Yesterday, OFSI and the EU reimposed sanctions on Iran under the JCPOA’s snapback provision. Here’s a breakdown of the key insights you need to understand to stay ahead.
Iran Sanctions Snapback: What You Need to Know:
The UK and EU have reimposed sanctions on most of Iran’s oil and petroleum industry, including major companies such as NIOC, NITC, and IRISL. The sanctions also target Iran’s financial sector, including key banks such as Bank Melli and Tejarat, as well as Iranian insurance companies.
EU sanctions broadly restrict many maritime services to Iran or Iranian entities. This includes the import and transport of Iranian oil and petroleum products through third countries (Articles 11–14), as well as maritime services such as bunkering (Article 37), ship classification and surveys (Article 37a), insurance (Article 35), and floating storage (Article 37b).
The snapback also restores previous restrictions, including export controls on Iran’s nuclear and ballistic missile programmes, limits on financing, and restrictions on oil field and exploration services.
What Does this Mean, and What is the Impact?
The EU sanctions are broad enough to block most maritime-related transactions, affecting not just tankers but other types of vessels as well. Enforcement will depend on each EU member state and the UK, but the sanctions are strong enough to close a gap in the Coalition’s previous approach to Russia and Iran. Hopefully, the US will also resume efforts against the Russian Dark Fleet.
From a practical standpoint, not much will change for Deep Blue Intelligence or PurpleTRAC customers, or for the majority of major bankers and commodities traders operating in Europe.
Clients of Pole Star Global and Blackstone Compliance Services’ Deep Blue Intelligence are already protected by the team’s robust monitoring of Iran’s and Russia’s Dark Fleet. Watchlists tracks over 1,350 tanker vessels, including more than 700 linked to known or suspected dealings with Iran. DBI clients have also received detailed training on how Iran evades sanctions at sea and through financial channels.
Complementing these capabilities, PurpleTRAC customers also benefit from this leading vessel screening and tracking solution. Users can screen vessels and related parties for sanctions, and receive automatic flags of dark fleet activity, spoofing, ship-to-ship transfers, and other risks highlighted in OFAC advisories.
It is particularly important for banks and commodities traders in Europe – many of whom already have sanctions policies restricting dealings with Iran or Iranian-origin oil – to review their procedures. Ensuring that your controls can detect attempts to evade Iran-related sanctions has never been more critical.
“I think, going forward, we should expect OFSI to become more active in Iran-related sanctions. OFSI has already targeted substantial portions of the Dark Fleet, including vessels dealing in both Russian and Iranian oil, and will continue to do so. The UK is also a powerful force within the shipping sector, as it is home to several major P&I clubs and commodities traders, and UK courts are frequently used to arbitrate maritime-related legal issues.” – David Tannenbaum, Director of Blackstone Compliance Services