By way of background, on November 24, 2013, the United States and its partners in the P5+1 reached an initial understanding with Iran, outlined in a Joint Plan of Action (JPOA), that halts progress on Iran’s nuclear program. In return for Iran’s commitment to place limits on its nuclear program, the U.S. government committed to provide Iran sanctions relief for a six-month period. In furtherance of its commitments under the JPOA, the U.S. government has implemented limited sanctions relief relating to certain activities and associated services taking place exclusively during the six-month period beginning on January 20, 2014 and ending July 20, 2014. What follows below is a brief overview and general summary of the highlights of the most important aspects of the relief—note, however, that other sanctions relief that deals with autos, gold, and other precious metals is also addressed in the January 30 guidance. … [Read more...] about Temporary Iran Sanctions Relief
Nioc iran sanctions
Certain Iran-related activities are reportable by an “issuer” in periodic US Securities and Exchange Commission (SEC) reports pursuant to Section 13(r) of the Securities Exchange Act of 1934 (a/k/a Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012). It should be noted that such activities are reportable even though they might not be violations or otherwise sanctionable under US law. Issuers required to file an annual or quarterly report to the SEC must disclose if, during the period covered by the report, the issuer (or an “affiliate” of the issuer) engaged in certain Iran-related activities under Section 13(r)(1)(A) -13(r)(1)(D) of the Securities Exchange Act of 1934. … [Read more...] about Iran Secondary Sanctions Relaxation: Effect on Shipping and Related Activities
With those sanctions lifted, EU companies should have a clear path to resume significant business with Iran. However, if an EU company has U.S. teammates – if they have U.S. person employees or executives, have U.S. ownership, or even a supply chain that draws from the United States – the EU company will need to understand what goods, money, technology, or services from the United States can and cannot be used as the company looks to resume business with Iran. … [Read more...] about Implementation Day: Do the Rules Let You Play in the New Ballgame for Business in Iran?
Notwithstanding the deal regarding the JCPOA, “US Persons” are still currently prohibited from entering into executory contracts for Iran-related transactions until US sanctions are lifted after Implementation Day. "US persons" means US nationals, US permanent resident aliens ("Green Card holders"), entities incorporated in the United States, individuals or entities in the United States, or entities established or maintained outside the United States that are owned or controlled by a "US person.” For a "US person" to sign such an executory contract before Implementation Day would be dealing in property or an interest in property involving Iran or a Specially Designated National, which is prohibited by current US regulations as applicable to "US persons.” The current Iran sanctions regulations expressly state that such executory contracts are property or an interest in property because they involve "contracts of any nature whatsoever, and any other property, … [Read more...] about Potential Upstream Investment Under the New Iranian Petroleum Contract
To safeguard their supplies, state oil trader Zhuhai Zhenrong Corp and Sinopec Group, Asia's biggest refiner, have activated a clause in long-term supply agreements with National Iranian Oil Corp (NIOC) that allows them to use NITC-operated tankers, four sources with direct knowledge of the matter said. … [Read more...] about China defies U.S. pressure as EU parts ways with Iranian oil