Please note that following the US decision to pull out of the JCPOA, US secondary sanctions have snapped back into place (primary sanctions were never lifted). The sanctions snapped back in two parts - 90 days and 180 days. The 90 day snap back was 7 August 2018 concerning metals, money and cars.
The 180 day snap back is TODAY - 5 November and mainly concerns shipping, oil, banking and insurance, including, but not limited to:
i. Iran’s port operators, and shipping and shipbuilding sectors;
ii. Petroleum-related transactions, including the purchase of petroleum, petroleum products, or petrochemical products from Iran;
iii. Transactions by foreign financial institutions with Iran’s Central Bank and other designated Iranian financial institutions;
iv. The provision of specialised financial messaging services to Iran’s Central Bank and other designated Iranian financial institutions;
v. The provision of underwriting services, insurance, or reinsurance for transactions with Iran;
vi. Iran’s energy sector.
If you are thinking of entering into a specific contract or transaction and are concerned as to whether the sanction regimes apply, you should consult your legal advisors.
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