1st August 2012: New Executive Order on Iran
On 1st August 2012 President Obama signed a new Executive Order on Iran. It gives new sanctions authorities to both the Department of the Treasury and the Department of State. The E.O. authorizes the Secretary of the Treasury to impose financial sanctions on foreign financial institutions found to have knowingly conducted or facilitated certain significant financial transactions with the National Iranian Oil Company ("NIOC") or Naftiran Intertrade Company ("NICO") or for the purchase or acquisition of petroleum or petroleum products from Iran through any channel. In addition, the E.O. provides Treasury new authority to impose sanctions on foreign financial institutions found to have knowingly conducted or facilitated significant transactions for the purchase or acquisition of petrochemical products from Iran.
Finally, it provides authority for Treasury to block the property and interests in property of any person determined to have materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services in support of, NIOC, NICO, or the Central Bank of Iran, or the purchase or acquisition of U.S. bank notes or precious metals by the Government of Iran.
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On 17 March 2022 the UK Government published a General Trade Licence in part to clarify earlier amendments to the UK Russia (Sanctions) (EU Exit) Regulations (the “Regulation”). Specifically, the licence addresses the issue as to whether it is lawful under the Regulation for insurers and reinsurers domiciled or operating from the United Kingdom to provide insurance for vessels calling at Russian ports or transiting Russian territorial waters.
UK Sanctions - An Update
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Members will have noted the decision by President Trump announced on May 8 to withdraw the USA from participation in the JCPOA (Joint Comprehensive Plan of Action) agreed between Iran, the EU, and the P5+1 (the five permanent members of the United Nations Security Council - China, France, Russia, United Kingdom, United States - plus Germany), and to re-impose US nuclear-related sanctions.
Since 2010, considerable sanctions' activity has been directed at shipping and its supporting industries reflecting the fact that 90% of world trade involves the carriage of goods by sea.