Iran Sanctions *Update*


13 August 2019

On 8 May 2019, the United States issued Executive Order 13871 imposing wide ranging and new sanctions on Iran’s metal industries.

E.O. 13871 applies to both US and non US nationals and targets virtually the entire metals sector in Iran including those engaged in transactions in support of the sector. A wind down period to allow for existing contracts to be concluded expired on 6 August 2019. Members are reminded that a vessel will cease to be entered in the Association if it engages in a trade that expose the Association to a risk of breaking sanctions and that there is no cover for any trade which breaks any applicable sanctions.

A link to a legal briefing prepared by US attorneys, Freehill Hogan & Mahar LLP may be accessed here.

28 January 2014 

A further update has been issued in relation to the six month suspension of insurance prohibitions and how this is to be interpreted by the US authorities. The interpretation may have a significant impact on members insurance cover arrangements if considering trading to Iran.

The urgent update may be read here.

20 January 2014 

The Club has issued an Iran Sanctions Update relating to changes in EU and US sanctions measures which are expected to take effect from Monday 20 January 2014, and which will provide for a temporary suspension of certain current sanctions. These are limited in scope and duration.

Comprehensive guidance on Iran sanctions can be found in our Iran Sanctions Loss Prevention Briefing. A similar briefing is available in relation to Syrian Sanctions. Both publications contain links to relevant sanctions legislation and lists of designated persons.

The International Group has issued a set of Frequently Asked Questions – IG FAQs – to assist Members with issues in connection to the recently published EU Council Regulation 1263/2012. These FAQs should be read in conjunction with the previous FAQs issued on 8 February 201227 March 201225 May 201214 August 2012 and 1 November 2012.

IG FAQs covering all aspects of US sanctions have been published and are available here. This is complimented by an IG briefing note on the most recent US sanctions legislation (Iran Freedom and Counter-Proliferation Act of 2012) available here.