U.N. Rapporteur Concludes Controversial Trip

On May 18, a U.N. official warned that unilateral sanctions – including by the United States – have severely impacted government revenues, contributed to inflation and poverty, and led to scarcity of basic necessities in Iran. Alena Douhan, a U.N. special rapporteur, expressed particular concern about the short supply of medicines, medical equipment and healthcare services.

In her findings after a 12-day trip to Iran, Douhan recommended that all local and international stakeholders “stop using the rhetoric of sanctions as a political instrument or a means to get economic advantages,” and instead use dialogue to settle disputes. “I call on sanctioning states, in particular the United States, to lift all unilateral measures imposed against Iran, Iranian nationals and companies without authorization of the UN Security Council,” especially of goods essential to critical infrastructure, food, health and humanitarian goods. “No good intention justifies the violation of fundamental human rights,” she reported.

The special rapporteur position was created in a U.N. resolution introduced by Iran in 2014 on behalf of the Non-Aligned Movement, a bloc of 120 countries. The rapporteur is tasked to investigate the negative impact of “unilateral coercive measures” on human rights. It covers other countries too. Since 2020, Douhan, who is a law professor from Belarus, has visited Venezuela and Qatar. The rapporteur’s mandate is to collect information – from governments, non-governmental organizations and other parties – and report to the U.N. Human Rights Council.

International human rights groups and Iranian activists warned that Tehran might use Douhan’s findings to blame its ills on foreign sanctions. “More than 'unilateral coercive sanctions,' it is the Islamic Republic and its institutions that are responsible for economic difficulties and blatant human rights violations,” five Iranian activists said in an open letter to Douhan. Nobel Peace Prize laureate Shirin Ebadi, a human rights lawyer now living in exile, called the visit a “ploy” by Tehran. Iran only allowed Douhan access after denying the request of 14 other U.N. human rights monitors since 2005, 11 human rights groups noted. “Iranian authorities exploit this visit in an inconspicuous attempt to blunt scrutiny of its record of non-cooperation with the U.N. human rights system,” they said in a joint statement.

Iran has blamed U.S. sanctions for hampering its fight against COVID-19 but Tehran also refused American aid in the early days of the pandemic. The Trump administration reimposed older sanctions as well as some 1,500 new sanctions as part of its “maximum pressure” after withdrawing from the nuclear deal in 2018. The goal was to coerce the Iran into renegotiating the deal and expand the subjects covered in it. The following are key excerpts from Douhan’s initial report to the United Nations, with the full report here.



The United States has imposed economic, trade and financial sanctions on Iran since the late -1970s, with a comprehensive trade ban since 1995 and measures to isolate Iran from the international commercial and financial system. These were expanded in the mid-2000s and again after 2010, extending to many economic sectors. U.S. sanctions also targeted the Iranian Central Bank and commercial banks.

The European Union adopted restrictive measures and comprehensive economic and trade sanctions against Iran in 2010, supplemented by an oil embargo in 2012 and trade prohibitions involving key sectors, and the freezing of assets of the Central Bank, the Iranian shipping and ship-building sector and a number of persons and entities, with significant restrictions on financial services and exports and imports.

After the conclusion of the JCPOA, endorsed by the UN Security Council resolution 2231 which terminated all the UNSC sanctions, the EU lifted its sanctions except an arms and military technology embargo; and the United States ceased application of sanctions as set forth in the JCPOA while still banning trade and investment with Iran. On 8 May 2018 the United States unilaterally withdrew from the JCPOA. It re-imposed all lifted sanctions, added new financial sanctions, including by designating the Central Bank and several other Iranian banks. Most foreign financial institutions have now left the Iranian market. Iranian assets frozen in foreign accounts are estimated at USD 100-120 billion, and the US list of designations includes more than 1700 individuals and entities.

Currently, the EU, the UK, Australia, Republic of Korea and others have unilateral sanctions, asset freezes and travel bans against a vast number of individuals,  entities and  trade restrictions. Canada imposed sanctions against key Iranian economic sectors and restricts financial activity, and currently has above 200 listed individuals and entities. This environment has led to de-risking and over-compliance, and many actors have disengaged from activities or relationships with Iran for fear of severe consequences.

Impact of unilateral sanctions

Unilateral sanctions have been reported to have a multifaceted negative impact on Iran’s economy and almost all sectors. Numerous studies demonstrate direct links between trade bans and financial and other restrictions on economic indicators. Sanctions on key sectors, including oil, which represented more than two third of the country’s exports, led to a radical reduction in public revenues. Statistics show that the re-imposition of unilateral sanctions since 2018 has had major adverse effects on Iran’s trade and economy.

Furthermore, Iran’s GDP went from growing 3.8% in 2017 to minus 6% in 2018, after the US withdrawal from the JCPOA and minus 6.3% in 2019, before the COVID-19 outbreak, while it showed signs of slight recovery in 2020 and 2021. Interlocutors highlighted the inflationary consequences of sanctions, with spiking prices in basic goods and services, as well as medicines and medical devices, challenging the Government’s capacity to support those in need. Together with the devaluation of the national currency, high unemployment and disruptions from the COVID-19 pandemic, this has put enormous pressure on poor and vulnerable segments of the population, causing additional social harm. Poverty rates have been rising with over 3 million new poor in the period 2017-2019.

In practical terms, all sectors of the Iranian economy, and the lives of Iranians inside and outside of the country, have been severely impacted by the inability to make international payments using Iranian accounts, even for staffs of international organizations and foreign diplomats. The designation of Iran’s main financial institutions, including the Central Bank, asset freezes and over-compliance by foreign financial institutions and businesses have been key elements in this process.

There is evidence of a clear link between the imposition of sanctions and financial and trade isolation policies on the one hand, and their adverse  impacts on the capabilities of the national healthcare system on the other. These not only concern the supply and availability of medicines and medical devices but also budget allocations for existing healthcare services as well as research and development of new therapies and procedures. With the re-imposition of sanctions resulting in rising costs and reduced supplies, including of raw materials for domestic pharmaceutical production, a deterioration is observed in Iran’s national health standards with particular impact on children, despite reported Government initiatives to strengthen overall healthcare capacity through the development of medical and pharmaceutical self-sufficiency with the strengthening of local production and the increased number of general and specialized clinics, pharmacies, and hospital beds in 2018-2020.

Of particular concern are significant challenges and obstacles in procuring and delivery of life-saving medicines and medical devices to treat rare and severe diseases, including certain cancers, thalassemia, haemophilia, multiple sclerosis, autism, epidermolysis bullosa (EB) and HIV/AIDS due to foreign companies’ over-compliance and restrictions on processing payments through the banking system and deliveries. I was also informed about the reluctance of insurance companies to insure air cargos, and about significant delays that caused deliveries of medicines close to their expiration dates.

Although medicines and medical devices are technically not subject to sanctions, the vagueness and complexity of the licensing processes, the persistent fear among producers and suppliers, the restrictions in the processing of payments, and the obstacles to shipping these goods have rendered them inaccessible to the Iranian public, in particular to those most in need, in particular in remote and rural areas. Government institutions and humanitarian non-government actors are striving to find alternatives, incurring additional costs due to the involvement of brokers and intermediaries.

Sanctions and the resulting economic pressures also have a pronounced gender perspective. Economic sectors that traditionally employ women have been particularly affected and an increasing number of women have entered the informal economy to respond to the financial needs of their households. Per the information received, the women’s unemployment rate is approximately twice that of men (48% and 25% respectively). Several interlocutors also raised concerns about the precarity of approximately 3 million female-headed households and of the vulnerability of 9 million women who find themselves in low-income categories of the population, and face difficulties in accessing basic services, including healthcare. Worsening economic conditions and bank transfer bans have also affected the elderly population. The high inflation has slashed their purchasing power and increased significantly their medical costs.

Iran hosts more than 5 million migrants and refugees, mostly of Afghan origin and undocumented, and in need of humanitarian aid. The situation worsened after the 2021 Taliban takeover forced more than 850,000 Afghans to cross into Iran. The Government has expressed its commitment to keep implementing inclusive policies, including equal access to education and healthcare. However, due to the economic impact of sanctions, the restrictions on financial transactions and delivery of provisions, and donors’ reported reduced interest, compounded by the pandemic outbreak, the costs of humanitarian assistance have jumped almost 50%. This has harmed the ability of the Government and humanitarian actors to implement projects, including providing basic goods and building schools and health centers to benefit this vulnerable population

It has also been reported that sanctions prevent Iran – a disaster-prone country experiencing 45 of the 47 types of natural disasters – from investing in disaster response and recovery. Delays in receiving financial allocations for emergency interventions and in the delivery of life-saving medicines and equipment are reported to extend from 1 week up to a year, due to banking transaction restrictions. The restrictions also prevent aid organisations from receiving financial support and donations from abroad, while procurement of search-and-rescue helicopters and air-ambulances is almost impossible due to the failure to secure financing and the fact that they may be deemed “dual-use”.

A local NGO researching international best practices to treat child drug addicts has been refused access to models developed by a US institution. It has taken 8 months for the same organisation, which also assists Afghan refugees, to identify a bank in Europe that would accept receiving EU funding to support one of its projects in Iran.  The Iranian Autism Association, which provides assistance to 6,000 families, has not been able to access new therapies which are being developed outside the country because relevant institutions are refusing to cooperate with it.


Primary unilateral sanctions, secondary sanctions, threats of sanctions, de-risking policies and over-compliance with sanctions have been substantially exacerbating humanitarian situations in Iran.

Sanctions imposed on main export goods, designation of all Iranian banks along with a long list of companies and nationals, including some engaged in pharmaceuticals and food production, have resulted in reduced state revenue, inflation, growing poverty, insufficient resources to guarantee basic needs of people with low incomes and other vulnerable groups, including people suffering from rare or severe diseases, disabled people, Afghan refugees, women-led households and children.

They have also prevented the Government from having resources to develop and maintain essential infrastructure including hospitals, schools, housing, refineries, roads, civil aviation, tankers and many others, and to maintain the necessary level of readiness to respond to natural disasters; and have resulted in the reduction of social support programs and prevented implementation of academic, cultural, environment and development projects, with a devastating effect on Iran’s whole population. 

The stated readiness and threats to impose secondary sanctions, criminal and civil penalties against individuals and companies circumventing unilateral sanctions regimes, as well as de-risking policies and over-compliance by third-country banks and private companies has resulted in growing problems to transfer or receive money when natural or legal persons of Iran are participants in the transactions, including closing long-established bank accounts; extending the length and costs of bank transfers, and creating the need to do transactions via third-country nationals or seek alternative ways of payments and procurement, which are often impossible or entail long delays, misuse of the situation by the third parties, deliveries of low-quality or counterfeit materials, reagents, medicine may cause various challenges in economic, social, crime prevention, and cultural fields

Preventing Iran from participating in international cooperation by impeding its ability to pay membership fees for international organizations, or to have inter-parliamentary cooperation, hampers Iran from international cooperation and prevents the fulfillment of the right to development.

I note with concern that due to the unavailability of new machinery, spare parts, software and technologies, frozen assets in a number of countries, and the lack of access to emergency loans, Iran’s people are affected by impediments to gasoline supplies, health care, adequate mechanisms of monitoring and responding to natural disasters, and face deteriorating situations with transportation and environmental security, maintenance of critical infrastructure, implementation of innovative technologies, growing risks of oil, air and land pollution, and deteriorating working conditions that affect economic and social rights and the rights to health and to life.

I underline that reduced revenues from the export of goods, low salaries and the deteriorating economic situation, and inflation have reduced the capability of the Government to maintain the level of social support it used to exercise in the spheres of food, health and housing, affecting thus the right to food, freedom from poverty, right to a decent life, right to health, and economic and social rights.

While recognizing the existence of OFAC general licenses for procuring and delivering with exemptions medical and agricultural goods to Iran, in practice humanitarian exemptions for food and medicine appear ineffective and nearly non-existent due to the real or alleged fear of secondary sanctions, civil and criminal charges, reported “advice” not to do any business in Iran, the impossibility, complexity, uncertainty and length of bank payments and good deliveries. This affects the whole scope of human rights of the Iranian people.

The refusal by producers of medicines and medical devices, raw materials,  food stuff and agricultural  commodities , spare parts, software, vaccines for human beings and livestock, seeds, fertilizers and other essential goods to conclude contracts with Iranians, the rejection of banks to do any transaction, and of transportation companies to guarantee deliveries, has resulted in documented growing mortality and disability rates of people with rare and severe diseases; greater deliveries and use of low-quality, expired and counterfeit medicine and medical equipment; deterioration of health status; and lower food production, reducing the life expectancy of people with disabilities and inevitably violating the rights to food and to health and eroding their quality of life, violating the right to live in dignity without pain and the right to life.

The whole scope of unilateral sanctions together with secondary sanctions and over-compliance, rejection of producers, banks and delivery companies to deliver essential goods has forced Iranian public institutions, private companies and individuals to look for alternative ways to participate in international trade by involving third parties, using informal and opaque mechanisms of trade, payments and delivery, facilitating poverty and low living standards, and violating economic and social rights.

The reported reluctance of foreign partners to cooperate with Iranian educational institutions, professional and amateur sport societies, cultural institutions, artists, technology and other companies, as well as cutting the possibility to transfer money, difficulties in getting visas, exclusion of Iranian scholars from editorial boards abroad and growing rejection of journals to assess and edit articles submitted by Iranian scholars, shrinking possibilities for Iranian students and scholars for research grants and scholarships, or getting access to foreign academic, technological and medical databases and libraries due to their Iranian nationality, and discrimination based on the country of the IP address all constitute discrimination on the ground of nationality, affecting the right to education as well as international academic, sports and cultural cooperation, innovation, academic freedoms and cultural rights, preventing cooperation and dialogue in all of the abovementioned areas.

Economic challenges arising from UCMs and lack of international cooperation based on shared responsibility prevent the Government of Iran from providing sustainable assistance to the most vulnerable categories of the population, including the Afghan refugees. While welcoming Iran’s efforts to provide equal access for Afghan refugees, both documented and undocumented, I note that insufficient revenue prevents the Government from developing schools, hospitals and urban infrastructure,

Unilateral sanctions and over-compliance, alongside with reduced bilateral and international cooperation, deteriorate economy and adversely affect the right to employment, right to decent work, especially for the poorest population groups, and hamper effective crime prevention, increase drug use and also hamper economic and social security.

I welcome the efforts and measures of the Government of the Islamic Republic of Iran to mitigate the negative impact of unilateral sanctions in different sectors, especially for the most vulnerable population categories, including Afghan refugees. However, while this reduces the direct impact on human rights, it shall not be used as a ground to legitimize the use of unilateral sanctions.

Unilateral sanctions on deliveries, insurance of transportation and Iran’s banking system and over-compliance by companies and banks seriously impede humanitarian organizations and associations from providing humanitarian assistance and deliveries, being somehow easier for international humanitarian non-governmental organizations receiving donations from the EU and its member states. The above impediments result in higher legal and bank fees, delays in deliveries even of life-saving medicine and medical devices, reduced donations from private donors, and the reported impossibility to transact and transfer money to procure and deliver goods, forcing the use of alternative, often non-secure ways of delivery, with risks for the quality of medicine and equipment, raising costs and therefore reducing operational capabilities. Humanitarian organizations are reported to function while risking civil and criminal charges from the United States for interacting with Iranian entities and their humanitarian activity in Iran. The application process for licenses is lengthy, unsure and very expensive, undermining the possibility of delivery to Iran even of purely humanitarian goods like medicine, medical equipment and food.


I remind all parties of their obligation under the UN Charter to observe principles and norms of international law, including principles of sovereign equality, political independence, non-intervention in the domestic affairs of states, and peaceful settlement of international disputes.

I urge all international and national stakeholders to stop immediately using the rhetoric of sanctions as a political instrument or a means to get economic advantages, and to engage in dialogue to settle disputes in accordance with principles and norms of international law, while assessing, preventing and monitoring the humanitarian impact.

I call on sanctioning states, in particular the United States, to lift all unilateral measures imposed  against Iran, Iranian nationals and companies without authorization of the UN Security Council and whose use cannot be justified as retortions or countermeasures in accordance with international law, especially as concerns trade, delivery, insurance and payment impediments for the development and maintenance of critical infrastructure including food, medicine and medical equipment, water, sanitation and electricity supply systems, mechanisms allowing for communications and transportation, among other things, that are essential for the population to enjoy the entire range of human rights and guarantees of health, food and transportation security. I also remind that no good intention justifies the violation of fundamental human rights. 

I urge the U.S. Government to cease the state of national emergency that is not in accordance with the ICCPR, and to align national legislation with international law, including human rights law, refugee law and the law of international responsibility.

I call on all interlocutors (including states, international organizations, banks, private companies , civil society and other stakeholders) to avoid coercion, written or oral threats or any other act which may cause or result in the application of own or third country unilateral sanctions or over-compliance, and to interpret all limitations including the qualification of goods and equipment as dual-use, in the narrowest possible way in the interim period before the lifting of unilateral sanctions.

I urge States that froze assets of the Central bank of Iran to unfreeze them in accordance with customary norms of international law on the immunity of state property, so the Government may fully carry out its responsibility to implement fully its obligation to promote and protect human rights.

I call on all banks and private companies to act in accordance with the Guiding Principles on Business and Human Rights to avoid over-compliance and the consequent violation of rights of nationals and residents of Iran, especially as regards critical infrastructure, on the first hand – delivery of medical equipment, spare parts, medicine, raw materials for medicine production, especially as concerns rare and serious diseases. I also recommend the Government to consider the possibility of alternative ways of payment for the delivery of humanitarian goods.

I remind all states and regional organizations of the obligation to comply with the principle of due diligence, and to take all necessary measures to guarantee that activity under their jurisdiction and control will not affect the human rights of people within and beyond national borders. Violating international obligations by states – including the one of due diligence to guarantee that activity under their jurisdiction and control does not cause damage to nationals, residents and companies of third states – establishes a valid ground for responsibility in accordance with international law. I also call on regional and national judicial institutions to consider sanctions-related cases with due diligence, preventing the prioritization of de-risking policies and economic concerns over international economic and human rights obligations.

I urge  states which impose sanctions against Iran, Iranian nationals and companies to ensure that the Islamic Republic of Iran is able to pay assessed and voluntary contributions to international organizations, Iranian diplomatic, consular and special missions, and that staff members receive entrance permits without any impediments, enjoy the possibility to open and keep bank accounts and exercise diplomatic and consular functions  free from any risk of freezing mission accounts in full conformity with the principle of sovereign equality of states, immunity of state property and the Vienna conventions on diplomatic, consular relations and special missions.

I urge the states participating in the JPCOA and the USA to continue negotiations in the good faith.

I also request banks, sports, cultural and academic institutions, organizations and associations to guarantee and facilitate the possibility for Iranian scholars, artists and sportsmen to engage in international cooperation under the uniformly recognized (including within the UN, UNESCO and other) obligations and initiatives that educational, sports and cultural cooperation and exchanges are inalienable means of achievement of the Sustainable Development Goals, conflict prevention and maintenance of peace and security worldwide. I urge all parties to ensure free access to information and the possibility to exercise freedom of expression, with any limitations in the digital world fully conforming with Art. 19–20 of the ICCPR.

I welcome the reported cooperation of the Government with the UN Country Team and UN specialized agencies present in Iran in the humanitarian area, and encourage the Government and the OHCHR to engage in a genuine and mutually respectful dialogue aimed at promoting and protecting human rights through a programme of technical cooperation as well as through interaction with Special Procedures mandate holders.

I urge UNCT, UNICEF, UNDP and UNAIDS to further engage with producers and relevant states, and help Iran procure proper quality medicines, raw materials, medical equipment and spare parts for treating rare and severe diseases including EB, thalassemia, hemophilia, HIV, cancer, hemophilia, autism, MSA and diabetes.

While welcoming and acknowledging efforts and measures to host the growing number of Afghan refugees, besides lifting unilateral sanctions to enhance the Government’s capability to provide necessary services and care to them, I call on the international community to provide adequate substantial assistance for Iran for this activity.

I call on the UN Country Team in Iran, UN specialized agencies and organizations, and relevant humanitarian organizations to engage in meaningful cooperation with Iran to mitigate the negative impact of unilateral sanctions on human rights in Iran within their spheres of responsibility, to ensure observance of the rule of law and human rights, and the achievement of the Sustainable Development Goals.

Mindful of the obligation of all states to settle international disputes by peaceful means, I welcome the submission of the case to the ICJ on the violation of the 1955 Treaty of Amity, Economic Relations, and Consular Rights, and call on all parties to use judicial mechanisms to settle existing disputes, to cooperate in good faith to prevent such disputes through negotiations, and to use all available mechanisms to protect human rights affected by UCMs, including the UN treaty bodies, European Court of Justice and the ECHR. I call on other Special Procedures to pay due attention to the impact of unilateral sanctions against Iran on the people of Iran.

I call on the office of the High Commissioner, UN treaty bodies, OCHA and other UN institutions working together with the Special Rapporteur to get engaged in developing compensation, remedial and redress mechanisms for victims of human rights violations due to UCMs. I also invite all stakeholders – states, international organizations, NGOs, banks and businesses – to launch multilevel discussions to develop Guiding Principles on secondary sanctions, over-compliance and human rights in order to protect human rights, prevent de-risking that entails over-compliance, and introduce due diligence principles in international cooperation, banking and business activity.