Current US regulations allow tough measures to be taken against non-US entities involved in prohibited activities, wherever based, which include: the development of Iranian petroleum resources; assistance to Iran’s production of refined petroleum products; and/or the exportation to Iran of refined petroleum products.

The first Chinese entity was recently penalized under the Iranian Sanctions Act of 1996, providing a clear indication of how determined and vigilant the US authorities are that companies comply with their trade restrictions.

On 23 January 2012, the EU significantly tightened its Iranian sanctions in-line with the US. The four key developments can be summarised as follows:

1) The import, purchase or transport of Iranian crude oil, petroleum and petrochemical products is prohibited. Therefore, all contracts relating to Iranian crude oil and petroleum products bound before 23 January 2012 can run until 01 July 2012, and those relating to petrochemical products bound before 23 January 2012 can run until 01 May 2012. No related contracts/policies can be bound on or after 23 January 2012 and no related contracts/policies can run to or beyond 01 May 2012 or 01 July 2012, whichever is applicable.
2) The sale, supply or transfer of key equipment and technology for the petrochemical industry in Iran, or to Iranian or Iranian-owned enterprises engaged in the industry outside Iran, is prohibited. Contracts/policies bound before 23 January 2012 can however, run until expiry.
3) The direct or indirect sale, purchase, transportation of gold, diamonds and precious metals to, from or on behalf of the Iranian government and any related entities is prohibited. The delivery of new or unissued Iranian banknotes to the Central Bank of Iran is also illegal.
4) Additional individuals and entities have been added to the asset freeze.

These regulations apply to all EU nationals, corporations, and flagged vessels wherever located. Insurance and/or reinsurance of any listed activities, irrespective of where they are taking place, which involve an EU national, corporation or flagged vessel are therefore illegal.

If you have any questions or concerns in relation to sanctions, please contact us. Please also be aware, international regulations are constantly changing and updates provided are by no means exhaustive.