On 21 December 2012, the Council of the European Union (EU) adopted the EU-wide legislation clarifying important details of the expanded sanctions measures already agreed by the Council in broad terms on 15 October 2012.1 Regulation 1263/20122 amends the existing Iran Sanctions Regulation (Regulation 267/2012)3 by introducing new sanctions elements into it. Through a separate regulation adopted on the same day, Implementing Regulation 1264/2012,4 the Council has also added more persons to the asset freeze list of the Iran Sanctions Regulation.

The general outline of new Iran sanctions measures established on 15 October 2012 results in a significant expansion of the EU’s sanctions regime against Iran. Our previous alert from 17 October 2012 provides a full list of these new sanctions elements, the most important being:

• a tightened ban on most EU bank transactions involving Iranian and Iranian-owned banks;

• a new ban on EU import, purchase and transport of Iranian natural gas (along with related financing and financial assistance)...

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