Sanctions Update – Iran
Tagged: insurance, Iran, reinsurance, sanctions
In accordance with EU sanctions, (re)insurance is prohibited for the benefit of Iranian persons, entities, and bodies. Imports of refined petroleum into Iran are also not permitted.
Additionally, from 21 November 2011, any transactions (direct or indirect) and business relationships with all Iranian banks, including their branches and subsidiaries, and the Central Bank of Iran are now prohibited; without exception. This includes all companies owned or controlled by any Specifically Designated Nationals (SDNs), which therefore do not have to be Iranian registered.
Nevertheless, HM Treasury has stated the recent Direction is not intended to serve as a trade ban with Iranian companies, even though the UK Government does not encourage such trade. Insurance not for the benefit of the relevant persons/bodies mentioned previously, therefore, is still permitted for certain exports to and imports from Iran; refined petroleum excluded. Sanctions may escalate further very soon however, after the UK Embassy was overrun in Tehran recently and Iranian Diplomats were expelled from the UK.
It is extremely important to note in addition that US sanctions are currently far more severe, highlighted by the recent identification of Iran as a “jurisdiction of primary money laundering concern”; consequently, all USD denominated transactions will come under increased scrutiny.
International restrictions are constantly changing and updates provided are by no means exhaustive. If you ever have any questions or concerns in relation to sanctions, do not hesitate to contact FP Marine Risks.
We also recommend that Assureds consider seeking legal advice for any shipments or reinsurance that may be affected by these sanctions.
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