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International Group FAQs on EU Regulation 267 2012

The International Group has issued an updated FAQ document dated 25 May 2012 covering the impact of EU Regulation 267/2012 dated 23 March 2012, which concerns further sanctions measures against Iran pursuant to the EU Council Decision 2012/35/CFSP of 23 January 2012 and which also incorporates (and expands) the measures which were contained in EU Regulation 961/2010 of 25 October 2010, notably:

  •        A ban on the import, purchase, or transport of Iranian crude oil, petroleum products and petrochemical products; and
  •        A ban on the provision, directly or indirectly, of financing or financial assistance, as well as insurance or reinsurance, related to those activities.

The new FAQs must be read in conjunction with the FAQs issued on 8 February 2012 in connection with EU Council Decision 2012/35/CFSP.

The new FAQs provide clarification of the following issues:

  •        The legal status of EU Council Regulation 267/2012;
  •        The effect of the “grace periods”;
  •        The cargo prohibitions in relation to LNG and LPG;
  •        The stemming of Iranian-origin bunker fuel;
  •        Impact on shipowners;
  •        Impact on the cover provided by the Clubs.

The Club has issued a circular ( B.575 and L.184 ) commenting on the revised IG FAQ document of 25 May 2012, and specifically on the impact on Club cover of the prohibitions in Articles 11 and 13 of EU Regulation 267/2012 on the purchase and transport of petroleum and petrochemical products, as these apply to Iranian-origin LPG and oil carried as bunker fuel on entered ships.

Copies of the latest FAQ as well as those of 8 February 2012 regarding EU Council Decision 2012/35/CFSP can be downloaded from the links set out below.

pdf file type
IG FAQs dated 8 Feb 2012 on EU Coucil Decision 2012/35/CFSP (2.45 MB)
pdf file type
IG FAQ on EU Regulation 267-2012 updated 25 May 2012.pdf (0.23 MB)