The United States, the European Union (EU), France, Germany, and the United Kingdom have taken measures against Iran for transferring short-range Fath-360 ballistic missiles to Russia for use against Ukraine. These actions include sanctions imposed by the EU, the United Kingdom, and the United States against entities and individuals involved in the ballistic missile program and the transfer of the missiles and other weapons.Footnote 1 They also include the cancellation by France, Germany, and the United Kingdom of their air services agreements with Iran.Footnote 2 “Today, the United States and our allies are taking concerted action in response to Iran's reckless decision to proliferate ballistic missiles to Russia for use in its war of aggression against Ukraine,” said Deputy Secretary of the Treasury Wally Adeyemo.Footnote 3 “Iran has opted to intensify its involvement in Russia's illegal war,” Adeyemo continued, “and the United States, along with our partners, will continue to stand with Ukraine.”Footnote 4
U.S. officials have warned for years that Iran and Russia were developing a “full-fledged defense partnership.”Footnote 5 Since 2022, Iran has provided hundreds of unmanned aerial vehicles (UAVs) to Russia for its war against Ukraine,Footnote 6 and the two countries have been working to develop a factory in Russia that would produce thousands of UAVs.Footnote 7 Reports circulated as well that Iran would sell ballistic missiles to Russia.Footnote 8
Until October 2023, transactions between Iran and Russia involving UAVs and ballistic missiles would have violated Security Council Resolution 2231, which endorsed the Joint Comprehensive Plan of Action (JCPOA).Footnote 9 With the sunsetting of the resolution's nuclear-related sanctions that month, the Russian Foreign Ministry hinted obliquely that Russia might purchase missiles from Iran.Footnote 10 At the same time, forty-eight members of the Proliferation Security Initiative, led by the United States, “affirm[ed] [their] commitment to take all necessary measures to prevent the supply, sale, or transfer of [Iranian] ballistic missile-related items, materials, equipment, goods, and technology, to protect peace and stability in the region and beyond.”Footnote 11 The EU and the United Kingdom retained the sanctions and designations that would have otherwise lapsed with the expiration of the UN restrictions.Footnote 12 (The United States had withdrawn from the JCPOA in 2018 and reinstated the sanctions that it previously lifted.)Footnote 13 In January 2024, a White House official announced that “[w]e assess that Russia intends to purchase missile systems from Iran.”Footnote 14
Shortly thereafter, the G7 and the EU cautioned Iran against providing missiles to Russia. In a March 2024 statement, the G7 “reiterate[d] [its] call on third parties to immediately cease providing material support to Russia's illegal and unjustifiable war of aggression against Ukraine or face severe costs.”Footnote 15 “We are extremely concerned,” the G7's statement continued, “about reports that Iran is considering transferring ballistic missiles and related technology to Russia after having supplied the Russian regime with UAVs . . . . We call on Iran not to do so, as it would add to regional destabilization and represent a substantive material escalation in its support for Russia's war in Ukraine.”Footnote 16 The G7 warned that if Iran were “to proceed with providing ballistic missiles or related technology to Russia, [it was] prepared to respond swiftly and in a coordinated manner including with new and significant measures against Iran.”Footnote 17 A week following the G7's statement, the European Council declared that “[i]t is extremely concerned about reports that Iran may transfer ballistic missiles and related technology to Russia for use against Ukraine after having supplied the Russian regime with unmanned aerial vehicles (UAVs), which are used in relentless attacks against the civilian population in Ukraine.”Footnote 18 The EU strengthened its sanctions regime shortly thereafter to cover the transfer of Iranian missiles to Russia.Footnote 19
In September, Secretary of State Antony J. Blinken announced that the United States had determined that Iran had transferred ballistic missiles to Russia.Footnote 20 “We've warned Tehran publicly, we've warned Tehran privately that taking this step would constitute a dramatic escalation,” he said.Footnote 21 “Dozens of Russian military personnel have been trained in Iran to use the Fath-360 close-range ballistic missile system . . . [and] Russia has now received shipments of these ballistic missiles and will likely use them within weeks in Ukraine against Ukrainians.”Footnote 22 Though Russia had its own ballistic missiles, Blinken asserted that “the supply of Iranian missiles enables Russia to use more of its arsenal for targets that are further from the frontline, while dedicating the new missiles it's receiving from Iran for closer-range targets.”Footnote 23 Pentagon Press Secretary Air Force Major General Pat Ryder explained that the missiles “deepen[] Russia's arsenal and also . . . giv[es] it the ability to strike the kinds of targets that we've seen them striking, to include civilian targets.”Footnote 24 Ukraine “has struggled to contain the ballistic missiles fired by Russia[,] . . . [shooting} down just 10%,” according to a Wall Street Journal analysis.Footnote 25 General Ryder also indicated that “we see them [Russia and Iran] sharing information as it relates to nuclear programs, space and other technological capabilities that Russia has that countries like Iran want.”Footnote 26 The partnership between Russia and Iran, White House National Security Communications Advisor John Kirby said, is thus “dangerous on both ends . . . , not just to Europe, but to the Middle East.”Footnote 27 G7 foreign ministers “condemn[ed] in the strongest possible terms Iran's export and Russia's procurement of Iranian ballistic missiles.”Footnote 28 They stated that they “remain[ed] steadfast in [their] commitment to hold Iran to account” and will “respond[] with new and significant measures.”Footnote 29
The United States imposed such measures immediately. The State and Treasury Departments designated for sanctions Iran Air, the Iranian national airline.Footnote 30 The designation noted that “IRAN AIR constitutes a key element of Iran's illicit proliferation network enabling Iran's acquisition of sensitive-western origin dual-use materials for use in the development of UAVs, some of which are provided to Russia for use in Ukraine.”Footnote 31 Iran Air was previously designated under Executive Order 13599 as an entity owned or controlled by Iran and its aircraft identified as blocked property.Footnote 32 Its new designation under Executive Orders 13949Footnote 33 and 14024Footnote 34 widened the possibility of secondary sanctions for non-U.S. parties that deal with the airline. The State and Treasury Departments also designated individuals, entities, and vessels, both Iranian and Russian, “that are enabling Iran's delivery of weapons components and weapons systems, including unmanned aerial vehicles (UAVs) and close-range ballistic missiles (CRBMs), to Russia.”Footnote 35 The State Department announcement noted that “[t]he expanding military partnership between Iran and Russia threatens European security and illustrates how Iran's destabilizing influence reaches beyond the Middle East to undermine security around the world.”Footnote 36
Shortly after Secretary Blinken's announcement, the European Union and the United Kingdom condemned the transfer of the ballistic missiles.Footnote 37 EU High Representative for Foreign Affairs Josep Borrell said that the “transfer [of ballistic missiles] is a direct threat to European security and represents a substantive material escalation from the provision of Iranian UAVs and ammunition.”Footnote 38 He indicated that sanctions would be forthcoming.Footnote 39 In September, the United Kingdom designated many of the same Iranian individuals and organizations sanctioned by the United States, as well as several Russian organizations and cargo ships.Footnote 40 The United Kingdom did not, however, immediately sanction Iran Air, though in a statement it (together with France and Germany) indicated that it was “work[ing] towards imposing sanctions” on the airline.Footnote 41 In October, the European Union designated for sanctions individuals and entities “responsible for the development and transfer of unmanned aerial vehicles (UAVs), missiles and related technology to Russia,” most notably Iran Air and two other airlines (Mahan Air and Saha Airlines).Footnote 42 In November, the United Kingdom designated Iran Air, as well as the Islamic Republic of Iran Shipping Lines (the state-owned national shipping carrier) and a Russian cargo ship.Footnote 43 Both the EU and the United Kingdom also broadened the scope their sanctions measures, further targeting items used to produce UAVs and ballistic weapons.Footnote 44
In September, France, Germany, and the United Kingdom canceled their bilateral air services agreements with Iran, calling the transfer of the ballistic missiles “an escalation by both Iran and Russia, and . . . a direct threat to European security.”Footnote 45 Termination of the agreements will end air service between the three countries and Iran.Footnote 46 Though the agreements’ cancellation will only take effect after twelve months,Footnote 47 all direct flights between the EU and the United Kingdom and Iran were suspended during the final months of 2024. The sanctioning of Iran Air by both the EU and the United Kingdom prevented Iran Air from operating in those jurisdictions, and the danger to civil aviation due to the conflict in the Middle East forced European carriers to cancel their routes to Tehran for safety reasons.Footnote 48
Iran denied that it had delivered ballistic missiles to Russia.Footnote 49 Iranian Foreign Minister Seyed Abbas Araghchi stated that, “[o]nce again, US and E3 [France, Germany, and the United Kingdom] act on faulty intelligence and flawed logic[.] Iran has NOT delivered ballistic missiles to Russia. Period[.] – Sanction addicts should ask themselves: how is Iran able to make & supposedly sell sophisticated arms? Sanctions are NOT a solution, but part of problem.”Footnote 50 Foreign Ministry Spokesperson Nasser Kanani said in a statement that “[t]he move by the three European countries is in line with the West's hostile policy and economic terrorism against the Iranian people, and will face the corresponding and proportionate move by the Islamic Republic of Iran.”Footnote 51
