Due Diligence
Helpdesk on EU
Sanctionsfor EU SMEs
dealing with IranProject Background
Contracting Authority: European Commission, Service for Foreign Policy Instruments (FPI)The Joint Comprehensive Plan of Action (JCPoA) entered and executed in 2015 between Iran andthe P5+1 (China, France, Germany, Russia, UK and US) as well as the EU, discusses all the rights andobligations of the parties including the term, exemptions and the remaining EU restrictive measures(sanctions) and US sanctions.
European businesses interested in doing business with Iran must consider whether their activitieswould fall under any existing sanctions as applicable and ensure that appropriate due diligence iscarried out before engaging in any business activity.
Many businesses, in particular SMEs, are not always able to allocate resources to carry out due
diligence checks. To avoid uncertainty about the legality of conducting any potential business withIran, they may therefore be inclined to abstain from pursuing legitimate business opportunities.
Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with Iran

Project BackgroundThe Iranian Market
European Countries have enjoyed along trading history with IranRole of INSTEX (Instrument inSupport of Trade Exchanges)
Challenges - Money laundering &international terrorist financing

COVID 19 & INSTEX 1st Transaction blood treatment equipment from
Germany (March 31, 2020 for€500,000)
Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranThe Iranian Market

Overall Objective
To support EU businesses interested indoing legitimate business with Iran, inparticular Small and Medium-sizedEnterprises (SMEs), in compliance with
the EU sanctions legislation, and as partof the EU’s continued commitment to theJCPoA.

Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranOverall ObjectiveHelpdesk ServicesAB

Identification andenrolment ofHelpdesk users

Due Diligence
Orientation &Initial Assessment(Level 1)

Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranCD• DocumentVerification(Level 2)

Ancillary services• On the GroundResearch (Level3)• AdditionalResources• Information

Helpdesk Services

GoalsProvide concrete support to EU businesses by carrying out due diligence regarding EU sanctions
compliance for specific business projects;
Help reduce transaction costs for EU SMEs dealing with Iran;
Encourage EU businesses to engage in Iran by applying a due diligence concept based, inter alia, on
principles elaborated within the framework of the Commission’s preceding action financed under
the Partnership Instrument (“Due diligence for EU operators related to Iran”);
Reassure European banks, which may be currently reluctant to handle transactions involving Iran byproviding EU SMEs with well-researched due diligence documentation on their Iranian business
partners;
Demonstrate the EU’s continued commitment to the JCPoA by allocating significant funds toimproving EU-Iran trade.
Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranGoals

Levels of Due Diligence
Level 2 check
Level 1 check:
DueDiligence
requestreceived
by theHelpdesk•

Provide the initial Due Diligencequestionnaire and list of necessary
documents from the potential Iranianpartners•

Review & assess documentation and carryout due diligence based on the submission•Assist in identifying any missing
information or red flags as part of the due
diligence

Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranAdditional independent verification,
including research of local Farsi
databases, to cover any discrepancy or
missing information

Level 3 check‘On-the-ground’ investigation, involvingsite visits, interviews with relevant
individuals, etc.

Levels of Due DiligenceWebsite
Basicinformation
about EU
sanctionsand theJCPoA

Trainings
andwebinars

PROJECT WEBSITE

Due Diligence
Analysis Tooland link to theEU Sanctions
Tool
Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with Iran‘How to’ guides
and factsheets
including sector
reports
identifying
opportunities

WebsiteDue Diligence Analysis
Tool
Helpdesk Team receives andprocesses requests from EU SMEs
for conducting due diligence using
comprehensive forms available onthe website.

Based on the disclosure quality andany red flags in the submitted
documentation, the team willconduct Level 1-3 due diligence.
GDPR (General Data Protection
Regulations) & compliance withprivacy law are of utmost
importance during the process.
Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranDue Diligence Analysis Tool

Due Diligence
Orientation Reports
For EU companies who do not yet
have a specific business projectplanned for Iran, but would like to
get more information about thesanctions and the Iranian market

The Orientation Reports provide
data on due diligence requirements
for EU companies in Iran, as well as
personalised information on relevant
contacts in the company’s homecountry

Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranDue Diligence Orientation ReportsOther Helpdesk Services

Organizing
trainings andwebinars

Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranSupporting
business
matchmaking
eventsPublication of businessguides, factsheets andother informationmaterials

Other Helpdesk Services

Key HelpdeskFigures
200 + enquiries answered, morethan 100 full due diligence reports
delivered
Key focus sectors:• Agriculture• Pharmaceuticals• Medical devices• Machinery• Consumer goods
Top EU Member State users of theHelpdesk include:
Austria / Germany / Italy /Netherlands / Spain
Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with Iran

The Helpdesk in action

Case study: the typical DD process
1.

The Helpdesk receives an enquiry by an EU SME via email and recommends that the EU SME submits arequest for DD through the Helpdesk website.

2.

The EU SME uses the Due Diligence Analysis Tool to file a request for DD

3.

The Helpdesk Team examines the case, in particular:•The proposed Iranian business partner•
The proposed business activity

4.

Upon concluding its investigation, the Helpdesk Team sends a detailed output report to the EU SME. If
legal uncertainties are involved in the business case, the Helpdesk Team will escalate the case to Level
2/3 for a more detailed analysis.
The process will now be presented in detail

Due Diligence Helpdesk on EU Sanctions
for EU SMEs dealing with IranCase study: the typical DD processThank you!
info@sanctions-helpdesk.eu
www.sanctions-helpdesk.eu