Doing business with Iran

Upcoming Regulatory Changes to Implement Iran Sanctions

On 28 September 2025, United Nations Security Council (UNSC) sanctions on Iran were reinstated. This follows the triggering of the snapback mechanism under the Joint Comprehensive Plan of Action (JCPOA). New Zealand remains deeply concerned about Iran’s non-compliance with its nuclear commitments and is moving ahead to promptly implement the sanctions.

The UN sanctions include: a range of prohibitions related to Iranian nuclear and military activities; an asset freeze for persons and entities designated by the UNSC; and a duty to “exercise vigilance” when doing business with Iran.

As a UN Member State, New Zealand is bound to implement sanctions imposed by the UNSC. Work is currently under way on the necessary regulatory changes to implement the UNSC obligations in New Zealand law on New Zealanders doing business with Iran.

When these UN sanctions on Iran were originally imposed in 2010, New Zealand implemented the duty to “exercise vigilance” through a compulsory registration scheme, whereby New Zealanders registered with the Ministry of Foreign Affairs and Trade if they intended to do business with people in Iran, or with Iranian entities or persons acting on their behalf.

We expect to share more implementation details and guidance on exercising vigilance when doing business with Iran before the end of October. We advise New Zealanders to apply heightened due diligence in reviewing any ongoing transactions during this interim period.

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. The Resolution also created 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.

New Zealand implemented the requirement to exercise vigilance through a compulsory registration regime. The scheme was designed to ensure that legitimate trade with Iran could continue, and that people engaging in such trade exercised the necessary degree of vigilance. Businesses were also required to keep records of their business with Iran, and notify any material changes to the business.

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 they believed that 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 high level 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.

Have a question or concern?

If you have any questions, please get in touch with the team at Sanctions@mfat.govt.nz.

Russia Sanctions Act

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.

Additional Requirements

New Zealanders doing business with Iran must still comply with the regulations regarding prohibited exports, including the export of weapons and of strategic goods (military and dual-use goods as listed in the New Zealand Strategic Goods List).

New Zealand’s regulations also still incorporates the asset freeze on individuals and entities designated on the 2231 List(external link).

Some countries, such as Australia, Canada, the European Union, the United States, and others, can impose restrictive measures unilaterally. These may be in addition to, or in the absence of, sanctions adopted by the UN Security Council. Such measures are often known as “autonomous” or “unilateral” sanctions. New Zealand businesses trading with countries subject to autonomous sanctions are advised to seek independent legal advice to ensure that their business does not contravene other sanctions regimes, including the remaining United States and European Union sanctions.

United States withdrawal from the JCPOA

On 8 May 2018 President Trump announced(external link) that the United States would withdraw from the JCPOA (Joint Comprehensive Plan of Action) - known as the “Iran nuclear deal” - over the next 90-180 days and reinstate autonomous sanctions against Iran. By 4 November 2018, all of the sanctions that the United States had in place before the JCPOA will have been reimposed and in effect.

The United States Treasury has released guidelines(external link) explaining how the United States will reinstate the sanctions it had previously eased as a result of the JCPOA.

New Zealanders doing business with Iran should note the potential impact of US sanctions, including the planned reinstatement by 6 August 2018 and 4 November 2018 of “secondary” sanctions that apply to non-US persons. These sanctions apply to a wide range of transactions.

Exporters of “humanitarian goods” to Iran such as dairy products, some beverages, meat, other food or medicine, should take particular note of the US policy toward these goods. The United States Treasury “Guidance on the Sale of Food, Agricultural Commodities, Medicine, and Medical Devices by Non-U.S. Persons to Iran” can be found its website(external link) (as at 3 August 2018). This guidance, issued in 2013, states that sales of “food, agricultural commodities, medicine, and medical devices” to Iran will “not trigger sanctions under U.S. law”.

Other factors for New Zealand exporters to consider

Iran will remain a challenging market in which to do business. An opaque regulatory environment, weak commercial law and IP protection, very high tariff levels and problems with corruption mean that New Zealand companies looking to do business in Iran will need to do their homework. Finding the right local partner will be critical.

New Zealanders are advised to consult their banks to confirm comfort levels with facilitating Iran-related trade prior to making any commitments.

New Zealand has also taken a number of actions in response to recent developments in Iran.

Get legal advice

New Zealanders 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 about sanctions or the requirements imposed by the United Nations (Iran – Joint Comprehensive Plan of Action) Regulations 2016(external link) or doing business with Iran, email: iranenquiries@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.