As reported in Circular 16/18 when U.S. secondary sanctions were re-imposed against the purchase and carriage of Iranian crude oil, petroleum products, liquified gases and petrochemicals, in November 2018, eight countries - China, Greece, India, Italy, Japan, South Korea, Taiwan, and Turkey – were granted waivers, known as Significant Reduction Exemptions (“SREs”), to permit the import of limited amounts of Iranian crude oil up to 2 May 2019.
Members should be aware that the U.S. State Department has announced that these SREs will not be renewed beyond 2 May 2019. In a further clarification provided to the Club’s US legal advisors, the State Department has advised that voyages with shipments pursuant to the existing SREs must be completed within that 2May deadline. Any purchase or carriage of Iranian crude cargoes after 2 May 2019 is therefore likely to be treated as a breach of U.S. sanctions, with all the risks which that involves.
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)
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.
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.
On May 8, 2019, exactly one year after President Trump announced that the United States was withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) and would re-impose the U.S. secondary sanctions against Iran, President Trump issued an Executive Order “Imposing Sanctions with Respect to the Iron, Steel, Aluminum, and Copper Sectors of Iran.”
