All persons in New Zealand must register with the Ministry of Foreign Affairs and Trade if they intend to do business with people in Iran, or with entities that are controlled by Iranians. This requirement also applies to New Zealand citizens in any place outside New Zealand, and any entity incorporated or constituted under New Zealand law or that is otherwise subject to New Zealand's jurisdiction.
The registration requirement applies to the supply and receipt of both goods and services. The registration requirement also applies to goods and services that are imported from Iran and exported to Iran. It is an offence to do business with Iran without being registered. The registration scheme is provided for in the United Nations Sanctions (Iran) Regulations 2010.
The Regulations implement United Nations Security Council Resolution 1929. Resolution 1929 expands the existing arms embargo in respect of Iran, bans Iranian investment in uranium mining, extends existing travel restrictions, and extends the existing asset freeze and financial sanctions in respect of Iran. Resolution 1929 also imposes an obligation on states to require their nationals to "exercise vigilance" when doing business with Iran, to ensure that they do not contribute to violations of specified Security Council Resolutions relating to Iran.
New Zealand has decided to implement the obligation to require its nationals to "exercise vigilance" through a compulsory registration scheme, administered by the Ministry of Foreign Affairs and Trade. New Zealand's implementation of Resolution 1929, through the Regulations, is designed to ensure that legitimate trade with Iran may continue, and that people engaging in such trade exercise the necessary degree of vigilance.
It is essential that New Zealanders fully comply with regulations that implement Security Council sanctions. Given the wide scope of the Regulations, and the penalties for non-compliance, it is essential that anyone contemplating doing business with Iran obtain independent legal advice before engaging in any business with people in Iran or with entities that are controlled from Iran. This guidance material does not constitute legal advice. The Ministry of Foreign Affairs and Trade does not accept liability for any loss or damage caused to any person relying on this material.
The Iran business registration system is implemented under the United Nations Sanctions (Iran) Regulations 2010, which are made under the United Nations Act 1946. The Regulations assist New Zealand in upholding its international obligations under the United Nations Charter.
The Regulations can be downloaded from the New Zealand Government Legislation website. United Nations Security Council Resolution 1929 can be accessed from the United Nations website.
Registration will be required in order to do business with Iran. You need to apply for registration with the Ministry of Foreign Affairs and Trade. Application forms are available on the link below.
You will need to ensure that you complete the application form in full. Failure to do so will result in delays in registration being granted. The form requires the applicant to provide:
In addition, the application form will require the applicant to complete a declaration stating that they believe, on reasonable grounds, that the business to be done could not contribute to violations of applicable United Nations sanctions concerning Iran.
Applicants are advised to ensure that they have conducted appropriate due diligence concerning their business partners in Iran. The provision of inadequate information about the person or entity with whom, or with which, the business is to be done is likely to result in a request for additional information. This will delay registration.
Applicants are advised to provide as much information as possible about their business partners in Iran. In the case of companies, for example, this may include details of their ownership, shareholders, activities, details of past dealings with the applicant, and so on.
In the case of individuals, this may include proof of identity, details of the person's directorships, shareholdings, any positions held in government or in state or corporate bodies, and so on.
Applications are also likely to be delayed or declined if the individuals or entities in Iran are named in applicable Security Council resolutions, or on the publicly notified "black lists" maintained by New Zealand's security partners.
If registration is granted, you will receive a registration number and will need to retain your confirmation and records of the business conducted with Iran (both written and electronic) for 7 years in accordance with United Nations Sanctions (Iran) Amendment Regulations 2010. These records must be kept in a safe place and be provided to authorities if requested.
Other sanctions against Iran
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. New Zealand businesses trading with countries subject to autonomous sanctions, including Iran, are advised to seek independent legal advice to ensure that their business does not contravene other sanctions regimes.
Guide to completing the Iran Business registration Form - Please read before completing the registration form.
If you have an enquiry about the registration requirements imposed by the Iran Sanctions Amendment Regulations, please contact:
Iran Registration Officer
Ministry of Foreign Affairs and Trade