Iran Sanctions Update 15 August 2018
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 linkedhere.
Companies based in EU may also need to consider the effects of the EU Blocking Regulation as noted in the Club'sCircular 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 linkedhere.
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:firstname.lastname@example.org
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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.
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.”
Given the global announcement of "Implementation Day" - that there will be a lifting of sanctions on Iran, the Club and IG are examining closely what this actually means in reality for Iran's oil, gas, shipping, petrochemicals, insurance and financial sectors, and importantly for those owners/operators wishing to engage business with Iran.