‘snap back’ into place.

In late August 2025, the UK, France and Germany triggered the ‘snapback’ process, citing Iranian breaches, including with regard to uranium enrichment. No UNSC resolution was passed continuing sanctions relief, and as a result, the sanctions outlined in UNSC Resolutions 1737 (2006), 1747 (2007), 1803 (2008) and 1929 (2010) were reimposed on 28 September.

New Zealand takes seriously its obligations as a UN member to implement UNSC sanctions. We implement UN sanctions in regulations made under the United Nations Act 1946. 

Get legal advice

New Zealand persons must fully comply with the sanctions regulations. Given the technical nature of the regulations, and the penalties for non-compliance, it’s essential you get independent legal advice if you are contemplating doing business with Iran. This guidance material does not constitute legal advice. MFAT is not responsible for any loss or damage caused to any person relying on this material.

Contact us

If you have questions or concerns about sanctions on Iran, please email sanctions@mfat.govt.nz.

If you have general questions about doing business in Iran, call New Zealand Trade and Enterprise on 0800 555 888, or email exporthelp@nzte.govt.nz.

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