How US sanctions may affect worldwide petroleum trade with Iran
Any company engaged in substantial business with Iran should have a contingency plan INTERTANKO has received a number of enquiries from Members regarding recent and proposed US sanctions on Iran. Jonathan Epstein, a partner in the Washington DC office of our Associate Member, Holland and Knight, has kindly provided the following commentary on this issue for the benefit of all Members.BeginsOn December 31, 2011, President Obama signed into law the National Defense Authorization Act For Fiscal Year 2012 ("NDAA" or "the Act"). Amended to and included in this major piece of legislation was Section 1245 ("Imposition of Sanctions with Respect to the Financial Sector of Iran"), which requires the President to sanction foreign financial institutions (e.g., foreign banks) that facilitate significant transactions with Iranian banks, particularly with respect to oil transactions.While there are grace periods for compliance, and considerable latitude given to the President to waive imposition of sanctions, the potential ramifications of this legislation are enormous for companies that operate tanker vessels carrying petroleum and petroleum products to and from Iran as, for the first time, the US has targeted transactions involving the export of crude oil from Iran to third countries.These new sanctions follow closely after the sanctions ...
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