International Group FAQs on EU Council Decision 2012 35 CFSP
Club Circulars B. 567 and L. 176 referred to the EU Council Decision 2012/35/CFSP of 23 January 2012 (the "Decision"), which introduces new European measures to prohibit the trade and transportation of Iranian crude oil, petroleum products and petrochemical products, and the provision of insurance and reinsurance related to such activities. This Decision is binding on the governments of EU Member States but requires implementing legislation to bind individuals and corporate entities subject to EU jurisdiction. The International Group has met with the EU and the UK Treasury seeking clarification and guidance on the impact of the measures on these trades and related insurance and reinsurance cover arrangements.
Based on the discussions to date, all member Clubs of the International Group have approved the issuance of a provisional set of Frequently Asked Questions (FAQs) concerning the Decision, which can be downloaded from the link below. Members should be aware that any guidance at this stage may be subject to change in the light of further advice received and/or the issuance of a final implementing Regulation.
The Group will continue to engage with the EU and the UK Treasury with regard to further clarification on the scope of the application of the Decision and the final form of any implementing Regulation, and in relation to specific new issues arising. The FAQs will be periodically updated to reflect further clarification and guidance received. Until the entry into force of the Regulation, the guidance set out in the FAQs is advisory only and will be monitored on a continuing basis. Members are strongly advised to consult with the Managers in relation to any queries arising out of the potential application of the provisions of the Decision to their current or anticipated trading and associated activities to the extent that these may be impacted by the provisions of the Decision.
