Iranian Sanctions update

The publication of the International Atomic Energy Agency's latest report on Iran has prompted a fresh round of sanctions against Iran. Attached to this briefing is an updated table of sanctions targets.

UK Sanctions

The Financial Restrictions (Iran) Order 2011 came into force at 3 p.m. on 21 November. Pursuant to the terms of the Order, all persons operating in the UK financial sector (being credit and financial institutions and branches of such persons, wherever those branches are located), are directed that they must not enter into, or continue to participate in, any transaction or business relationship with any of the following ("designated persons"):

All banks incorporated in Iran All subsidiaries and branches of banks incorporated in Iran, wherever located The Central Bank of Iran, also known as Bank Markazi Jomhouri Islami Iran The case remains that there is not a trade ban with all Iranian companies, although the UK Government does not encourage such trade.

Any person affected by the Order can apply to the Treasury for a licence exempting a transaction or relationship, although it is unlikely to issue licences for business with Iranian banks on an ongoing basis under new contracts. The Treasury has also issued six general licences:

transactions for or related to humanitarian activities or purposes, including the export of medical equipment or foodstuffs and the provision of healthcare, under €40,000; transactions for or related to personal remittances (that is, payments between persons acting in a non-commercial, private capacity, the payments not being made in the course of a business), under €40,000; transactions in relation to the provision of insurance which is permitted under Article 26(2) and (3) of Regulation (EU) No. 961/2010 against Iran; holding of asset-frozen Iranian banks' accounts; holding accounts of non-frozen Iranian banks; completion of payments to or from Iranian banks in progress at the time of the Direction coming into force. The notice to exporters issued by the Export Control Organisation includes the following guidance:

Q12: Are banks in other EU countries affected by this? A12: No

Q13: My bank wasn't letting me do business with Iran anyway. What's changed? A13: That would have been a commercial decision for your bank. Now it is subject to UK law.

EU Sanctions

It is anticipated that the outcome of a meeting of EU foreign ministers on 1 December 2011 will be a further EU Regulation, likely to target industries...