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IG FAQs Enforcement against Foreign Persons of US Iran Trade Sanctions

I.G. FAQs REGARDING ENFORCEMENT AGAINST FOREIGN PERSONS OF U.S. TRADE SANCTIONS AGAINST IRAN - MARCH 2013

The International Group has published FAQs on the range of US sanctions measures in respect of Iran and their potential effect on the shipping and insurance sectors.  The FAQs summarise the relevant statutory enactments and Executive Orders applicable to foreign persons, and the practical implications of the sanctions regime. The US sanctions regime in respect of Iran is now very broad and many provisions have extra territorial effect.  Persons considering carrying out business with an Iranian connection may wish to consider obtaining legal advice to avoid inadvertent violations.  A copy of the FAQs can be downloaded from the link set out below.

 

UPDATE - REVISED I.G. FAQS PUBLISHED 4 JUNE 2013

As U.S. sanctions measures in respect of Iran continue to evolve, the I.G. has updated the FAQ's previously published in March 2013.  Of particular note are:

Section 6 - clarification of the impact from 1 July 2013 of NDAA 2013, which will result in foreign persons facing the same civil and criminal penalties as are prescribed against U.S. persons under the International Emergency Powers Act ("IEEPA");

Section 10 - commentary on State Department guidance on types of policies and procedures that insurers might adopt in order to demonstrate the exercise of due diligence so as to avail of exemptions from sanctions written into various U.S. measures, including Section 102 of The Comprehensive Iran Sanctions, Accountability and Divestment Act 2010 (CISADA), Section 212 of The Iran Threat Reduction and Syria Human Rights Act of 2012 of 10 August 2012, and Section 1246 of NDAA 2013;

Section 14 - in the context of the prohibition in Executive Order 13622 on knowingly engaging in a "significant transaction for the purchase or acquisition" from Iran of petroleum, petroleum products or petrochemical products", whether bunkers of Iranian origin may be caught. As a matter of prudence Members should enquire as to the origin of bunkers to satisfy themselves that they do not contain any Iranian origin components. 

Copies of the old and new FAQs can be downloaded from the links set out below.

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IG FAQs ON ENFORCEMENT AGAINST FOREIGN PERSONS OF US IRAN TRADE SANCTIONS - 12 MARCH 2013 (0.27 MB)
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IG FAQs ENFORCEMENT OF SANCTIONS AGAINST FOREIGN PERSONS REVISED JUNE 2013 (0.17 MB)