Germany, France, and the United Kingdom - the so-called E3 countries - have announced coordinated sanctions against Iran over its alleged supply of ballistic missiles to Russia. The actions will include the termination of bilateral air service agreements, albeit deferred for 12 months, and potential sanctions against majority state-owned IranAir (IR, Tehran Mehrabad).

"The E3 has privately and publicly been clear that we would take new and significant measures against Iran if the transfers took place. We now have confirmation that Iran has made these transfers. We will be taking immediate steps to cancel bilateral air services agreements with Iran. In addition, we will pursue the designations of significant entities and individuals involved with Iran's ballistic missile programme and the transfer of ballistic missiles and other weapons to Russia. We will also work towards imposing sanctions on IranAir," the three countries said in a joint statement.

The cancellation of the bilaterals, once in effect, will effectively force all airlines to stop direct flights between the three jurisdictions and Iran. It will affect Iranian airlines as well as European ones, although currently none of the former flies to Iran on a scheduled basis. The ch-aviation schedules module shows that the only UK-Iran scheduled flights are currently operated by IranAir, which flies 3x weekly between Tehran Imam Khomeini and London Heathrow. It also operates weekly to Paris CDG in France, and 2x weekly to Cologne/Bonn and weekly each to Frankfurt International and Hamburg Helmut Schmidt in Germany.

IranAir's EU network also includes Milan Malpensa, Rome Fiumicino, and Vienna. Austrian Airlines is currently the only EU carrier serving Iran on a scheduled basis.

The E3 countries did not disclose which sanctions they were considering against IranAir. As a general rule, foreign sanctions are imposed by the European Union rather than its individual member states, such as Germany or France.

The CEO of the Iranian flag carrier, Shamseddin Farzadipour, subsequently told local media that the airline had not received any notification of new sanctions that would jeopardise its operations at least for now.

The United States simultaneously imposed additional sanctions on IranAir, although the carrier and its entire fleet were already designated by the US Office of Foreign Assets Control (OFAC) as a government-owned entity in Iran since 2018 under Executive Order 13599. The new designations were imposed under Executive Order 14024 in relation to IranAir's alleged role in supporting the Russian invasion of Ukraine and under Executive Order 13949 in relation to the carrier's alleged role in carrying conventional arms to and from Iran.

The new designations do not impact IranAir as it was already banned from any transactions with the US or covering US-made goods.