SANCTIONS UPDATE: Iran: EU extends sanctions relief
Members are advised that confirmation has been received from the US government and from the EU Council that they have extended until 30th June 2015 the suspension of restrictive measures specified in the Joint Plan of Action agreed by E3/EU+3 and Iran on 24th November 2013.
While the remainder of the restrictive measures against Iran remain in place, the practical effect of both the European and US measures is "no change" in the sanctions regime of both jurisdictions in respect of Iran until June 2015.
The extension of the JPoA has not increased or reduced the easing of sanctions, and the easings are still limited to the areas identified in http://www.ukpandi.com/knowledge/article/freehill-hogan-mahar-client-alert-us-eases-sanctions-against-iran-129743/. There are a number of points to remember:
- With the exception of civil aviation activities and the humanitarian channel, the easing of sanctions does not apply to U.S. persons or to any foreign entity owned or controlled by a U.S. person.
- The relief granted applies only to activities taking place exclusively during the six-month period beginning 20th January 2014, and ending 30th June 2015 (the "JPoA period").
- The relief granted may be revoked by the U.S. authorities if Iran does not meet its commitments under the JPoA.
- The U.S. authorities retain the authority to impose sanctions:
(i) For activities that occurred prior to 20th January 2014;
(ii) For activities that occur during the six-month period of sanction relief if those activities are materially inconsistent with the sanctions relief prescribed under the JPoA; and
(iii) For violations of all other U.S. sanctions other than those where some relief has been specifically granted. - The relief does not permit transactions with persons or entities on the U.S. Specially Designated Nationals list, except for limited and specific exceptions.
- All other U.S. sanctions, other than those which have been eased pursuant to the JPoA, remain in effect and will be enforced. In their 25th November 2014 FAQs on the continuing JPoA sanctions relief, the U.S. Department of the Treasury cautions:
"The U.S. will continue to vigorously enforce our sanctions against Iran that are not subject to the limited relief provided pursuant to the JPOA, including by taking action against those who seek to evade or circumvent our sanctions. The USG [U.S. Government] also retains the authority to revoke this limited sanctions relief at any time if Iran fails to meet its commitments under the JPoA."
New FAQs have been issued. Both the Guidance and the FAQs are attached and can be accessed at the
. Also attached is the Second Amended Statement of Licensing Policy On Activities Related To The Safety Of Iran's Civil Aviation Industry. A copy of the Council Decision 204/829/CSFP is available here.
Downloads
-
20756 - guidance_ext_11252004 57 KB
26/11/2014
Download PDF -
20757 - Iran_extension_-_Nov_14 61 KB
11/02/2016
Download PDF -
20758 - jpoa_ext_faq_11252014 157 KB
11/02/2016
Download PDF -
20759 - OJ-JOL_2014_338_R_0001-EN-TXT 302 KB
11/02/2016
Download PDF -
20755 - 2nd_amended_jpoa_lic 66 KB
11/02/2016
Download PDF
Tags
You may also be interested in:
On 4 December 2022, the UK Government issued General Licence INT/2022/2469656 (“GL”) to implement the EU/G7 price cap in respect of Russian origin crude oil, which was amended on 3 February 2023 to implement the separate price cap in respect of petroleum products.
This circular confirms approval by the International Group of an updated version of the Secro Customer and User Agreement dated 16th March 2023 as well as use of the Secro Customer e-billls of lading in conjunction with the said User Agreement
Founded in 1543, Santos has been long known as a port city – first through the export of coffee and then other commodities. Santos was significantly modernised and expanded in the 1990s to incorporate new technologies, operating with specialised terminals for containers, general cargo, and dry and liquid bulk, and it is responsible for almost 27% of the country’s trade. Santos is considered the largest port in Latin America, with its docks being 25 km long and able to accommodate about 50 ships at a time.
The region comprising Latin America and the Caribbean is a busy one for the UK P&I Club. Some prominent Members have a large number of tons entered with the Club and have this region as their principal place of business. Moreover, many of the Club’s entered ships frequently call at Latin American and Caribbean ports regardless of where the Member is based, which can undoubtedly be anywhere in the world.