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Export Control and Sanctions Update: EU sanctions against Iran partially lifted

    • Competition, EU and Trade - Export controls and sanctions
    • Diversified industrials
    • Energy and infrastructure
    • Financial institutions

    27-01-2014

    1. On 20 January 2014, the US and EU partially suspended some of the restrictive measures in force against Iran in line with the Joint Plan of Action agreed between Iran and the E3/EU+3 group (China, France, Germany, the Russian Federation, the UK and the USA) in November 2013. The suspension is stated to last only six months, but can be extended by the mutual consent of all parties.  The long term objective of the Joint Plan of Action is to find a solution to address concerns about Iran’s nuclear programme.  If negotiations are successful this could eventually involve the lifting of all sanctions, but for the moment the suspension introduced on 20 January is relatively limited and is likely to have only a marginal impact on EU and US companies trading with Iran.

    Changes to the EU sanctions

    1. Through Regulation 2014/42/EU, amending Regulation 267/2012, the EU has suspended a number of sanctions against Iran, including prohibitions against:

      • The provision of insurance, reinsurance and transport of Iranian crude oil to non-EU destinations (the prohibition against purchasing or importing Iranian crude oil is not lifted or affected);
      • The import, purchase or transport of Iranian petrochemical products and the provision of related services (involving non-designated entities) including financial assistance, insurance and reinsurance for petrochemical product transactions; and
      • The trade in gold and precious metals with the Government of Iran, its public bodies and the Central Bank of Iran, or agents acting on their behalf.
    1. In addition to the above, the EU will:

      • Introduce licensing grounds for transfers of frozen funds or economic resources to the Iranian Ministry of Petroleum where necessary for the import or purchase of Iranian petrochemical products; and
      • Agree not to pursue new nuclear-related sanctions.
    1. Finally, whilst the restrictions on transfers of funds to and from Iranian persons, bodies or entities remain in place, the thresholds for needing to obtain authorisation have increased tenfold.  For example, the threshold for authorisations for personal remittances has increased from €40,000 to €400,000.  However, the requirement to notify any payments over €10,000 remains in place. 
    1. It is worth noting that the UK has not yet implemented legislation setting out the criminal penalties for breaching the updated sanctions, but this is due to happen imminently.  In any event, EU Regulations take direct effect in the UK and therefore the amended EU sanctions on Iran are now in force in the UK.  HM Treasury has however issued updated guidance in respect of whether notifications or prior authorisations are required for relevant transfers of funds and this can be found on www.gov.uk.

    If you would like to discuss these developments further, or require advice on how they may affect you or your business, please contact:

    For more information contact

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