Worldwide: Snapshot Summary Of EU Sanctions On Iran

Last Updated: 26 January 2012
Article by Nigel Kushner
  • Ban On The Import, Purchase And Transport Of Iranian Crude Oil And Petroleum Products – Including Financing And Insuring, Directly Or Indirectly. However:
    • Contracts Already Concluded May Be Executed Until 1st July 2012;
    • Contracts Already Concluded Which Call For Iranian Crude Oil And Petroleum Products To Be Supplied For Reimbursement Of Outstanding Amounts May Be Executed – Including After 1st July 2012; And
    • A Review Of The Measures Will Take Place Before 1st May 2012.
  • Ban On The Import, Purchase And Transport Of Iranian Petrochemical Products – Including Financing And Insuring, Directly Or Indirectly. However:
    • Contracts Already Concluded May Be Executed Until 1st May 2012;
    • Contracts Already Concluded Which Call For Iranian Petrochemical Products To Be Supplied For Reimbursement Of Outstanding Amounts May Be Executed – Including After 1st May 2012;
  • Ban On The Sale, Supply Or Transfer Of Key Equipment And Technology For The Petrochemical Industry In Iran Or To Iranian Or Iranian Owned Enterprises Outside Iran – Including Technical Assistance Or Training And Other Related Services, Or Financing Related To It. However:
    • Contracts Already Concluded For The Sale, Supply, Or Transfer Of Such Equipment May Be Executed.
  • Ban On New Investments In Petrochemical Companies In Iran And Related Joint Ventures. However:
    • Obligations Prior To 26 July 2010 May Be Executed.
  • Additional Asset Freeze On 3 Individuals And 8 Entities (Including Bank Tejarat And Tidewater Middle East Company). However:
    • For A Period Of 2 Months From 24th January 2012, Payments To And From Bank Tejarat May Be Authorised On A Case By Case Basis By Member States So Long As The Payment Is Not Received Directly Or Indirectly By An Entity Subject To The Asset Freeze.
  • Assets Of The Central Bank Of Iran In The EU Are Frozen. However:
    • Transfers May Be Authorised On A Case By Case Basis By Member States For Specific Trade Contracts So Long As No Other Sanctioned Bank Is Involved And No Person Or Entity Subject To The Asset Freeze Will Receive The Monies.
  • Ban On Direct Or Indirect Sale, Purchase, Transportation Or Brokering Of Gold, Diamonds And Other Precious Metals To, From Or For Iranian Public Bodies And The Central Bank Of Iran;

Note On Tidewater Middle East Company ("Tidewater")

This Entity Must Not Be Confused With A US Entity With A Similar Name. Tidewater Is Subject To An Asset Freeze And Is Reported To Have Operations At Seven Of The Main Ports In Iran, Namely (I) The Shahid Rajaee Container Terminal At Bandar Abbas, (Ii) Bandar Imam Khomeini Grain Terminal, (Iii) Bandar Anzali, (Iv) One Terminal At Khorramshahr Port, (V) Assaluyeh Port, (Vi) Aprin Port And (Vii) Amir Abad Port Complex. The Asset Freeze States "No Funds Or Economic Resources Shall Be Made Available, Directly Or Indirectly, To Or For The Benefit Of [Tidewater]....." This Means That Any EU Entity Or Individual Involved "Directly Or Indirectly" In A Payment To Tidewater Is Potentially In Breach Of The EU Sanctions. This Will Include Payment Of Port Dues.

The Oil Embargo

The EU Crude Oil Ban Mainly Impacts Greece, Italy And Spain, The Only EU Members Who Import Iranian Oil (Although EU Traders Are Also Impacted) But In Fact This Ban Will Not Take Effect Until 1st July.

Subject To Other Factors, We Expect To See A Decrease In The Price Of Iranian Oil. This Emanates Not Only From The EU Ban But More Likely As A Result Of Pressure Being Placed By The US On Other Buyers Of Iranian Oil To Cease Doing So. The US Has Had Mixed Success To Date. However, We May See A Shift In Approach With The US Facing Reality That They Cannot Force The Likes Of China And India To Cease Buying Iranian Oil. The US May Instead Request That Those Who Buy Iranian Oil Insist On Steep Discounts, In An Attempt To Damage The Iranian Economy.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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