US Sanctions Update

The Britannia P&I Club has issued an article regarding the current 26 US sanctions programmes administered by the US Office of Foreign Assets Control (OFAC)

US sanctions against Iran started in 1979, following the US Embassy hostage crisis. Sanctions were increased in 1984 and in 1996, with the passing of the Iran Sanctions Act. The 1996 Act was a response to the perceived threat of the Iranian nuclear programme and intended to discourage support for a number of groups that are considered by the US to be terrorist organisations. As a result, US persons are currently prohibited from engaging in virtually any transaction that has a connection with Iran.

In July 2010, sanctions against Iran were further bolstered by the Comprehensive Iran Sanctions, Accountability and Divestment Act (CISADA), which required non-US persons and companies to observe US sanctions. Sanctions affecting persons in or operating from another state are often referred to as secondary sanctions.

The enforcement of many of the provisions found in CISADA are the responsibility of the US State Department, rather than OFAC.

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Further legislation in the form of Presidential Executive Orders and the Iran Freedom and Counter-Proliferation Act (IFCA) 2012 followed.

OFAC also administers a blacklist of more than 6,000 individuals, businesses and groups, known as Specially Designated Nationals (SDNs). The assets of those listed are blocked and US persons, including US businesses and their foreign branches, are forbidden from transacting with them.

Shortly after the implementation of CISADA, the EU introduced its own direct and indirect financial restrictions and specific trade restrictions on Iran. The relevant EU sanctions apply to:

• any party within the EU;

• any ship under a Member State’s jurisdiction;

• any person, body or entity incorporated or constituted in a Member State; and

• any legal person doing business in the EU, including insurers, reinsurers and financial institutions within the EU.

Negotiations between the P5+1 and Iran began in 2013 in order to seek a resolution of the situation. In January 2014, both the US and EU suspended a limited number of sanctions2 for six months, in an attempt to encourage Iran to compromise. As negotiations continued, this suspension was extended; it is currently due to expire on 16 January 2016. On 14 July 2015, an ‘in principle’ agreement, known as the Joint Comprehensive Plan of Action (JCPOA) was finally agreed with Iran.

You may read the article ”Sanctions Update” at the following publication of the Britannia P&I Club