Background and Regulation: Last week the European Union (“EU”) introduced further restrictive measures against Iran in light of Iran’s failure to engage in negotiations to address deepening international concerns over the nature of its nuclear programme.
These sanctions add to and amend Council Regulation No 267/2012, published on 23 March 2012 (“Regulation 267/2012”). As you will recall, Regulation 267/2012 prohibits:
(i) the import into the EU or the purchase or transport (worldwide) of crude oil, petroleum products or petrochemical products originating from or located in Iran;
(ii) the financing, financial assistance (including financial derivatives and insurance and reinsurance) relating to the import into the EU or the purchase or transport of crude oil, petroleum products or petrochemical products originating from or located in Iran; and
(iii) the making of funds and/or economic resources available to the specific persons/entities listed in Annex IX to Regulation 267/2012.
Annex IV lists the crude oil and petroleum products and Annex V lists the petrochemical products referred to in Regulation 267/2012. These lists are wide-ranging and designed to capture any and all transactions in relation to these products.
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