対イラン制裁アップデート 2018年8月15日
当クラブは
2018年6月27日に米国のJCPOA離脱および二次的制裁の再開についてお伝えしました。本件に関する米国大統領令やEUブロッキング規則について、2つの法律事務所による解説とアップデート情報をお伝えします。
We refer to the Club's update on Iran sanctions of 26th June 2018, regarding the decision of the United States to withdraw from the Joint Comprehensive Plan of Action ("JCPOA") and to re-impose secondary sanctions.On August 6, 2018, President Trump issued Executive Order 13846 which re-imposes secondary sanctions that had been suspended pursuant to the JCPOA. For some categories of transactions, however, including those relating to the energy, shipping, shipbuilding and port sectors of Iran, and export of Iranian petroleum and petroleum products, a previously established wind-down period remains in effect until November 4, 2018.
Companies that had resumed trading with Iran will need to reassess whether their trading activities are sanctionable by the US or will become so after November 4, 2018. We attach an update on the re-imposed sanctions from law firm Freehill, Hogan & Mahar with further details and insight regarding President Trump's Executive Order 13846. The update is linked
here.Companies based in EU may also need to consider the effects of the EU Blocking Regulation as noted in the Club's
Circular 8/18.We attach an update from law firm Gibson Dunn, which adds to their analysis of Executive Order 13846 some useful commentary on the effects of the EU Blocking regulation. Their update is linked
here.Should you have any detailed enquiries regarding the effect of sanctions on the operation of the Club, or the cover it provides, please contact Nigel Carden (Tel: +44 20 7204 2147; Email:
nigel.carden@thomasmiller.com)
