Are there any restrictions for citizens of sanctioned countries such as Iran to work "remotely" for Europe companies or foundations?

if it matters, work mentioned in question is about mobile software development

Thanks in advance

1 Answer 1


There is a remote possibility that it could be prohibited, because there is no blanket exception of the type "unless working remotely".

This regulation, No 359/2011, is aimed at specific individuals (listed in Annex I), and Art 2 para 2 says that "No funds or economic resources shall be made available, directly or indirectly, to or for the benefit of the natural or legal persons, entities or bodies listed in Annex I", accordingly a person on that list cannot "work remotely" in the EU, though Art 4 makes it possible for a state to allow certain releases of funds if they are "intended exclusively for the payment of reasonable professional fees" (but this requires official Member State approval).

Regulation 267/2012 has similar prohibitions directed against a longer set of entities and individuals. Art 4 states, for instance, that

It shall be prohibited to purchase, import or transport from Iran, directly or indirectly, the goods and technology listed in Annex I or II whether the item concerned originates in Iran or not.

where Annex I is defined in part as everything listed in Annex I of regulation 428/2009 minus some specified set of software and information security items, plus some specifically listed items. While the intent relates to petroleum, weapons and trading in precious commodities, the employer would need to work through the list carefully to see whether their stuff is on the list(s) or not.


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