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
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.
The International Group has engaged extensively with the (OFAC) in the U.S. and its European counterparts to explain some of the practical effects arising from the reactivation of U.S. 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.
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.
Overview of key provisions in Iran nuclear dealJoint Comprehensive Plan of Action regarding sanctions relief timelines, snapback risks, permitted activities pre-Implementation Day
The diplomatic agreement of 14 July 2015 between the E3/EU+3 and the Islamic Republic of Iran opens the way for the restoration of trade activates with Iran by lifting the trade, energy, insurance and banking embargoes that have been incrementally imposed by the European Union and U.S since 2009.
There have been reports from the P5+1/Iran nuclear negotiations in Vienna that the deadline for reaching an agreement has now been extended through July 10th 2015.
The Joint Plan of Action ("JPoA") agreed by the P5+1 and Iran, which brought limited sanctions relief, is set to expire today, 30th June 2015. While there has been no official world, recent developments suggest that it is highly unlikely that a final agreement on a nuclear deal with Iran will be reached by tomorrow.
The Club has been made aware of recent attempts to export crude oil from Iran in breach of sanctions. On several occasions, oil has been carried from Iran, to Kor Fakkan UAE, under documents falsely describing the cargo as having been loaded in Iraq. It has then been delivered by ship-to-ship transfer to vessels bound for countries that do not benefit from a waiver under applicable US Sanctions legislation.
Confirmation received from the US government and the EU Council that the existing relief program, which ran from 20 January to 20 July, suspending certain Iran sanctions measures, is being extended for 4 months to 24 November 2014.
Following the agreement reached in November last year between Iran and representatives of USA, UK, China, France, Russia & Germany, the Club reminded Members that a formal change in EU, UK and US laws would be needed to provide shipowners and their insurers with relief from existing prohibitions - and that until such changes were made, the effect of sanctions on Club cover would remain unaltered.
The attached FAQs from the International Group provide a comprehensive summary of the relevant legislation and key provisions that impact on trade activities and financial transactions with Iran
