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Web Alert: New US Executive Order - reimposing sanctions against Iran

09 August 2018

On 6 August 2018, Donald Trump issued a New Executive Order ('Reimposing Certain Sanctions With Respect to Iran') which reimposes secondary sanctions on non-US persons that were lifted under the Joint Comprehensive Plan of Action (JCPOA). A full copy of the Executive Order may be found here.

We have previously reported in our circular dated 31 May 2018 regarding the decision by the US Administration to withdraw from the JCPOA and reimpose secondary sanctions against Iran.

As previously advised on 7 August 2018 (following a 90-day winding down period) sanctions were reimposed on the direct or indirect sale, supply or transfer to or from Iran of graphite, raw or semi-finished metals such as aluminium and steel, coal and software for integrating industrial processes. 

On 5 November 2018 (following a 180-days winding down period) sanctions will be reimposed on Iran's port operators and shipping and shipbuilding sectors, including the Islamic Republic of Iran Shipping Lines (IRISL). Furthermore, sanctions will be reimposed on petroleum-related transactions with, amongst others, the National Iranian Oil Company (NIOC) and the National Iranian Tanker Company (NITC) including the purchase of petroleum, petroleum products or petrochemical products from Iran. Further details can be found in new FAQs issued by US OFAC relating to the New Executive Order.

In response to this, the European Commission announced that the updated EU Blocking Regulation (EU Reg. No. 2271/96 as amended by EU Reg 2018/1100) entered into force on 7 August 2018. This aims to counter the effects of US sanctions on EU economic operators, the intention being that EU operators will be able to recover damages arising from extra-territorial sanctions within its scope from the persons causing them. A helpful guidance note has been issued by the European Commission here​.

The International Group and The Standard Club are reviewing the implications of the EU Blocking Regulation and will report shortly.

Due to the increasing complexity of the situation, the club recommends its members to take a very cautious approach to any Iranian-linked commercial activity.

If members have any queries regarding the above please contact your usual club contact for guidance.