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Sanctions in Iran

The UN, EU and US have imposed sanctions in response to concerns about Iran’s nuclear programme and human rights abuses.

Key restrictions:

  • asset freeze of listed persons/entities
  • ban on the sale, supply, transport or (re)insurance of Iranian crude oil, petroleum and petrochemical products
  • ban on trading in key equipment and technology used in Iran’s oil and gas sector
  • ban on trading in graphite and raw or semi-finished metals (e.g. iron, steel, copper etc.)
  • prohibition on financial transactions with Iranian banks and financial  institutions

Joint Plan of Action (JPOA) 

On 24 November 2013 the limited easing of sanctions was agreed under the JPOA between E3/EU+3 (UK, US, France, China, Russia, Germany) in return for Iran agreeing to make concessions in respect of its nuclear programme. US extraterritorial sanctions and EU sanctions were suspended in respect of petrochemical and crude oil exports from Iran to China, India, Japan, South Korea, Taiwan and Turkey (which have all previously benefitted from waivers under the US National Defence Authorisation Act 2012).  The JPOA has currently been extended to 14 January 2016.  Further details can be found in our web alert dated 3 February 2014 and Standard club circulars dated 17 January 2014, 28 January 2014 and 25 July 2014.

Joint Comprehensive Plan of Action (JCPOA)

On 14 July 2015, the JCPOA was agreed between the E3/EU+3, the European Union and Iran whereby Iran sanctions will be lifted, in exchange for Iran agreeing not to develop or acquire any nuclear weapons.  There is no immediate relief from sanctions - the JCPOA simply provides a framework for them to be lifted.  Once the International Atomic Energy Agency has verified that Iran has complied with its nuclear commitments (known as ‘Implementation Day’ under the JCPOA) the EU and US nuclear-related sanctions will be lifted.  For further details, please see our web alert and Freehills client alert

If the JCPOA is implemented it will result in the comprehensive lifting of all UN sanctions as well as EU and US nuclear-related sanctions. However, this will only include US extraterritorial sanctions i.e. those involving non-US persons.  US primary sanctions which apply to US persons (or entities owned or controlled by US persons) shall remain in effect. 

Publications

Standard Bulletin Special Edition: Sanctions, July 2013

Sanctions July 2013 resize

Standard Bulletin Special Edition: Sanctions, August 2012

August 2012

Standard Bulletin Special Edition: Sanctions, December 2010

December 2010

Circulars issued by the club

14 April 2016, Standard Club circular - Iran Trading, P&I cover

22 March 2016, Standard Club circular - Iran trading P&I cover update

23 February 2016, Standard Club circular - Iran trading, P&I cover

20 January 2016, Standard Club Circular - Iran Sanctions lifting of certain sanctions under the JCPOA

25 July 2014, Standard Club Circular- Iran sanctions, extension of sanctions relief under the Joint Plan of Action

28 January 2014, Standard Club Circular- US-EU Iran sanctions – further update

17 January 2014, Standard Europe Circular, Iran sanctions update

16 February 2012, Standard Club Circular: War Risks Class, Sanctions against Iran and impact on club cover

1 February 2011, Standard War Risks Circular: 2011/2012 Policy Years Renewal, Amendments to the Rules and Sanctions

9 July 2010, Standard Bermuda Circular: Sanctions Against Iran And Impact On Club Cover

Web alerts issued by the club

Iran Sanctions: “Implementation Day” announced which marks the lifting of EU and US sanctions under the JCPOA 

Iran sanctions- warning re ship to ship transfers in the Persian Gulf, 15 January 2015

Joint Plan of Action to ease sanctions against Iran, 29 November 2013

EU sanctions against Iran, 26 June 2013

US tightens Iran sanctions, 4 June 2013

US announces new sanctions against Iran, 3 June 2013

US issues update to Iran regulations, 20 March 2013

The International Group publishes further guidance on Iran sanctions , 31 January 2013

US Iran Sanctions significantly expanded by the enactment of the Iran Freedom and Counter-Proliferation Act of 2012, 18 January 2013

The EU has issued fresh sanctions against Iran, 17 October 2012

New US sanction law tightens Iran prohibitions, 11 October 2012

New US statute sanctions Iran, 16 August 2012

UK government department's views on bunkers, 15 August 2012

US strengthens Iran sanctions again, 1 August 2012

EU issues further sanctions in respect of Iran, 26 March 2012