In the early hours of Tuesday, 7 August 2018, and as foreshadowed by President Trump’s announcement on 8 May 2018, the United States reimposed certain secondary sanctions on Iran, being those which apply to non-U.S. persons. The imposition of these sanctions follows the conclusion of a 90-day wind-down period and, as mentioned in our previous blog post, will impact (among other things) trade in graphite, raw or semi-finished metals and the Iranian automotive sector. Importantly, the new Iran sanctions permit the U.S. government to impose sanctions on non-U.S. persons who provide significant support to those acting in violation of the sanctions. Note that a second wind-down period expires in early November, at which time further secondary sanctions will be reimposed, affecting, among other things, shipping, the petroleum and petrochemical industry, and insurance.
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Iran Sanctions
Iran Sanctions – August Deadline
On 8 May 2018, President Trump announced that the United States would withdraw from the Joint Comprehensive Plan of Action (“JCPOA”). In conjunction with that announcement, the President issued a National Security Presidential Memorandum (“NSPM”) directing the re-imposition of certain secondary sanctions, being those that apply to non-US persons even where there is no US nexus. Depending on the economic sector targeted, the particular sanction will be imposed either 90 or 180 days after the President’s announcement (6 August and 5 November, respectively).
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Iran Sanctions – Developments from the EU
As discussed in our blog post of 21 May 2018, the EU has reaffirmed its commitment to the Joint Comprehensive Plan Of Action in the wake of the US’ announcement that it would be withdrawing from that agreement and re-imposing its nuclear-related secondary sanctions. The European Commission has now published an amendment to its Regulation 2271/96, the so called “blocking statute”, in order to mitigate the impact of the US’ secondary sanctions.
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Sanctions on Iran – The EU Response
Following President Trump’s announcement that the United States will withdraw from the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose US sanctions (including secondary sanctions) against Iran, the European Union has chosen to signal its commitment to the continuation of the JCPOA. Readers will be aware that the US has indicated it will be re-imposing secondary sanctions on Iran over the course of the coming months, following two winding-down periods, the first of which ends in August this year, and the second of which ends in November.
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Iran: Joint Comprehensive Plan of Action agreed on 14 July 2015, but no immediate sanctions relief
On 24 November 2013, the E3/EU+3 (or the P5+1, comprising the United States, Russia, China, the United Kingdom, France and Germany), together with Iran, agreed the Joint Plan of Action (“JPOA”), which relaxed some of the sanctions imposed against Iran by the EU and the United States.
The JPOA was intended to provide interim sanctions…
Iran: Joint Comprehensive Plan of Action agreed, but no immediate sanctions relief
On 24 November 2013, the P5+1 countries (comprising the United States, Russia, China, the United Kingdom, France and Germany) together with Iran, agreed the Joint Plan of Action (JPOA), which relaxed some of the sanctions imposed against Iran by the EU and U.S. The JPOA was intended to provide interim sanctions relief, while the parties…
P5+1 and Iran Agree on Framework for Joint Comprehensive Plan of Action, Sanctions Easing Expected June 2015
On April 2, 2014, the P5+1 (the United States, Germany, France, the UK, Russia, and China) and Iran reached an agreed-upon framework outlining the roadmap for a future agreement surrounding Iran’s nuclear program that would include suspension of U.S. and EU nuclear-related sanctions imposed on Iran. For further details, please see the recent Reed Smith…
Iran: limited sanctions relief extended to 24 November 2014
In January 2014, both the EU and U.S. brought into force measures which temporarily suspended and relaxed (for a period of six months, to end on 20 July 2014) some of the sanctions in place against Iran. This reflected the Joint Plan of Action (JPoA) agreed between the E3+3 and Iran in November 2013. Those…
Sanctions Update – Iran: Easing of Sanctions by the United States and European Union
As reported in our Client Alert of December 2013, the “Joint Plan of Action” reached between the United Kingdom (“UK”), the United States (“U.S.”), Germany, France, Russia and China (collectively known as the “E3+3”) and Iran in November 2013 envisaged a two-step process in relation to relief from international trade sanctions against Iran.
On…
Sanctions Update on Iran
As reported in our client alert in December 2013, the “Joint Plan of Action” reached between the E3+3 and Iran in November 2013 envisaged a two-step process in relation to relief from international trade sanctions.
On 12 January 2014, it was announced that the interim deal (of six months of initial measures) between the…